       may have had little exposure to discussions or concerns around freedom of expression and other human rights issues and their role and responsibilities. There is a clear need for further awareness raising and training that could be taken on by business partners, donors, and civil society. ICT companies may therefore find it necessary to put in place contractual requirements and follow up to ensure that their business partners are aligned with their human rights approach. Prevent and mitigate impacts around the 2015 national elections: Mobile operators and social media providers should consider experiences from other countries (see Table 30 case study on Kenya). They should consult relevant experts and other stakeholders, and devise appropriate responses to a range of pre and postelection scenarios to ensure that they are prepared to deal with unfolding events in a manner that best protects users. Promote and preserve Myanmar languages online: Companies may want to think creatively or collaboratively with other stakeholders (such as civil society or donors) about opportunities to facilitate access and use of minority languages. Companies should publish Terms of Service in local languages. Understand what is being posted or discussed publicly in online company portals: The wide range of languages in Myanmar has implications for those companies hosting content, such as social media pages, to be able to understand and decide upon whether content is consistent with the right to freedom of expression and in line with the company’s terms of service. See also Chapter 4.2 on Hate Speech. Review anonymity policies: Companies should think through the implications of including ‘real names’ policies, and whether these are effective in the context of Myanmar (see Chapter 4.2 on Hate Speech). Companies should err on the side of allowing the use of pseudonyms particularly to individuals or groups who have a wellfounded fear of possible prosecution. At the same time, companies may be required by law in some instances to reveal the identity of the user to the State (such as during an investigation into terrorism charges). In such a case, where appropriate, companies should inform the user that his or her identity has been compromised. Provide and publish guidelines for employees and workers on the use of social media. All companies should publish specific guidelines that educate staff on how to use social media and the Internet responsibly while at work. Raise awareness of how to use, why to use and the results of using social media platforms’ ‘content reporting’ functions. Promote public awareness of the link between ICT and human rights. This can encourage more CSOs and media to understand and cover the issues. Companies can also take steps to promote access to information:  Be transparent around ICT licenses, contracts and their Terms: While the process to license the telecommunications operators was more transparent than previous bidding processes in Myanmar, the Government did not make the terms of the licenses public. Few governments do provide transparency around the terms of telecommunications operating licenses, but the pressure for contract transparency and information on tariffs, fees and proceeds around public service contracts will continue to grow. The International Finance Corporation (World Bank Group) “encourages” the disclosure of information around telecommunications projects it finances. 279 279 IFC “Policy on Environmental and Social Sustainability” (2012), para 53: “When IFC invests in projects involving the final delivery of essential services, such as the retail distribution of water, electricity, piped gas, and telecommunications, to the general public under monopoly conditions, IFC encourages the public disclosure of information relating to household tariffs and tariff adjustment mechanisms, service standards, CHAPTER 4.1: FREEDOM OF EXPRESSION 137 4 4.1