G3. Internal implementation

1. Does the company clearly disclose that it provides employee training on freedom of expression and privacy issues?
2. Does the company clearly disclose that it maintains an employee whistleblower program through which employees can report concerns related to how the company treats its users’ freedom of expression and privacy rights?

While Indicator G2 evaluates whether company leaders at the senior governance level commit to overseeing freedom of expression and privacy issues, this indicator, G3, evaluates if the company discloses whether and how it institutionalizes these commitments within the company.

This indicator seeks disclosure about how the company helps the rest of its employees understand the importance of freedom of expression and privacy. When employees write computer code for a new product, review requests for user data, or answer customer questions about how to use a service, they act in ways that can directly affect people’s freedom of expression and privacy. We expect companies to disclose information about whether they provide training that informs employees of their role in respecting human rights and that provides employees with an outlet to voice concerns they have regarding human rights.

A company can only receive full credit on this indicator if it clearly discloses information about employee training on freedom of expression and privacy and the existence of a whistleblower program that also encompasses these issues. Disclosure should specify that employee training and whistleblower programs cover freedom of expression and privacy. Companies may still receive credit on this indicator if a company’s whistleblower program does not specifically mention complaints related to freedom of expression and privacy so long as the company has made commitments to these principles elsewhere and in a way that makes clear that the company would entertain those complaints through their whistleblower program.

Potential sources:

• Company code of conduct
• Employee handbook
• Company organizational chart
• Company CSR/sustainability report
• Company blog posts