4  Publicly report on Government requests for censorship: Transparency enables 4.1   governments and companies to demonstrate whether they are upholding key human rights principles and for other stakeholders to hold governments and companies accountable to such principles. 280 A key development in company transparency in the ICT Sector has been the annual or bi-annual release by some companies of information relating to Government requests companies receive for content takedown, or requests for user data. 281 Publishing information on Government requests and how the company responded increases awareness among users of the scale and scope of Government requests, and increases transparency about corporate responses. The first transparency report was published by Google in 2010. To date, there is not a standardised method of publishing the information, and therefore each company transparency report differs slightly, making comparison difficult, but as more companies publish reports, there has been an effort to move beyond publishing mere numbers and add context on the laws governing censorship and surveillance, including areas where companies are prevented by law from disclosing information. Providing this additional context highlights the responsibilities of the Government and areas where disclosure and transparency can be improved. Report according to the US State Department Requirements for US Companies: The State Department requires all companies investing US$500,000 or more in Myanmar to submit an annual report on their activities, covering areas including land, labour, environmental and other human rights. TPG Holdings, which through its jointly owned company Apollo Towers, is engaged in the construction and operation of telecommunications towers submitted a report in 2014. 282 See also Chapter 4.4 on Surveillance. D. Relevant International Standards and Guidance on Freedom of Expression Relevant International Standards:  Universal Declaration of Human Rights (Article 19)  International Covenant on Civil and Political Rights (Article 19)  Freedom Online Coalition, Tallinn Agenda for Freedom Online (2014) Relevant Guidance:  Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression, Frank La Rue, A/HRC/17/27 27th May 2011  UN Human Rights Council, The Promotion, Protection and Enjoyment of Human Rights on the Internet, A/HRC/20/L.13 29th June 2012 investment obligations, and the form and extent of any ongoing government support. If IFC is financing the privatisation of such distribution services, IFC also encourages the public disclosure of concession fees or privatisation proceeds. Such disclosures may be made by the responsible government entity (such as the relevant regulatory authority) or by the client.” 280 Freedom Online Coalition, “Draft Report Executive Summary“ Working Group 3: Privacy and Transparency (May 2015). 281 See, Access Transparency Reporting Index, a record of transparency reports published by Internet companies and telecommunications companies. 282 TPG Holdings, “Re: Report on Responsible Investment in Myanmar” Letter to the US Department of State (1 April 2014). 138 PAGE CHAPTER 4.1: FREEDOM OF EXPRESSION