ARTICLE 19 China Apple’s shareholders have organised some pushback in response to its conduct in China. The company released its Human Rights Policy, cited earlier, after shareholders voted on a proposal for greater transparency over China’s attempts to restrict freedom of expression on Apple products; the proposal, initiated partly by a non-profit organisation, failed but garnered 40% of shareholder votes.93 Shareholder advocacy in the tech company context can be challenging because of the nature of the share structure of most tech companies, but it has increasingly been used as an advocacy tool and may be an effective tactic in a country like China with a highly restrictive civic space.94 Case study: Microsoft’s Bing in China Microsoft’s search engine Bing remains active in the Chinese market and even overtook domestic search engines as the top search engine in China in 2023. 95 It has been able to stay in the Chinese market because it has complied with Chinese censorship demands. Bing has declined to discuss its policies in China but it does censor content that the government considers sensitive in its search results in China.96 In early 2023, the Citizen Lab published a study comparing the levels of censorship across 8 of the major search platforms accessible in China.97 It found that Bing search results demonstrated higher rates of censorship in terms of political and religious content than those of Chinese counterparts, including Baidu, the dominant Chinese search engine.98 The study cast serious doubt on the theory that foreign companies offer less-censored services. Limited information is available about the extent to which Microsoft may be negotiating or pushing back. There have been signs of crackdowns on Microsoft by authorities at various points. In July 2014, 4 of its offices in China were raided by officials, who questioned ____________________________________________ 93 Tech Transparency Project, Apple Is Censoring Its App Store for China; Eko, 40% of Shareholders Defy Apple Management in Vote on China Cyber Surveillance, 26 February 2020. 94 J. Rydzak, Dissecting Big Tech’s Shareholder Showdown, Ranking Digital Rights, 16 June 2022; A.L. Nabors, Is Momentum on Tech Shareholder Activism Stalling? How to Reinvigorate It in 2024, Ranking Digital Rights, 5 July 2023. 95 A. Hasnain, Microsoft Bing Emerges as China’s Favorite Search Engine, Digital Information World, 24 May 2023. 96 T. Simonite, US Companies Help Censor the Internet in China, Too, Wired, 3 June 2019. 97 Knockel, Kato, and Dirks, Missing Links. 98 Knockel, Kato, and Dirks, Missing Links. 28