How Companies Can Help Prevent Mass Atrocities

How Companies Can Help Prevent Mass Atrocities

By Sarah Creedon | February 2026

The global economy is increasingly affected by rising conflicts, the private sector is finding itself on the front lines operating in a governance gap and navigating geopolitical shifts. In this context, companies must shift from standard Human Rights Due Diligence (HRDD) to proactively integrating a conflict-sensitive perspective including early warning signs of mass atrocities into their risk assessments and strategic planning.

Context

I participated in a panel hosted by the United States Holocaust Memorial Museum’s Simon-Skjodt Center for the Prevention of Genocide in January 2026, bringing together practitioners, academic experts, companies, and government representatives to discuss the role of the private sector in preventing mass atrocities. Mass atrocities is a term that encompasses large-scale systematic violations of international humanitarian law such as genocide, crimes against humanity, war crimes, and ethnic cleansing often including mass killings, torture, and forced displacement. For example, the Assad regime’s systematic killing of civilians in Syria from 2011-2024 through mass detention, torture, and indiscriminate aerial campaigns is tantamount to crimes against humanity and war crimes.

The discussion included changes in regulations, geopolitical shifts, and the accountability landscape for companies, with case examples from Ukraine, Russia, Syria, and Myanmar. For companies, not engaging in atrocity prevention is a massive legal, fiduciary and reputational risk. A multinational company can be held accountable in one country for the conduct of a subsidiary in another, as the enhanced use of universal jurisdiction and 3rd country prosecutions in Europe and the U.S. has demonstrated. For example, in 2022, Lafarge pleaded guilty in U.S. federal court and paid $777.8 million in fines for providing material support to ISIS in Syria. Investigations into corporate engagement during the recent conflicts in Syria, Sudan, and Myanmar continue in 2026, proving that past actions will follow a company indefinitely. There is no statute of limitations on war crimes or crimes against humanity, corporate complicity is a permanent brand and legal liability. Therefore, it is in companies’ interest to respond to early warning signs of atrocities.

One approach to navigate this fragile and volatile landscape is for companies to enhance due diligence compliance to Heightened Conflict-Sensitive Human Rights Due Diligence (hCSHRDD)—a process that yields clarification of red lines and outlines proactive collective diplomacy aiming to de-escalate conflict. Conflict prevention is more than reporting and documenting. Business can play an active role in promoting stability and peace: this requires recognizing and responding to early warning signs of mass atrocities—like the closing of civic space or the targeting of minorities—and using corporate leverage to de-escalate tensions before they reach a breaking point. Academic institutions, civil society and UN actors can help companies steer this shift.

The Shift: From Preservation to Strategic Prevention

A decade ago, I participated in a similar multi-stakeholder gathering on the role of social media during conflicts in Myanmar and Syria where grave violations, war crimes, and crimes against humanity were being documented, in particular social media companies’ involvement in removing or deleting photo and video content. At the time, tech companies lacked policies for preserving evidence of atrocities, often deleting crucial photos of mass graves or extrajudicial killings because they violated graphic content mandates. Since then, I saw the power of consistent and collaborative engagement: content policies now allow for the tagging and preservation of evidence vital for establishing accountability for perpetrators and enabling remediation.

This time around, discussing atrocity prevention, new challenges for conflict prevention emerged. From the impact of AI-generated hate speech—which can incite mass violence—to the politicization and under resourcing of traditional human rights reporting, businesses must adapt. A key take away from the January meeting is that these current challenges require a shift from passive data collection for HRDD to proactive engagement and strategic planning to inform responses to early warnings before a crisis emerges.

The Three Pillars of Proactive Engagement

1) Proactive Protection of Human Rights Defenders (HRDs)

In the session we also discussed the value of early warning information from sources on the ground. HRDs provide rich insights and on-the-ground early warning data as well as conflict prevention recommendations that internal company audits miss. However, the trust deficit between companies and HRDs is significant. 2025 saw a sharp rise in Strategic Lawsuits Against Public Participation (SLAPP) and the use of commercial spyware to target civil society leaders. SLAPPs are legal claims of defamation, libel, data protection, and breaches that result in the intimidation of critics – often human rights defenders. To bridge this trust gap, companies should: first, establish formal HRD policies which explicitly condemn reprisals and support safe engagement with human rights defenders and civil society organizations. Second, companies must ensure dual-use technology is not being misused to suppress free speech and audit dual-use tech. Third, companies should avoid blind spots in their due diligence - a company that intimidates HRDs is effectively blinding their own risk assessment.

