United Nations Strategy and Plan of Action on Hate Speech - Detailed Guidance on Implementation for United Nations Field Presences
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United Nations Strategy
and Plan of Action
on Hate Speech
Detailed Guidance on
Implementation for
United Nations Field Presences
SEPTEMBER 2020TABLE OF CONTENTS
FOREWORD BY THE SECRETARY-GENERAL. . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
I. I NTRODUCTION: A COMMON APPROACH. . . . . . . . . . . . . . . . . . . . . . . . . . . 7
II. U NDERSTANDING HATE SPEECH. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
A. What is “hate speech” under the Strategy?. . . . . . . . . . . . . . . . . . . . . . . . . . . 10
B. What types of speech are covered by the Strategy?. . . . . . . . . . . . . . . . . . . . . . 12
C. How should the severity of hate speech be assessed?. . . . . . . . . . . . . . . . . . . . . 17
D. How is the Strategy relevant to United Nations field presences?. . . . . . . . . . . . . . . 19
III. I MPLEMENTATION OF THE STRATEGY’S THIRTEEN COMMITMENTS. . . . . . . . 23
IV. ACTION POINTS AND SPECIFIC RECOMMENDATIONS FOR
IMPLEMENTING THE THIRTEEN COMMITMENTS OF THE STRATEGY . . . . . . . 25
COMMITMENT 1: Monitoring and analysing hate speech.. . . . . . . . . . . . . . . . . . . 25
COMMITMENT 2: Addressing root causes, drivers and actors of hate speech. . . . . . . . 28
COMMITMENT 3: Engaging and supporting the victims of hate speech. . . . . . . . . . . 30
COMMITMENT 4: Convening relevant actors.. . . . . . . . . . . . . . . . . . . . . . . . . . 32
COMMITMENT 5: Engaging with new and traditional media. . . . . . . . . . . . . . . . . . 33
COMMITMENT 6: Using technology.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
COMMITMENT 7: Using education as a tool for addressing and countering hate speech.. . 40
COMMITMENT 8: Fostering peaceful, inclusive and just societies to address the
root causes and drivers of hate speech. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
COMMITMENT 9: Engaging in advocacy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
COMMITMENT 10: Developing guidance for external communications.. . . . . . . . . . . 47
COMMITMENT 11: Leveraging partnerships. . . . . . . . . . . . . . . . . . . . . . . . . . . 48
COMMITMENT 12: Building the skills of United Nations staff. . . . . . . . . . . . . . . . . 49
COMMITMENT 13: Supporting Member States. . . . . . . . . . . . . . . . . . . . . . . . . 50
KEY RESOURCES ON HATE SPEECH. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51Foreword
by the Secretary-General
UNITED NATIONS STRATEGY AND PLAN OF ACTION ON
HATE SPEECH: DETAILED GUIDANCE ON IMPLEMENTATION
FOR UNITED NATIONS FIELD PRESENCES
Fighting hate, discrimination, racism and Implementing the Strategy requires concerted
inequality is at the core of United Nations system-wide efforts. My Special Adviser on the
principles and the Organization’s work. It is Prevention of Genocide is coordinating these
enshrined in our founding Charter, in the inter- efforts in close collaboration with the United
national human rights framework and in our Nations Working Group on Hate Speech, com-
collective efforts to achieve the Sustainable prised of 16 United Nations entities. United
Development Goals. Hate speech, including Nations Country Teams and our peace opera-
online, has become one of the most frequent tions and political missions are also engaged,
methods for spreading divisive and discrim- since we know that often the most effective
inatory messages and ideologies. This is action to address and counter hate speech
why I launched a United Nations Strategy happens at the national and grassroots levels.
and Plan of Action to counter this poison.
This Guidance1 provides detailed information
The Strategy embodies a commitment by the on how to implement the 13 commitments
United Nations to step up coordinated action set out in the Strategy and options for action
to tackle hate speech both globally and at that United Nations staff can take in field con-
the national level. It responds to the worrying texts, guided by the broad vision of prevention,
growth of xenophobia, racism and intolerance, and building on good practices from within
including anti-Semitism and anti-Muslim hatred, the United Nations system as well as from
around the world. Hate speech undermines Member States, civil society and other stake-
social cohesion, erodes shared values and holders. The Guidance is a living document
can lay the foundation for violence, undermin- that will be reviewed and updated as needed.
ing peace, stability, sustainable development
and the fulfillment of human rights for all. I encourage all Resident Coordinators and heads
of United Nations missions to use this guidance
to develop country-level action plans to tackle
1 Developed by the Office on Genocide Prevention and the Responsibility to Protect, in consultations with the United Nations Working
Group and several United Nations field presences
3 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020hate speech, drawing on existing plans and The United Nations also has an important role in
programmes, most importantly the Sustainable convening and partnering with others, including
Development Cooperation Frameworks. civil society, media and the private sector, in
particular tech and social media companies.
