1. Introduction This specific instance outlines breaches of the OECD Guidelines for Multinational Enterprises by Meta Platform, Inc., (hereafter “Facebook”) that contributed to the commission of widespread atrocities and human rights violations in Myanmar’s Rakhine state that resulted in the displacement of approximately 750,000 Rohingya into Cox’s Bazar in Bangladesh in 2017. The specific instance is directed at the Irish NCP against Facebook for the actions of its Irish subsidiary ‘Facebook Ireland Limited’, which is responsible for Facebook’s global operations outside of the United States and Canada, and where policies related to their Myanmar operations are made and implemented. As is well-documented by numerous human rights bodies, including the United Nations Independent International Fact Finding Mission on Myanmar (“IIFFMM”), military operations conducted by the Burmese military in 2017 forcibly displaced 750,000 Rohingya into neighbouring Bangladesh, and were accompanied by numerous other egregious human rights abuses. The military used Facebook to incite violence, which resulted in numerous human rights violations suffered by the Rohingya, including: the right to be free from torture and inhumane and degrading treatment, and their rights to life, housing, food and education as guaranteed by the Universal Declaration of Human Rights (“UDHR”). The IIFFMM concluded that Facebook’s role in spreading the hate speech that fuelled the violence in Rakhine state in 2017 was ‘significant.’ Facebook itself acknowledged that it did not do enough to prevent its platform from being used to incite violence. Despite Facebook’s acknowledgment that it did not do enough the prevent the violence, it has never provided any form of remediation to the Rohingya victims for the human rights violations to which it contributed. Representatives of the Rohingya community, including individuals within the sixteen people submitting this complaint, have made modest requests for Facebook to fund education facilities in Cox’s Bazar, which Facebook has rejected. In the latest communication, and after Rohingya communities spent three-months developing a proposal, Facebook responded that they do not directly engage in ‘philanthropic activities’ and that while it does partner on some initiatives, these ‘generally have to have a more direct link to [Facebook’s] products, internet literacy or digital empowerment.’ The Complainants reject the notion that Facebook providing educational facilities amounts to ‘philanthropic activity’ but is rather a remedy which is owed by Facebook to the Rohingya as provided for under the United Nations Guiding Principles on Business and Human Rights (“UNGPs”) and the OECD Guidelines. As an organisation that qualifies as a multinational enterprise under the OECD Guidelines, Facebook should be held to the standards of the OECD Guidelines. The Complainants submit that Facebook is in breach of the Guidelines because it: 1) failed to conduct adequate due diligence for its business operations in Myanmar; 2) contributed to human rights violations suffered by the Rohingya in 2017 through its acts and omissions; 3) did not have a policy commitment to respect internationally recognised human rights as at 2017, and has since issued one that is inadequate; and 4) failed to provide a remedy despite contributing to the human rights violations in question. 3