2020 RDR Index methodology

1. About the 2020 RDR Index methodology

The RDR Index offers a road map companies can use to improve. It also provides a tool for researchers, advocates, policymakers, and investors to push companies in the right direction. Our theory of change is based on the power of benchmarking companies with indicators that set high but achievable standards for corporate transparency and policies that align with internationally recognized human rights standards.

The 2020 RDR Index evaluates 26 companies on 58 indicators in three main categories: governance, freedom of expression and information, and privacy. Below we summarize what we evaluate in each category.

Understanding the impact of 2020 methodology revisions on company scores

In 2020, we applied an expanded methodology that allowed us to examine a broader range of threats that platforms and telecommunications companies pose to people’s rights. Our 2020 methodology includes new benchmarks for what companies should disclose about their algorithmic systems and targeted advertising practices. We did this in order to better hold companies accountable for the technologies and systems that fuel the Big Tech business model—and that so often drive the spread of disinformation and harmful speech online. We also added Amazon and Alibaba to this year’s ranking, enabling us to assess the human rights commitments and policies of two of the world’s biggest online retailers.

How did this impact the overall scores?

Changes to the methodology resulted in significant score declines for most companies in our ranking, particularly U.S. platforms. The figure below shows the difference between the total 2019 and 2020 scores. This shows that despite some improvements, overall scores went down for the majority of the companies because of methodology changes. Our new standards on algorithms and targeted advertising underline the fact that most companies are disclosing very, very little about these systems.

The biggest decline in scores can be observed among what were previously the top-scoring companies—Google, Microsoft, Facebook, AT&T, Deutsche Telekom, Vodafone, and Verizon—with the exception of Twitter and Apple, which were the least affected by the new indicators among the U.S. platforms.

Twitter’s disclosures on the new indicators in the Freedom of expression and information category drove its relatively strong performance on those indicators, thus cushioning the impact that many of its peers felt the most. Similarly, Apple’s results on the new indicators addressing transparency around ad targeting policies and users’ control over the use of user information resulted in the smaller negative impact of the new indicators compared to its U.S. peers.

It is also worth noting that some companies with positive score changes, such as Etisalat, Axiata, and Baidu, disclosed much less about their policies and practices than the companies mentioned above. While they did make important improvements in this index cycle, on balance they have much further to go.

2. Companies included in the 2020 RDR Index

The 2020 RDR Index evaluates 26 companies, listed below. Researchers examine overarching “parent” company policies and practices, in addition to the disclosed policies and practices of selected services and/or local operating companies, depending on company structure.

Digital platform companies: The 2020 RDR Index evaluates 14 digital platform companies. This includes all of the 12 digital platform companies evaluated previously plus two new companies (Amazon and Alibaba). For each of these companies we evaluate global group-level policies for relevant indicators plus policies in the companies’ home market. (For example: we evaluate Facebook’s privacy policy that is applicable to users in the U.S.)

For each company we examine up to five services, as follows:

• Alibaba (China)—Taobao.com (e-commerce platform), AliGenie (personal digital assistant ecosystem)
• Amazon (U.S.)—Amazon.com (e-commerce platform), Amazon Alexa (personal digital assistant ecosystem), Amazon Drive
• Apple (U.S.)—iOS mobile ecosystem, iMessage, iCloud
• Baidu (China)—Baidu Search, Baidu Cloud, Baidu PostBar
• Facebook (U.S.)—Facebook, Instagram, WhatsApp, Messenger
• Google (U.S.)—Google Search, Gmail, YouTube,Android mobile ecosystem, Google Drive
• Kakao (South Korea)—Daum Search, Daum Mail, KakaoTalk
• Mail.Ru (Russia)—VK, Mail.Ru email, Mail.Ru Agent messaging, Mail.Ru Cloud
• Microsoft (U.S.)—Bing, Outlook.com, Skype, OneDrive
• Samsung (South Korea)—Samsung implementation of Android, Samsung Cloud
• Tencent (China)—QZone, QQ, WeChat, Tencent Cloud
• Twitter (U.S.)—Twitter
• Verizon Media (U.S.)—Yahoo Mail
• Yandex (Russia)—Yandex Mail, Yandex Search, Yandex Disk

Telecommunications companies: The 2020 RDR Index ranked all of the 12 telecommunications companies we previously ranked. No new companies were added for the 2020 research cycle. For each of these companies we evaluate global group-level policies for relevant indicators plus the home-country operating subsidiary's prepaid and postpaid mobile service, and fixed-line broadband service where offered, as follows:

