Executive summary been inadequate, however, and companies have lacked the rigorous response needed for this dangerous and complex context. Tech companies operating in authoritarian contexts often face real challenges in navigating a legal and political landscape that is hostile to freedom of expression and privacy. However, too often they merely cite domestic law as justification for collaborating in rights violations, without making sufficient effort to mitigate human rights harms or limit cooperation to the minimum necessary. It does not appear to be common for them to employ rigorous human rights due diligence or to incorporate human rights standards into decision-making processes. Far greater industry efforts are needed to ensure that companies act in accordance with the UNGPs when operating in authoritarian countries. Summary of recommendations ARTICLE 19 calls on governments in the region to: • revise their legal frameworks to bring them into line with international human rights standards, including on freedom of expression and privacy; • recognise their responsibilities under the first pillar of the UN Guiding Principles (UNGPs) and human rights law, and avoid compelling or pressuring companies to breach their human rights responsibilities; • foster universal access to an open internet, avoiding shutdowns and unnecessary restrictions on online platforms and facilitating a vibrant online ecosystem; and • protect human rights defenders and activists, including by taking measures to prevent harassment, threats, or violence against them; immediately and unconditionally release individuals who have been wrongly detained or imprisoned solely for exercising their right to freedom of expression and other human rights. We call on tech companies operating in authoritarian contexts to: • uphold human rights standards in accordance with the UNGPs; • conduct human rights due diligence, including by undertaking regular human rights impact assessments; these should be country specific and disclosed publicly, the process should be transparent and should involve meaningful consultation with affected stakeholders, and once assessments are completed, effective measures should be put in place to mitigate identified risks; • develop, publish, and fairly apply clear policies and procedures for content moderation, including specific standards for responding to government requests to remove content, and ensure that they reflect the principles articulated in the Santa Clara Principles; • develop clear policies on how they will respond to government requests to restrict services or share user data that include reasonable efforts to resist such requests, such 4

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