Yahoo’s Business and Human Rights Program, or BHRP, advises the company on responsible decision-making regarding the human rights impacts and opportunities of its business operations. Our commitment is translated into the structured approach detailed below.
Yahoo has a company-wide commitment to operating with respect for human rights, consistent with the U.N. Guiding Principles on Business and Human Rights. This starts with a clear and visible commitment from our executive team and is supported through all levels of the company.
The BHRP leads the company’s efforts to make responsible decisions in the areas of free expression and privacy. A designated team guides, directs, and manages the work of the program. The team is under the remit of the Chief Legal Officer, who is a member of the Board of Directors. A Vice President oversees the day-to-day work of the program and provides regular updates on information about the global human rights risks and opportunities identified in the BHRP team’s ongoing due diligence to the Chief Legal Officer, as well as other senior executives as relevant. The Yahoo Board of Directors oversees and receives regular updates on global human rights risks and opportunities related to Yahoo. These updates are informed by the BHRP
Designated and cross-functional team
The business and human rights work is led by a designated team that provides centralized leadership on global strategy, business decision-making, and internal engagement on human rights matters. The BHRP reviews where Yahoo’s business intersects with potential human rights issues and works to ensure those issues are routed to the right teams. They partner with cross-functional experts consisting of senior-level employees from across the globe in privacy, law enforcement response, compliance, internal policy, product, security, technology, legal and more.
Guiding principles and operational guidelines
Yahoo is committed to respecting internationally-recognized human rights, and our Business and Human Rights Program translates those principles into practical steps to be followed by employees. This information is shared in targeted employee training and information-sharing sessions to discuss current trends, human rights policies, and company procedures.
Ongoing Human Rights Due Diligence
Yahoo is committed to human rights due diligence, as set forth in the U.N. Guiding Principles on Business and Human Rights and as embodied through our structured approach. The BHRP regularly consults with a variety of experts as part of our human rights due diligence process.
The BHRP partners with teams across Yahoo to identify, understand, and address the human rights implications of our business decisions, including our technology, algorithms, products, services, and strategy. This includes attention to such rights as privacy, freedom of expression and information, and non-discrimination. This work helps to identify circumstances when such rights may be jeopardized or advanced and to develop appropriate risk mitigation strategies.
When do we conduct HRDD?
Yahoo conducts HRDD to identify circumstances when human rights may be jeopardized or advanced. As part of this process, we conduct short-form HRIAs for specific, smaller-scale, and targeted questions. When we identify a potentially significant risk to users’ human rights, we undertake a long-form HRIA.
Below is an illustrative and non-exhaustive list of the type of matters for which Yahoo undertakes either regular human rights due diligence review or, depending on the circumstances, more comprehensive human rights impact assessments:
- Entry into new markets;
- Significant legal, policy, or political changes in markets where Yahoo already does business;
- Launch of new or updated products or services;
- Revision of internal procedures or policies for responding to government and other relevant third-party demands to disclose user data or to restrict content;
- Launch of new or updated products or services;
- Development or use of relevant automated systems, algorithms, and artificial intelligence, such as content moderation systems, that may impact the freedom of expression, privacy, and non-discrimination rights of users; and
- Data collection, use, transfer, and storage location decisions.
Human Rights Impact Assessments
The Human Rights Impact Assessment (HRIA) is an essential element of our ongoing review of the human rights landscape and of Yahoo’s business plans. HRIAs inform our evolving strategies to promote and protect our users’ human rights. When we conduct an HRIA, including for each of the types of matters listed above, we review a number of factors, including:
- The international legal and normative foundations for human rights, including rights such as freedom of expression and information, privacy, and non-discrimination;
- The responsibility of corporations to respect human rights, as set out in the U.N. Guiding Principles on Business and Human Rights;
- Yahoo’s business, strategy, or product plans;
- The intersection points between our business strategy, products, or services and potential human rights risks;
- The human rights landscape in relevant countries or regions; and
- Local laws, policies, and practices relevant to the human rights impacts of our business practices.
Based on this work, the BHRP team identifies potential human rights risks and opportunities that could arise from Yahoo’s products and operations. The BHRP then makes recommendations to avoid or mitigate those risks, protect our users, and promote human rights with our products and on our platforms.
As part of our HRDD and HRIA processes, we consult with a variety of local, regional, and international experts, including GNI participants, government agencies, human rights organizations, academics, journalists, and other experts.
Yahoo values our engagement with industry peers, human rights experts, and others on human rights risks, opportunities, and trends.
We recognize that our company can help to foster an exchange of ideas; promote human rights and the rule of law; and seek to reform laws, government policies, and practices that infringe on freedom of expression and privacy.
We engage with governments and agencies around the world to encourage a shared understanding of the power of the Internet, media, and information to inspire, inform, and create positive change. Yahoo also strives to create a shared understanding of the negative impact of laws that do not protect the rights to freedom of expression and privacy, including through the Reform Government Surveillance coalition.
We also serve as a board member of the Global Network Initiative (GNI), a multi-stakeholder organization consisting of companies, human rights experts, academics, and investors dedicated to human rights in the tech sector.
Accountability and Transparency
Yahoo seeks to be accountable, including by being transparent. Our human rights efforts are shared and reflected in our policies, website and transparency reporting.
As an internet company offering content and communications properties globally, Yahoo receives government requests for the removal of content and for user data. Given the potential impact of these requests on free expression and privacy, Yahoo has articulated Global Principles for Responding to Government Requests which inform our policies. These Principles are informed by the GNI Principles on Freedom of Expression and Privacy and explain our commitment to respect human rights when interacting with government demands, including by minimizing disclosure of user data and restrictions to freedom of expression online; we balance our GNI commitments with our public responsibility and legal obligations. Yahoo makes public the results of our application of our principles in a twice-yearly Transparency Report, which includes quantitative and qualitative information on the government requests we receive for content moderation and user data.
Yahoo also provides publicly-available processes by which people may report potential issues related to the human rights impacts of our activities. The Yahoo Ethics & Compliance site (yahooinc.com/yahooethics) is available 24/7 to anyone who wants to ask questions, seek guidance, and report concerns, including about our human rights commitments. This intake function allows for anonymous reporting (where permitted by local law) via web submission, email, toll-free phone number, and physical mail.
Additionally, as part of the commitment to the Global Network Initiative, member companies undergo assessments by an independent third-party assessor every two years on their policies and procedures. The findings are shared with the multistakeholder GNI Board of Directors which determines whether each company is making a good faith effort to implement the GNI Principles. This information is shared publicly and may be accessed here.
Yahoo is an industry pioneer in the effort to assess human rights risks and impacts in the course of business operations and has engaged with many external partners as part of this effort. Yahoo conducted the first human rights impact assessment in the tech sector when considering how to engage more extensively and in a responsible way in Vietnam -- a milestone for business and human rights in the information and communications technology sector.