G3. Internal implementation

The company should have mechanisms in place to implement its commitments to freedom of expression and information and privacy within the company.

Elements:

1. Does the company clearly disclose that it provides employee training on freedom of expression and information issues?
2. Does the company clearly disclose that it provides employee training on privacy issues?
3. 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 information rights?
4. 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’ privacy rights?

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.

Whistleblower program — This is a program through which company employees can report any alleged malfeasance they see within the company, including issues related to human rights. This typically takes the form of an anonymous hotline and is often the responsibility of a chief compliance or chief ethics officer.

Indicator guidance: Indicator G2 evaluates whether a company’s senior leadership commits to overseeing freedom of expression and privacy issues. This indicator, G3, evaluates if the company discloses whether and how these commitments are institutionalized across the company. More specifically, this indicator seeks disclosure of whether and how the company helps 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 users’ 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 information, and privacy, as well as the existence of whistleblower programs addressing 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.

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