30 communities in doing so, it is likely to incentivize behaviours that lead to adverse human rights impact. If an Internet company’s staff automatically defer to every Government request for information about users, regardless of the human rights implications, it runs the risk of being involved in any human rights abuses that result. Several factors are likely to influence the extent to which internal policies and procedures are effective in embedding respect for human rights across an enterprise. Existing systems may provide relevant and effective models, for example systems related to health and safety or non-discrimination that can be built on. Senior management attention and accountability for human rights risk management can also help, as can staff training. Including indicators related to human rights policies and procedures in the performance assessments of staff across all relevant functions—not just those that lead on human rights—can be particularly important. QUESTIONS TO ASK What elements does our statement of policy commitment to respect human rights need to include in order to: (a) Set clear expectations for the behaviour of personnel, business partners and other relevant parties linked to our activities? (b) Trigger the necessary internal attention, resources and action for its delivery? (c) Be credible in the eyes of our key stakeholder groups? What sources can we use to help us identify our key human rights risks? With whom can we test our ideas about which human rights risks are most salient in our sector and in the areas where we operate? How can we make sure that in focusing on the most salient human rights we do not forget that we might have an impact on others? Which credible experts could we ask to comment on our draft policy commitment, perhaps as part of a group of external stakeholders? What additional internal policies and procedures are we going to need to put this policy commitment into practice?