The Complainants have undertaken efforts to engage Facebook through direct negotiations. These efforts have not resulted in remediation, or an offer of remediation that the communities deemed to be acceptable. Education around internet literacy or digital empowerment is not a replacement for an actual education, which the Rohingya have been deprived as a result of human rights violations that were facilitated by the actions and omissions of Facebook. While Facebook’s profits continued to soar throughout 2017, approximately 750,000 Rohingya were deprived of basic necessities such as education, housing and healthcare a situation which persists until this day. If the NCP decides that the issues raised merit further examination and offers it good offices, the Complainants would seek the following outcomes through this process: 1. Facebook divest from a portion of its 2017 profits – certainly those from Myanmar and provide remediation to the Rohingya in the form of educational facilities, or other facilities suitable to ameliorate their living conditions within the camps. 2. Facebook conducts due-diligence around the adverse human rights impacts of the datamining and algorithmic aspects of its business model as a whole. 3. Facebook amends its human rights policy and the mandate of its Oversight Board to explicitly include remediation beyond content removal (such as rehabilitation or financial compensation) where it contributes to human rights violations. 4. Facebook create a community advisory board with representatives from the Rohingya and other vulnerable users around the world, to be consulted over the development of a new human rights policy. The Complainants feel that Facebook has shown previous interest in engagement with them, but has not carried through. This is regrettable given common ground between the parties, especially around issues such as education and knowledge sharing. Moreover, Facebook has in the past described its remediation efforts for what happened in Myanmar as “some of the most important work being done at Facebook... The weight of this work, and its impact on the people of Myanmar, is felt across the company.”90 The Complainants believe that with the support and guidance of the Irish NCP, the parties can forget conversations of blame, and instead find constructive solutions to meet the serious needs of the communities suffering as a result of the violence. We therefore request that the Irish NCP investigate this complaint and make specific recommendations to bring Facebook into compliance with the OECD Guidelines with respect to this case. 3. Conclusion and Recommendations In conclusion, the Complainants contend that Facebook breached its obligations under the OECD Guidelines in four respects: (1) its inadequate human rights due diligence; (2) its actions and omissions that contributed to the human rights violations suffered by the Rohingya as a result of the 2017 operations; (3) its non-existent human rights policy at the time of the 90 The Gambia v Facebook, Inc, In re Application Pursuant to 28 U.S.C. § 1782 [22 September 2021] p 32. 22