• América Móvil (Mexico)—Telcel (pre- and postpaid mobile only)
• AT&T (U.S.)—AT&T
• Axiata (Malaysia)—Celcom
• Bharti Airtel (India)—Airtel India
• Deutsche Telekom AG (Germany)—Deutsche Telekom
• Etisalat (UAE)—Etisalat UAE
• MTN (South Africa)—MTN South Africa
• Ooredoo (Qatar)—Ooredoo Qatar
• Orange (France)—Orange France
• Telefónica (Spain)—Movistar
• Telenor ASA (Norway)—Telenor
• Vodafone (UK)—Vodafone UK

Company selection

• User base: The telecommunications companies in the RDR Index have a substantial user base in their home markets and beyond, and the digital platforms have a large number of global users. The policies and practices of these companies affect billions of people worldwide.
• Geographic reach and distribution: The RDR Index includes companies that are headquartered in North America, Europe, Africa, Asia, and the Middle East. Several of them operate globally and offer services in almost every country in the world.
• Relevance to users’ freedom of expression and privacy rights: Most of the companies in the RDR Index operate in or have a significant user base in countries where human rights are not universally respected. We consulted relevant research from such organizations as Freedom House, the World Wide Web Foundation, and Reporters Without Borders as well as stakeholder feedback.

3. What the 2020 RDR Index evaluates

The 2020 RDR Index evaluates companies on 58 indicators in three main categories: Governance, Freedom of expression and information, and Privacy. Each category contains multiple indicators, each of which comprises a series of elements or questions, that enable researchers to evaluate company disclosure for that category.

Governance: Indicators in this category seek evidence that the company has robust governance processes in place to ensure that it respects the human rights to freedom of expression, information, and privacy. These rights are part of the Universal Declaration of Human Rights (UDHR), and are enshrined in the International Covenant on Civil and Political Rights (ICCPR). They apply online as well as offline.^[1] In order for a company to perform well in this category, the company’s disclosure should at least follow, and ideally surpass, the UN Guiding Principles on Business and Human Rights (UNGPs) and other industry-specific human rights standards focused on freedom of expression and privacy such as those adopted by the Global Network Initiative.

Indicators in this category look for companies to disclose:

• Commitment to human rights: An explicit public commitment to freedom of expression and privacy as human rights, including an explicit commitment to protect human rights in their development and deployment of algorithmic systems (G1).

• Governance management and oversight: Clear evidence of senior-level management and oversight over freedom of expression and privacy (G2).

• Internal implementation: Employee training and whistleblower programs addressing these issues (G3).

• Human rights due diligence to identify and mitigate the potential risks of companies’ products, services, and business operations (Indicator G4). Indicator G4 consists of a family of indicators that address whether companies provide evidence of conducting robust, systematic risk assessments of government regulations (Indicator G4a), policy enforcement (Indicator G4b), targeted advertising policies and practices (Indicator G4c), algorithmic systems (Indicator G4d), and zero-rating (Indicator G4e).

• Stakeholder engagement: Systematic and credible stakeholder engagement, ideally including membership in a multi-stakeholder organization committed to human rights principles, including freedom of expression and privacy (Indicator G5).

• Remedy: Clear, predictable grievance mechanisms enabling users to notify companies when their freedom of expression and privacy rights have been affected or violated in connection with the companies’ business, plus evidence that the company provides appropriate responses or remedies (Indicator G6a). We also look for platforms to disclose similarly clear, predictable processes enabling users to appeal content moderation decisions (Indicator G6b).

Freedom of expression and information: Indicators in this category seek evidence that the company demonstrates it respects the right to freedom of expression and information, as articulated in the UDHR, the ICCPR, and other international human rights instruments. The company’s disclosed policies and practices demonstrate how it works to avoid contributing to actions that may interfere with this right, except where such actions are lawful, proportionate, and for a justified purpose. Companies that perform well on this indicator demonstrate a strong public commitment to transparency not only in terms of how they respond to government and others’ demands, but also in how they determine, communicate, and enforce private rules and commercial practices that affect users’ fundamental right to freedom of expression and information.

In this category, we evaluate:

• Access to policies: We expect companies to ensure that policies affecting users’ freedom of expression and information rights are easy to find and understand. Terms of service or community guidelines that specify what types of content or activities are prohibited should be easy to access from a service’s main web page or app, be available in the primary languages of the company’s home market, and presented in an easy to read format. We also expect companies to clearly disclose if and how they directly notify users of changes to these policies (Indicators F1, F2).