I also hope this Guidance will inspire
United Nations senior leaders in the field to I trust that this Guidance will facilitate
strengthen their collaborative work on this implementation of the Strategy on the ground
crucial challenge. We need a collective effort and bring us closer to upholding the values of the
as each entity has something to contribute Charter of the United Nations that reaffirms the
to addressing and countering hate speech dignity and worth of every person, a commitment
and no single entity can address and counter to live in tolerance and respect and the shared
hate speech on its own. While States have promise of the 2030 Agenda for Sustainable
the primary responsibility, the United Nations Development to leave no one behind.
is well-placed to support such efforts
through technical assistance and c
apacity
building and by ensuring that national
measures are in line with international
human rights norms and standards.
António Guterres
United Nations Secretary-General
4 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020Summary
This Guidance is a resource tool for United Nations field presences on
implementing the United Nations Strategy and Plan of Action on Hate Speech.
The Strategy covers three categories or levels of unlawful and lawful expression.
1. AT THE TOP LEVEL, “direct and public incitement to genocide” and “advocacy of national,
racial or religious hatred that constitutes incitement to discrimination, hostility or violence” are
prohibited under international law.
2. AT THE INTERMEDIATE LEVEL, certain forms of hate speech may be prohibited, but only if
restrictions are provided by law, pursue a legitimate aim (e.g. respect of the rights of others, or
the protection of public order) and are necessary and proportionate.
3. AT THE BOTTOM LEVEL, legal restrictions should not be imposed on the dissemination of
lawful expressions that are, for example, offensive, shocking or disturbing.
The primary duty bearers under international (e) the extent of its dissemination; and (f) the
human rights law are State actors, including likelihood of harm, including imminence (the
Governments, legislatures, State authori- “six-part test” or the “Rabat threshold test”).
ties, and courts. States remain at the centre
of the implementation of the Strategy. In implementing the Strategy, United
Nations field presences should note that:
The United Nations should support State actors
in discharging their responsibilities under inter- > Only incitement to discrimination, hos-
national human rights law and towards imple- tility or violence that meets all six
menting the Strategy. In doing so, the United criteria should be criminalized;
Nations should place victims at the centre of
> Less severe forms of incitement or hate
its approach. Civil society organizations are an
speech (i.e. which do not meet all six criteria)
indispensable partner to the United Nations.
should attract civil or administrative law-
United Nations field presences’ responses to based restrictions, or public policy responses;
hate speech should be calibrated according
> Public condemnation of hate speech,
to the level of severity, assessed on the basis
accountability for attacks on those exercis-
of (a) the social and political context; (b) the
ing their right to freedom of expression, and
status of the speaker; (c) the intention of the
the expediting of public policy measures on
speaker; (d) the content and form of the speech;
5 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020the promotion of diversity may be especially freedom of opinion and expression and the
important in the immediate aftermath of an right to equality and non-discrimination, in
incident of hate speech or incitement, and addressing and countering hate speech.
when tensions are escalating in a society.
United Nations peacekeeping missions with an
explicit mandate on hate speech have a height-
ened responsibility to implement the Strategy.
All United Nations field presences
have a common responsibility The United Nations Working Group on Hate
to implement the Strategy. Speech, 2 and the United Nations Office on
Genocide Prevention and the Responsibility
United Nations resident coordinators, coun- to Protect, as the designated focal point on
try teams (UNCT), peacekeeping opera- the Strategy, stand ready to provide sup-
tions and special political missions have port, technical assistance and further direc-
responsibilities to protect and promote tion to the United Nations field presences
for the implementation of this Guidance.
2 The United Nations Working Group on Hate Speech at Headquarters includes the following entities: Department of Global
Communications, Department of Peace Operations, Department of Political and Peacebuilding Affairs, Envoy of the Secretary-General
on Youth, Executive Office of the Secretary-General of the United Nations, Global Pulse, International Organization for Migration, Office
of Counter-Terrorism, the United Nations Office on Genocide Prevention and the Responsibility to Protect, Office of the United Nations
High Commissioner for Human Rights (OHCHR), Office of the United Nations High Commissioner for Refugees (UNHCR), United Nations
Alliance of Civilizations, United Nations Children’s Fund (UNICEF), United Nations Development Programme (UNDP), United Nations
Educational, Scientific and Cultural Organization (UNESCO) and United Nations Entity for Gender Equality and the Empowerment of
Women (UN-Women).
