Our approach: Built on seven pillars
The Business & Human Rights Program leads our efforts to make responsible decisions in the areas of free expression and privacy. We take a structured approach to this work built on seven pillars.
1. Executive commitment
2. Dedicated and Cross-Functional Team
The BHRP is led by a dedicated team that provides centralized leadership on global strategy, business decision-making, and internal and external engagement on human rights matters. This team is supported by and partners with a virtual, cross-functional team consisting of senior-level employees and experts from across the globe in legal, law enforcement, internal policy, product, security, technology, communications and marketing, global public policy and more.
3. Guiding Principles and Operational Guidelines
We’re committed to the international foundations of freedom of expression and privacy, and translate those principles into practical steps to be followed by our employees. We design targeted employee training and information-sharing sessions to discuss human rights policies and procedures.
4. Human Rights Inventory and Clearinghouse
We are constantly reviewing where Verizon Media’s business intersects with potential human rights issues and working to ensure those issues are routed to the right teams.
5. Human Rights Impact Assessments
We’re committed to exploring risks to free expression and privacy in business decisions, engaging with internal and external stakeholders to inform this work and designing risk mitigation strategies. To learn more about our approach to conducting HRIAs, click here.
7. Accountability Framework
As a member of GNI, Verizon Media has committed to implement the GNI Principles on Freedom of Expression and Privacy. Verizon Media undergoes assessments by an independent third-party assessor every other year on the policies and procedures we have in place. The findings are shared with the multi-stakeholder GNI Board of Directors which determines whether we are making a good faith effort to implement the GNI Principles. This information is shared publicly.For information on previous assessments of Yahoo (now part of Verizon Media, f.k.a. Oath), see here.
As the leader of the Business & Human Rights Program, Nicole drives efforts to respect and promote human rights across Verizon and Verizon Media and works to identify innovative solutions to human rights challenges. Nicole previously led the Yahoo Business & Human Rights Program.
Prior to joining Yahoo, Nicole worked as an attorney at Schulte Roth & Zabel LLP in New York; as an international policy fellow at Human Rights First, examining issues of business and human rights and national security law and policy; and as a human rights consultant to the UN Office of the High Commissioner for Human Rights. Nicole also worked at the UN in the Office of the Legal Counsel, as well as at the State Court of Bosnia and Herzegovina, in the Special Department for War Crimes in Sarajevo.
Nicole co-teaches a course on Corporate Sustainability and Transnational Business and Human Rights at Fordham University School of Law.
Nicole received her LL.M. in International Legal Studies from New York University School of Law; her J.D. from Boston College Law School; and her B.A., magna cum laude, in Politics and Sociology from Brandeis University.
As Counsel in the Business & Human Rights Program, Sarah supports Verizon and Verizon Media's commitment to integrating attention to human rights impacts into its legal and business operations. She also seeks to identify and respond to technological trends that may create human rights risks.
Sarah was previously Counsel in Foley Hoag LLP's Corporate Social Responsibility Practice, where she advised corporate clients on how best to assess and address the human rights impacts of their operations and to respond to emerging legal and regulatory requirements specific to human rights. In 2018 and 2017, she was recognized by Chambers Global as among the top lawyers in the field of business & human rights.
Sarah is currently co-teaching a seminar on business & human rights law at Georgetown University Law Center. Prior to law school, Sarah was a research analyst with the socially responsible investment firm, KLD Research & Analytics.
Sarah received her J.D. from Harvard Law School and her B.A., magna cum laude, in Political Science from Williams College.
Carolina is based in London and works in the EMEA legal team on a variety of legal, compliance and public policy issues. Most recently Carolina has applied her interest in the areas of privacy and freedom of expression to her work in support of the Business & Human Rights Program managing projects, including the 2019 Ranking Digital Rights review of Verizon Media.
Prior to joining Verizon Media, Carolina completed internships at the International Criminal Court in The Hague, working closely with the external relations team, and Reed Smith working in the corporate team.
Carolina was awarded the Lord Mayor of London Scholarship for Academic Excellence at London City University, where she completed a BSc in International Politics and Sociology focusing on international security, conflicts and law, followed by the Undergraduate Law Conversion, GDL. Carolina also obtained diplomas in International Criminal Law and International Humanitarian Law from Leiden University, where she completed specialized summer courses.