2) Concrete Steps to Conduct Heightened Conflict-Sensitive HRDD

HRDD is typically defined by the way a company identifies, mitigates and accounts for adverse human rights impacts. Standard HRDD is insufficient in pre-atrocity environments where the risk of complicity in gross violations of human rights increases, as critical conflict drivers might be overlooked. Standard HRDD should be complemented by conflict analysis – heightened Conflict-Sensitive HRDD can be applied through examining the company’s impact on conflict drivers and how the conflict may impact the company. To do this in a concrete way a more proactive approach should entail:

First, a strategic risk analysis that monitors early warning signs for mass atrocities such as the targeting of vulnerable groups. This entails identifying shifts in rhetoric or discriminatory legislation targeting ethnic or religious minorities.
Second, monitoring closing civic space, including limitations on freedom of expression and assembly, such as internet shutdowns and the use of commercial spyware to threaten human rights defenders.
Third, monitoring security sector shifts to detect any changes in behavior by state or private security actors, particularly excessive use of force on or near company locations such as mining or infrastructure sites.

Analyzing corporate responses to recent conflicts, one key takeaway from the United States Holocaust Memorial Museum’s Simon-Skjodt Center for the Prevention of Genocide session is that many companies were unprepared for the speed of the Ukraine crisis. The lack of preparation and strategic planning in the event of mass atrocities lead to inconsistent withdrawal timelines from business relationships in Russia which incurred severe operational, reputational and financial costs. Companies who remained in Russia after 2022 are subjected to asset seizures and high taxes from Russia that directly fuel their ability to continue the war on Ukraine, as well as legal and sanction violation costs. Companies should learn from this experience and develop a strategic decision tree ahead of conflicts to determine when and how to engage to prevent mass atrocities and red lines for a responsible exit plan. Defining these triggers in advance prevents paralysis during a crisis.

3) Leverage Collective Diplomacy via Multi-Stakeholder Initiatives (MSIs)

In the session we talked about the opportunities companies have in pre-conflict environments. Companies possess unique leverage points: government relationships, financial flows, and essential infrastructure. When UN agencies are restricted, businesses are often the only actors remaining on the ground with access to decision-makers.

Individual companies may fear retaliation for speaking out. Collaborative engagement such as the Multi-Stakeholder In-Country Working Group model (as detailed in our ICRC-DCAF-GCBHR Security and Human Rights Toolkit) provides a solution. By utilizing neutral facilitators, like universities, to create a safe space for dialogue, companies can engage collectively to de-escalate tensions with a broad range of security and policy actors.

Recommendations for 2026

For Businesses:

We recommend developing a crisis response plan before conflict breaks out, to define triggers for withdrawal or suspension and defining engagement leveraging multi-stakeholder initiatives. This will require deepening and diversifying data sources including proactive engagement with civil society and protection of civic space. HRDs can be reliable interlocutors to identify early warning signs - and companies should avoid being complicit in practices that result in silencing them. Moreover, companies should leverage MSIs. When speaking out individually is risky, collective action through neutral facilitators can de-escalate tensions. In fragile environments, it is key that companies assess the operating context—including historical grievances and the company’s impact on human rights elements of the conflict – to avoid unintentionally contributing to conflict drivers, ensuing human rights violations and risking liability with the associated reputational, legal, and financial costs.

For Civil Society & Academia:

We recommend conducting research that engages key stakeholders through an iterative process, including site visits where feasible, and systematic analysis of core business operations and contextual factors. Multiple rounds of stakeholder engagement may be necessary to develop practical recommendations and evaluation standards for companies. Such sustained research processes can generate rigorous analysis and actionable guidance for companies and policymakers. The value and impact of such research should be enhanced by translating insights into practice through continued, in-depth engagement with companies, multi-stakeholder initiatives, and government representatives.