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The Global Network Initiative (GNI) welcomes the opportunity to provide input on the targeted update of the OECD Guidelines for MNEs and Implementation Procedures. Fifteen years ago, the GNI Principles on Freedom of Expression and Privacy and Implementation Guidelines (together, “the GNI framework”) were created to establish a human rights-based framework for information and communication technology (ICT) companies responding to government pressures, demands, and restrictions. The GNI framework is centered around conduct of holistic human rights due diligence (HRDD) to identify, prevent, evaluate, mitigate and account for risks to the freedom of expression and privacy rights that are implicated by the company’s products, services, activities and operations. Five years ago, GNI completed a review and revision of this framework to ensure its consistency with the OECD Guidelines and the UN Guiding Principles on Business and Human Rights (UNGPs).

GNI is a multistakeholder initiative (MSI) that brings together 85 leading academics, civil society organizations, ICT companies, and investors from around the world. Through our unique assessment process, GNI member companies undergo periodic, independent review of the systems, policies, and processes they have put in place to implement the GNI framework, as well as their experiences implementing it in practice. These assessments give us unique insights into the challenges that ICT companies face with regard to a diverse set of products and services in a wide range of jurisdictions. GNI also facilitates shared learning on relevant topics and engages in policy advocacy to strengthen freedom of expression and privacy globally.

GNI welcomes the targeted edits to the OECD Guidelines. In particular, we welcome clarification of and expanded guidance regarding the holistic nature of HRDD, the importance of robust stakeholder engagement, and the important role that MSIs can play.