In total shareholders filed eleven proposals calling for increased disclosures, risk assessments, and policy changes they say are needed to prevent significant impacts to Alphabet stakeholders including its workers, the users of its platforms, its customers, and investors. The full list of proposals, proponents, and comments for the record are available here.
While the issues raised by the proposals cover a range of environmental, social, and governance concerns (ESG), collectively they underscore how Alphabet’s unparalleled reach and influence require enhanced oversight structures to mitigate potential human rights and digital rights harms. The proposals also signal that investors are closely observing topics that, while seemingly complex, are likely to ultimately determine the architecture of the internet.
Said Jan Rydzak of Ranking Digital Rights, an NGO that works to promote freedom of expression and privacy on the internet, “Governments and tech titans are pushing to reassert control over people’s data and content, each in their own way. Alphabet will play a pivotal role in shaping this future landscape. Many of these proposals address areas of critical human rights risk, from falling in with authoritarian regimes to transforming how companies use personal data to target ads. Alphabet must show that it takes the risks of these endeavors seriously if it aspires to be a responsible steward of the internet.”
A cluster of proposals highlights potential data privacy, misinformation, and discrimination harms as a result of Google’s business model and the algorithms it uses to collect data, manage content, and target users with advertising. While investors have been attempting to engage Alphabet on these risks for several years, the company has often been unresponsive to requests for dialogue. The investors say they are hopeful this year that dynamic will change.
One such proposal seeks enhanced disclosure around how Alphabet uses algorithmic systems to target and deliver ads, error rates, and the impact these systems have on user speech and experiences. “Promoting fairness, accountability, and transparency in artificial intelligence is central to its utility and safety to society,” said Trillium Asset Management, Chief Advocacy Officer Jonas D. Kron. “Let’s get this right before it is too late. Alphabet’s investors and Stakeholders require transparency and pro-social impacts.”
On a parallel theme, Alphabet expects to eliminate the use of third-party cookies through the introduction of a new technology called Federated Learning of Cohorts (FLoC). As opposed to third-party cookies, FLoC relies on algorithmically grouping users into large “cohorts” whose behavior and activities are broadly similar. Civil society actors, however, have identified potential human rights risks associated with FLoC. A proposal filed by the Canadian Shareholder Association for Research & Education (SHARE) seeks a human rights impact assessment before FLoC is launched to ensure users’ digital rights will be adequately safeguarded.
“Alphabet has the responsibility to guarantee that the digital rights of its billions of global users are in good hands. Without proper measures to address potential digital rights harms, there will continue to be significant risks to all stakeholders involved in Alphabet’s global sphere of influence. As Alphabet prepares to revamp and widely implement its new advertising technology (FLoC), the Company must urgently provide greater transparency and due diligence on these critical issues.” said Sarah Couturier-Tanoh, Manager, Corporate Engagement & Advocacy at SHARE.
Another proposal requests that Alphabet commission a racial equity audit analyzing Alphabet’s adverse impacts on Black, Indigenous, and People of Color (BIPOC) communities. Said Laura Campos, Director of Corporate and Political Accountability at Nathan Cummings Foundation, “Investors have a responsibility to ensure that companies back up their messages of support for communities of color with a thorough examination of where their products and practices are causing harm and a concrete plan to address any problems uncovered. As a long-term investor, we believe that uncovering and addressing racial equity problems now will lead to stronger returns in the long run.”
Investors also cite what they view as Alphabet’s dangerous flirtation with authoritarian and nondemocratic regimes, including their silent compliance with demands to censor content (such as the Russian government’s efforts to stifle opposition candidates online) and their building of data centers in human rights hot spots. A shareholder proposal from SumofUs requests a report assessing the siting of Google Cloud Data Centers in countries of significant human rights concern, and the Company’s strategies for mitigating the related impacts.
Observed Christina O’Connell, Advisor, SumOfUs, “As Alphabet expands its global network, it is planning to establish major data centers in countries with shocking human rights records and particularly problematic digital rights laws and prosecutions. From arrests in India of online journalists to the Saudi government placing spies inside Twitter to access critics’ private communications, many of the selected locations are of grave concern. Our network of members who are Alphabet shareholders are challenging the company to live up to its pledge to ‘In everything we do, including launching new products and expanding our operations around the globe, [be] guided by internationally recognized human rights standards.’’
Again, the full list of proposals, proponents, and comments for the press can be found at this link.
About the Investor Alliance for Human Rights
The Investor Alliance for Human Rights is a collective action platform for responsible investment that is grounded in respect for people’s fundamental rights. Its members include asset management firms, public pension funds, trade union funds, faith-based institutions, family funds, and endowments. Collectively, they represent nearly US$8T in assets under management and 19 countries. The Investor Alliance is an initiative of the Interfaith Center on Corporate Responsibility.
Visit our website at: https://investorsforhumanrights.org/ and follow us on Twitter: @InvestForRights