• Terms of service enforcement:We expect companies to clearly disclose what types of content and activities are prohibited and their processes for enforcing these rules (Indicator F3a). We also expect companies to publish data about the volume and nature of content and accounts they have removed or restricted for violations to their terms (Indicators F4a and F4b), and to disclose if they notify users when they have removed content, restricted a user’s account, or otherwise restricted access to content or a service (Indicator F8).

• Ad content and ad targeting rules and enforcement: Companies that enable any type of advertising on their services or platforms should clearly disclose the rules for what types of ad content is prohibited (for example, ads that discriminate against individuals or groups based on personal attributes like age, religion, gender, and ethnicity) (Indicator F3b). Companies that enable advertisers and other third parties to target their users with tailored ads or content should have clear policies describing their ad targeting rules and what targeting parameters (like using certain types of audience categories, like age, location, or other user characteristics)are not permitted (Indicator F3c). Companies should also disclose their processes for identifying breaches to ad content and targeting rules and provide evidence that they are enforcing these policies by publishing data about content removed for violations (Indicator F4c).

• Algorithmic system use and curation policies: Companies should also publish policies that clearly describe the terms for how they use algorithmic systems across their services and platforms (Indicator F1d). Similar to having terms of service policies or user agreements that outline the terms for what types of content or activities are prohibited, companies that use algorithmic systems should publish a clear and accessible policy stating the nature and functions of these systems, because of the potential of these systems to cause human rights harms. Companies should publish clear policies describing their use of algorithmic curation, recommendation, and ranking systems, including the variables that influence such systems (Indicator F12).
• Government and private demands: We expect companies to clearly disclose their process for responding to government and private demands to restrict content and user accounts (Indicators F5a, F5b). We expect companies to produce data about the types of requests they receive and the number of these requests with which they comply (Indicators F6, F7). Private requests for content restrictions can come from a self-regulatory body such as the Internet Watch Foundation, or through a formal notice-and-takedown system, such as the U.S. Digital Millennium Copyright Act.

• Identity policies: We expect companies to disclose whether they ask users to verify their identities using government-issued ID or other information tied to their offline identities (Indicator F11). The ability to communicate anonymously is important for the exercise and defense of human rights around the world. Requiring users to provide a company with identifying information presents human rights risks to those who, for example, voice opinions that do not align with a government’s views or who engage in activism that a government does not permit.

• Network management and shutdowns: Telecommunications companies can shut down a network, or block or slow down access to specific services on it. We expect companies to clearly disclose if they engage in practices that affect the flow of content through their networks, such as by throttling or traffic shaping (Indicator F9). We also expect companies to clearly disclose their policies and practices for handling government network shutdown demands (Indicator F10). We expect companies to explain the circumstances under which they might take such action and to report on the requests they receive and with which they comply.

Privacy: Companies demonstrate concrete ways in which they respect the right to privacy of users, as articulated in the UDHR, the ICCPR, and other international human rights instruments, with indicators in this category. The company’s disclosed policies and practices should demonstrate how it works to avoid contributing to actions that may interfere with users’ privacy, except where such actions are lawful, proportionate, and justified. They will also demonstrate a strong commitment to protect and defend users’ digital security. Companies that perform well on these indicators demonstrate a strong public commitment to transparency not only in terms of how they respond to government and private party demands, but also how they determine, communicate, and enforce private rules and commercial practices that affect users’ privacy.

In this category, we evaluate:

• Collection and handling of user information: Companies should clearly disclose each type of user information they collect (P3a), infer (P3b), and share (P4), for what purposes (P5), and for how long they retain it (P6). We also expect companies to give users control over their own information, which should include options for users to control how their information is used for advertising purposes and development of algorithmic systems, and turning off targeted advertising by default (P7). Companies should also allow users to obtain all of the information a company holds on them (P8) and should clearly disclose if and how they track people across the web using cookies, widgets, or other tracking tools embedded on third-party websites (P9).

• Security: We expect companies to clearly disclose internal measures they take to keep their products and services secure (Indicator P13), explain how they address security vulnerabilities when they are discovered (Indicator P14), and outline their policies for responding to data breaches (Indicator P15). We also expect companies to disclose that they encrypt user communications and private content (Indicator P16), that they enable features to help users keep their accounts secure (Indicator P17), and to publish materials educating users about how they can protect themselves from cybersecurity risks (Indicator P18).

