The company’s senior leadership should exercise oversight over how its policies and practices affect freedom of expression and information, and privacy.
Elements:
- Does the company clearly disclose that the board of directors exercises formal oversight over how company practices affect freedom of expression and information?
- Does the company clearly disclose that the board of directors exercises formal oversight over how company practices affect privacy?
- Does the company clearly disclose that an executive-level committee, team, program or officer oversees how company practices affect freedom of expression and information?
- Does the company clearly disclose that an executive-level committee, team, program or officer oversees how company practices affect privacy?
- Does the company clearly disclose that a management-level committee, team, program or officer oversees how company practices affect freedom of expression and information?
- Does the company clearly disclose that a management-level committee, team, program or officer oversees how company practices affect privacy?
Definitions:
Board of directors — Board-level oversight should involve members of the board having direct oversight of issues related to freedom of expression and privacy. This does not have to be a formal committee, but the responsibility of board members in overseeing company practices on these issues should be clearly articulated and disclosed on the company’s website.
Clearly disclose(s) — The company presents or explains its policies or practices in its public-facing materials in a way that is easy for users to find and understand.
Executive-level oversight — The executive committee or a member of the company’s executive team.
Management-level — A committee, program, team, or officer that is not part of the company’s board of directors or the executive team.
Oversight / oversee — The company’s governance documents or decision-making processes assign a committee, program, team, or officer with formal supervisory authority over a particular function. This group or person has responsibility for the function and is evaluated based on the degree to which it meets that responsibility.
Senior Leadership— CEO and/or other members of the executive team as listed by the company on its website or other official documents such as an annual report. In the absence of a company-defined list of its executive team, other chief-level positions and those at the highest level of management (e.g., executive/senior vice president, depending on the company) are considered senior executives.
Indicator guidance: This indicator seeks evidence that the company has strong governance and oversight over freedom of expression and information and privacy issues at all levels of its operations. Companies should clearly disclose that senior leadership–from the board to management level–oversees and is accountable for its policies and practices affecting these human rights.
To receive full credit for this indicator, companies need to clearly disclose that, at each governance level (board, executive, managerial), there is clear oversight of both freedom of expression and information, and privacy issues. At the board level, this oversight could include a board of directors or another public explanation of how the board exercises oversight over these issues. Below board level, it can include a company unit or individual that reports to the executive or managerial level. The committee, program, team, officer, etc. should specifically identify freedom of expression and privacy in its description of responsibilities.
Potential sources:
- List of board of directors
- Company governance documents
- Company sustainability report
- Company organizational chart
- Company human rights policy
- Global Network Initiative documents (if company is a member)
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