4 4.9    (such as tower companies and fibre cable digging companies) to have robust stakeholder engagement procedures that are grounded in a concept of respect for rights holders. This should be backed up with training to ensure that site hunters understand the core concepts of treating stakeholders fairly. With such a large number of stakeholders to deal with, and the race to construct infrastructure to meet licensing targets, there is a clear risk of stakeholders being treated only as one more item in a long checklist. While many interactions with stakeholders will be routine, the lack of awareness of many stakeholders of even what the network rollout activities are all about, much less their rights, makes many of the stakeholders, particularly in rural areas, at risk of unfair practices. This is an area where the tensions could arise between commercial pressures on tower companies and fibre laying companies to meet time targets and good practice on stakeholder engagement and even on respecting rights. While the fee companies pay for access to land for infrastructure varies according to a number of factors including assessed damages to crops, or overall disruption by workers on site, the procedures should be consistent, transparent and accessible to stakeholders and in particular those with whom companies are negotiating. See Chapter 4.7 on Land for further information. Provide accurate, accessible and timely information: Companies should be prepared to engage with stakeholders with a very low level of literacy, scientific knowledge or understanding. They should be prepared to respond in a way that is simple, accurate, balanced and understandable in local languages. This includes health and safety issues (whether the tower could withstand earthquakes or severe weather; concerns about unsafe levels of radiation from the tower (see below); concerns about being electrocuted by the tower during rain showers); information about which companies are involved in the tower site and where future questions or concerns should be directed. They should also provide clear explanations to potential customers about potential costs (such as for roaming), privacy, etc. Require and monitor engagement carried out by business partners: Subcontractors are often the first ‘face’ of forthcoming operations for the rollout of the network, sales of SIM cards or sales of other ICT equipment or services. Many of these will be local companies, including very small shops. Most companies operating in Myanmar, local and foreign, are unfamiliar with the concept of stakeholder engagement, including opening their business up to receiving complaints directly from workers and local communities through grievance mechanisms. Sub-contractors, particularly in construction, will need training and incentives/ disincentives to develop positive relationships with local communities from the earliest phase of roll-out. Engage constructively with civil society: Local and international civil society organisations provide necessary support to local communities to hold government and companies to account. Companies are encouraged to engage openly with civil society and community based groups to understand their concerns and provide accurate and timely information. They should model behaviour about the right to freedom of expression that demonstrates support for the right, both in law and in practice. Dealing with criticism through constructive engagement should encourage the authorities to do the same, rather than accusing civil society groups of “stirring up opposition”, or even arresting them 630 . When there are arrests or violence in connection with a company’s operations that violate human rights, companies should raise the issue with the Government, whether quietly or publicly, individually or collectively, to express their concerns. 630 See OHCHR, “Report of the Special Rapporteur on the situation of human rights defenders, Michel Forst” A/HRC/28/63 (29 December 2014), reporting on risks faced by land and environmental activists around some extractive projects. 250 PAGE CHAPTER 4.9: STAKEHOLDER ENGAGEMENT & GRIEVANCE MECHANISMS