• Government and private demands: We expect companies to clearly disclose their process for responding to government and private demands to hand over user information (Indicators P10a, P10b). We expect companies to produce data about the types of requests they receive and the number of these requests with which they comply (Indicators P11a, P11b).

4. RDR Index methodology development

The RDR Index methodology has been developed over years of research, testing, consultation, and revision. Since its inception in 2013, the project has engaged closely with researchers around the globe. For the methodology development and pilot study of the inaugural 2015 RDR Index, we partnered with Sustainalytics, a leading provider of ESG (environmental, social, and governance) research to investors.

4.1 The 2020 RDR Index methodology expansion and development

Since its launch in 2015, the RDR Index has contributed to improved company disclosure of policy and practice across a number of areas, including transparency reporting, content removals, account restrictions, network shutdowns, and handling and securing user information. However, given the geopolitical and technological developments with clear human rights implications that have taken place in the years since the RDR Index methodology was first developed, it became clear that the methodology needed to be updated if companies are to be held fully accountable for the range of potential online threats to human rights.

In January 2019, RDR began a process of expanding and revising the methodology to include new issue areas and new company types. This work has focused on three main areas:

• Improving methodology: We reviewed the 2019 RDR Index methodology to identify key areas for revision and improvement.
• Incorporating new indicators on targeted advertising and algorithms: Since early 2019, RDR has been developing new indicators that set global accountability and transparency standards for how companies can demonstrate respect for human rights online as they develop and deploy these new technologies. In October 2019, RDR published draft indicators on targeted advertising and algorithms, based on nearly a year of internal research and feedback from more than 90 stakeholders. These draft indicators were pilot-tested by the RDR research team. The results of this pilot study were published in March 2020.

• Incorporating new companies: In early 2019, we began the process of research and public consultation on ways to expand the RDR Index to include Amazon and Alibaba. This process laid the groundwork for incorporating two new services—e-commerce platforms and virtual assistants (what we call “personal digital assistant ecosystems”)—into the 2020 RDR Index methodology.

In April 2020, RDR published a draft version of the final 2020 RDR Index methodology, which integrated work across these three areas. We then opened a final round of public consultation to solicit feedback from key stakeholders, which informed decisions we made as we finalized the methodology.

Visit https://rankingdigitalrights.org/2020-indicators to read the full text of our indicators for 2020.

4.2 Expanded human rights scope

Integrating new indicators on targeted advertising and algorithmic systems required us to expand the methodology to include a broader scope of human rights. In addition, integrating new platforms like Amazon and Alibaba required us to rename the “internet and mobile ecosystem” company category.

The RDR Index focuses on two fundamental human rights: freedom of expression (UDHR article 19) and privacy (UDHR art. 12). We do so because these two human rights are most directly affected by the companies ranked in the RDR Index and because the ability to exercise these rights unlocks the ability to exercise many other human rights. If freedom of expression and privacy rights are not protected and respected, people cannot use technology effectively to exercise and defend political, religious, economic, and social rights. Indeed, as a set of human rights risk scenarios published by RDR in 2019 highlighted, companies’ failure to respect privacy and freedom of expression can cause or contribute to a range of other human rights violations.^[2]

While the RDR Index methodology cannot address the full range of human rights harms associated with the companies it ranks (for example, labor and environmental rights are beyond our scope), two areas can and must be expanded: freedom of information (UDHR art. 19) and freedom from discrimination (UDHR arts. 7 and 23):

• Freedom of expression and information.The right to receive and impart information falls within the scope of the fundamental right to freedom of expression. Therefore we revised the category name to “Freedom of Expression and Information.”

• Freedom from discrimination. Targeted advertising business models and algorithmic systems are two closely related tools that carry high risks of discrimination harms. In addition to posing critical risks to privacy and freedom of expression and information, these technologies can also threaten the right to non-discrimination. These discrimination harms are enabled by the mass data collection practices of companies in service of targeted advertising business models. They are enacted through algorithmic decision-making systems whose design can replicate and reinforce existing patterns of discrimination. This constitutes discrimination in the most basic sense of the definition: “the practice of treating particular people, companies, or products differently from others, especially in an unfair way.”^[3]

Because discrimination harms are tightly interwoven with freedom of expression, information, and privacy harms, we have opted to integrate indicators and elements that assess companies’ respect for freedom from discrimination within the existing RDR Index categories (Governance, Freedom of Expression and Information, and Privacy) rather than creating a new category focused on discrimination.

