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GNI and its members appreciate the opportunity to provided comments to UNESCO on the draft “Guidance for regulating digital platforms: a multistakeholder approach,” which will be featured at the upcoming UNESCO Global Conference: Internet for Trust: Regulating Digital Platforms for Information as a Public Good, Paris, 2023.

Over the years, UNESCO has done important work to empower civil society, establish useful guidance for member states, and build trust with the private sector, and GNI has appreciated opportunities to engage and collaborate with UNESCO on various digital policy initiatives. However, in our submission, we note concerns about the failure of UNESCO to model effective multsitakeholder engagement and policymaking in the production of this guidance to date, and share a set of substantive recommendations in line with the GNI Content Regulation Policy Brief. We call on UNESCO to make significant efforts to ensure that the process for continuing to improve the Guidance, including any follow-up coming out of the Global Summit, is transparent, deliberate, and broadly and meaningfully participatory.

The Global Network Initiative (GNI) is a multistakeholder initiative that brings together 85 prominent academics, civil society organizations, ICT companies, and investors from around the world. Members’ collaboration is rooted in a shared commitment to advancing the GNI Principles on Freedom of Expression and Privacy, which are grounded in international human rights law and the UN Guiding Principles on Business and Human Rights (UNGPs). For over a decade, the GNI Principles and corresponding Implementation Guidelines have guided ICT companies to assess and mitigate risks to freedom of expression and privacy in the face of government laws, restrictions, and demands.

GNI has appreciated the many opportunities to collaborate and engage with UNESCO on important digital policy and freedom of expression initiatives in recent years.  These efforts include a colloquium on “Improving the Communications and Information Ecosystem to Protect the Integrity of Elections,” which resulted in a report of the same title, participation in UNESCO’s annual World Press Freedom Conferences, and consultations around the Internet Universality Principles (ROAM Principles), among other engagements. GNI and many of its members will be traveling to the Paris conference and we look forward to continuing this engagement.

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