... We welcome that already... you referenced the capacity of MTN to “play an important and leading role in digital and financial inclusion of the African continent, working with our stakeholders and partners.” MTN set out a strong public position in support of the “rights of all people to communicate, access, and share information freely and responsibly, and to enjoy privacy and security regarding their data and their use of digital communications.” ...

We would, however, like to draw your attention to areas where MTN has not met its commitments under international human rights standards, including the African Declaration on Internet Rights and Freedoms... According to the 2019 Ranking Digital Rights (RDR) Corporate Accountability Index, MTN ranked eighth out of the 12 telecommunications companies based on an evaluation of its disclosed policies for its prepaid and postpaid mobile services and fixed-line broadband service in South Africa... [W]e encourage you and the relevant staff within MTN to adopt four key recommendations...

Publish regular transparency reports... Clearly disclose MTN’s policies for handling government orders to shut down or degrade networks... Provide greater disclosure about the policies and practices of MTN that affect users’ privacy... Expand partnerships and engagement with civil society stakeholders...