4.3 New indicators on targeted advertising and algorithmic systems

In January 2019, RDR began the process of drafting new indicators on targeted advertising and algorithmic systems for integration into the 2020 RDR Index methodology.

In October 2019, RDR published draft indicators on targeted advertising and algorithms, based on nearly a year of internal research and feedback from more than 90 expert stakeholders. These draft indicators were tested by the RDR research team and the results of this pilot were published in March 2020. These indicators were then revised and integrated into a draft version of the 2020 RDR Index methodology, published in April 2020.

The final version of the 2020 RDR Index methodology sets key baseline standards of corporate transparency for the development and use of algorithmic systems in a way that minimizes human rights harms. New indicators and elements ask companies to publish a formal policy articulating their commitments to respect human rights as they develop and deploy algorithmic systems. New indicators also ask companies to publish overarching policies that describe how algorithms are developed and deployed across their platforms and services.

In addition, the 2020 RDR Index methodology includes new indicators aimed at holding companies accountable for their targeted advertising policies and practices. We ask companies to conduct robust human rights impact assessments on how targeted advertising may affect users’ fundamental rights to expression, information, and non-discrimination. New indicators also ask companies to clearly disclose rules around ad targeting and how those rules are enforced.

4.4 Company categories

The inaugural 2015 RDR Index evaluated two main company types: internet companies and telecommunications companies. For the 2017 RDR Index, we expanded the internet company category to include mobile ecosystems, which enabled us to add Apple iOS, the Google Android operating system, and Samsung’s implementation of Android to our ranking.

With the expansion of the 2020 RDR Index to include new services offered by Amazon and Alibaba—e-commerce platforms and personal digital assistant ecosystems—we have renamed the “internet and mobile ecosystem” category “digital platforms,” the scope of which includes a range of products and services offered by internet companies, as well as mobile ecosystems, e-commerce platforms, and personal digital assistant ecosystems. Indicators and elements that previously applied specifically to internet and mobile ecosystem companies have been expanded to apply to “digital platforms.”

4.5 Incorporation of new companies: Amazon and Alibaba

In early 2019, we began the process of research and public consultation on ways to expand the RDR Index to include Amazon and Alibaba. As two of the world’s largest digital platforms, Amazon and Alibaba’s absence from the RDR Index was a critical gap in our ranking. There have been growing concerns about both companies’ privacy practices and respect for human rights in general. Amazon collects an enormous amount of information about people, notably through its e-commerce platform and through its dominance in the personal digital assistant ecosystem market, mainly due to its Alexa software. Alibaba’s handling of user data, including its practice of sharing user data with its credit-scoring arm and other third-party services without explicit consent, has also raised concerns.

In July 2019, we published a set of public consultation documents that synthesized our approach to incorporating these companies into the RDR Index:

• Rationale for RDR’s methodology expansion to include Amazon and Alibaba: an overview of why and how the RDR research team is approaching the addition to the RDR Index.
• Human rights risk scenarios: a list of “risk scenarios,” each describing human rights harms directly or indirectly related to privacy and expression that can result from e-commerce and personal digital assistant ecosystem businesses.
• Best practices: a number of best practices for company disclosure and policy that could help prevent or mitigate these risks.

This background research laid the groundwork for incorporating e-commerce platforms and personal digital assistant ecosystemsinto the 2020 RDR Index methodology.

We integrated e-commerce platforms into our methodology without having to create any new indicators or elements unique to these types of services. While the privacy risks posed by e-commerce platforms may be more evident, these platforms can also affect users’ fundamental rights to expression and information. We therefore opted to apply indicators in the Freedom of Expression and Information category to e-commerce platforms.

To integrate personal digital assistant (PDA) ecosystems, we added separate elements to various indicators, similar to our approach when integrating mobile ecosystems into the RDR Index methodology in 2017. While many mirror the elements that apply to mobile ecosystems, we opted to separate elements for PDA ecosystems so that we could highlight these ecosystems’ unique features.

The incorporation of PDA ecosystems also required us to develop the following explanatory terms or definitions:

• Personal digital assistant (PDA) ecosystem refers to an artificial intelligence-powered interface installed on digital devices that can interact with users through text or voice to access information on the internet and perform certain tasks with personal data shared by the users. Users can interact with PDA ecosystems through skills, which are either made available by third-party developers/providers or the PDA itself.

• Skills are voice-driven personal digital assistant capabilities allowing users to perform certain tasks or engage with online content using devices equipped with a personal digital assistant. Personal digital assistant ecosystem skills are similar to mobile ecosystem apps: users can enable or disable built-in skills or install skills developed by third parties through stores similar to app stores.

• Skill store is the platform through which a company makes its own skills as well as those created by third-party developers available for download. A skill store (or skill marketplace) is a type of digital distribution platform for computer software.

These definitions have been added to the 2020 RDR Index glossary, which is appended at the end of the 2020 RDR Index methodology.

5. Research process and steps

RDR works with a network of international researchers who collect data on each company and evaluate company policies in the language of the company’s operating market. RDR’s external research team for the 2020 RDR Index consisted of 32 researchers from 17 countries.

A list of our partners and contributors can be found on our affiliates page.

The research process for the 2020 RDR Index consisted of rigorous cross-checking and internal and external review, as follows:

• Step 1: Data collection. A primary research team collected data for each company and provided a preliminary assessment of company performance across all indicators.

• Step 2: Secondary review. A second team of researchers fact-checked the assessment provided by primary researchers in Step 1.

• Step 3: Review and reconciliation. RDR research staff examined the results from Steps 1 and 2 and resolved any differences.

• Step 4: First horizontal review. Research staff cross-checked the indicators to ensure they had been evaluated consistently for each company.

• Step 5: Company feedback. Initial results were sent to companies for comment and feedback. All feedback received from companies by our deadline was reviewed by RDR staff,who made decisions about score changes or adjustments.

• Step 6: Second horizontal review. Research staff conducted a second horizontal review, cross-checking the indicators for consistency and quality control.

• Step 7: Final scoring. The RDR team calculated final scores.

6. Evaluation and scoring

RDR Index scores are based on an evaluation of company disclosure on several levels—at the parent company level, the operating company level (for telecommunications companies), and the service level. This enables the research team to develop as complete an understanding as possible about how companies disclose or apply their policies.

For digital platforms, we typically evaluated policies of the parent company and those of each service we selected. For telecommunications companies, with the exception of AT&T, the parent company did not directly provide consumer services, so researchers also examined a subsidiary or operating company based in the home market to ensure that the RDR Index captured operational policies alongside corporate commitments. Given AT&T’s external presentation of its group-level and U.S. operating company as an integrated unit, we evaluated the group-level policies for AT&T.

Research for the 2020 RDR Index was based on company policies that were active between February 9, 2019 and September 15, 2020. New information published by companies after that date was not evaluated.

Scoring: Companies receive an average score of their performance across all RDR Index indicators. Each indicator has a list of elements, and companies receive credit (full, partial, or no credit) for each element they fulfill. The evaluation includes an assessment of disclosure for every element of each indicator, based on one of the following possible answers:

• “Yes”/ full disclosure: Company disclosure meets the element requirement.

• “Partial”: Company disclosure has met some but not all aspects of the element, or the disclosure is not comprehensive enough to satisfy the full scope of the element.

• “No disclosure found”: Researchers were unable to find information provided by the company on its website that answers the element question.

• “No”: Company disclosure exists, but it specifically does not disclose to users what the element is asking. This is distinct from the option of “no disclosure found,” although both result in no credit.

• “N/A”: Not applicable. This element does not apply to the company or service. Elements marked as N/A will not be counted for or against a company’s score.

Points

• Yes/full disclosure = 100
• Partial = 50
• No = 0
• No disclosure found = 0
• N/A = excluded from score and averages

7. Company engagement

Proactive and open stakeholder engagement has been a critical component of RDR’s work and of the RDR Index methodology. We communicated with companies throughout the research process.

Open dialogue and communication. Before the research began, we contacted all 26 companies and informed them that they would be included in the 2020 RDR Index, describing our research process and timeline. Following several stages of research and review, we shared each company’s initial results with them. We invited companies to provide written feedback as well as additional source documents. In many cases, the research team conducted conference calls or meetings with companies to discuss the initial findings as well as broader questions about the RDR Index and its methodology.

Incorporating company feedback into the RDR Index. While engagement with the companies was critical to understand their positions and ensure we reviewed relevant disclosures, the RDR Index evaluates information that companies disclose publicly. Therefore, we did not consider a score change unless companies identified publicly available documentation that supported a change. The research team reviewed company feedback and considered it as context for potential inclusion in the narrative report, but we did not use it for scoring purposes.