6 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020I. I ntroduction:
A Common Approach
Recent years have witnessed an upsurge in identity and objectives of the United Nations
hate speech around the world, often with grave as expressed in the Organization’s Charter —
implications. Hate speech has been identified especially respect for human rights without dis-
as a common “precursor to atrocity crimes, crimination — laying the foundation for violence,
including genocide” in many situations, “from while “setting back the cause of peace, stability,
Rwanda to Bosnia to Cambodia”. A campaign of3
sustainable development and the fulfilment of
hate speech that included language dehuman- human rights for all”.7 In today’s digital age, hate
izing the Rohingya, combined with the active speech is further “enabled and amplified expo-
silencing of critical voices, has been linked to nentially through digital technology, often target-
the commission of grave human rights viola- ing women, minorities, and the most vulnerable”.8
tions in Myanmar, more recently. Moreover, the
4
Hate speech is also often linked to disinforma-
coronavirus disease (COVID-19) pandemic has tion, misinformation and malinformation.9
given rise to a new wave of hate speech and dis-
crimination across the world.5 Hate speech has The United Nations Strategy and Plan of Action
been shown to result in a range of real harms, on Hate Speech, launched by the Secretary-
attacking tolerance, inclusion, social cohesion General in June 2019, is the first system-wide ini-
and shared values.6 It undermines the essential tiative designed to tackle hate speech as such.10
3 Remarks of the Secretary-General of the United Nations, António Guterres, at the launch of the United Nations Strategy and Plan
of Action on Hate Speech, 18 June 2019. On atrocity crimes generally, see United Nations Office on Genocide Prevention and the
Responsibility to Protect, Framework of Analysis for Atrocity Crimes (2014) (A/70/741-S/2016/71, annex).
4 A/HRC/39/CRP.2, paras. 1289–1360; and Gert Rosenthal, “A brief and independent inquiry into the involvement of the United Nations
in Myanmar from 2010 to 2018” (29 May 2019), p. 7. See also A/HRC/42/CRP.5, available from www.ohchr.org/EN/HRBodies/HRC/
MyanmarFFM/Pages/ReportHRC42thSession.aspx.
5 United Nations, “United Nations guidance note on addressing and countering COVID-19 related hate speech”, 11 May 2020.
6 Remarks of the Secretary-General at the launch of the United Nations Strategy and Plan of Action on Hate Speech.
7 Ibid.
8 Ibid.; see also the joint open letter on concerns about the global increase in hate speech, signed by 26 special procedure mandate hold-
ers, available at www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=25036&LangID=E.
9 Cherilyn Ireton and Julie Posetti, Journalism, Fake News and Disinformation: Handbook for Journalism Education and Training (Paris,
UNESCO, 2018).
10 Remarks of the Secretary-General at the launch of the United Nations Strategy and Plan of Action on Hate Speech; and Gert Rosenthal,
“A brief and independent inquiry into the involvement of the United Nations in Myanmar from 2010 to 2018”. Most United Nations texts
refer to “incitement to discrimination, hostility or violence” rather than “hate speech” as such, largely because there is no definition in
international law of the latter term and there is a lack of consensus about its meaning. Recent exceptions include General Assembly res-
olution 73/328, A/74/486, and the joint open letter on concerns about the global increase in hate speech, signed by 26 special procedure
mandate holders.
7 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020This Guidance has been developed by the United
The United Nations Strategy defines Nations Office on Genocide Prevention and the
hate speech as Responsibility to Protect, the designated United
Nations focal point on the Strategy, to provide
“any kind of communication in speech,
more detailed advice and direction on how the
writing or behaviour, that attacks or uses
Strategy should be effectively implemented
pejorative or discriminatory language
by United Nations field presences. Given the
with reference to a person or a group
work of the field presences at the frontlines of
on the basis of who they are, in other
the United Nations system, their engagement
words, based on their religion, ethnicity,
is critical to the effective implementation of
nationality, race, colour, descent, gender
the Strategy. The Guidance translates each of
or other identity factor”.
the Strategy’s 13 commitments into concrete
actions to be taken by field presences, and in
doing so, elaborates upon the responsibilities of
While the above is not a legal definition and is
key actors. It applies to all personnel in United
broader than the notion of “incitement to discrim-
Nations field presences, in both mission and
ination, hostility or violence”, which is prohibited
non-mission settings, including resident coordi-
under international human rights law,11 the defi-
nators (RCs), humanitarian coordinators, special
nition in the Strategy provides a single, unified
representatives, special envoys, personal envoys,
framework for how the United Nations system
and special coordinators in political and peace-
should address hate speech globally. Developed
keeping missions, as well as country teams and
on the basis of a joint effort by 14 United Nations
all United Nations staff. It offers examples of
entities, the Strategy tasks the United Nations
existing good practices on measures to address
with addressing “the root causes and drivers
hate speech, which should serve to “level up”
of hate speech”, on the one hand, and enabling
existing actions and efforts on the subject.
effective responses to its impact upon socie-
ties, on the other.12 The commitments set forth
In fleshing out how to implement the Strategy,
in the Strategy are not aimed at “preventing”
this Guidance underlines the importance of
speech as this could suggest restrictions on
a clear, common and concrete approach to
freedom of opinion and expression that would
address and counter hate speech, one that
be problematic in practical terms and contrary to
is coherent, comprehensive and coordi-
international human rights law, but are directed
nated system-wide, and one that protects
at addressing and countering hate speech.13
and promotes human rights in accordance
11 Art. 20 of the International Covenant on Civil and Political Rights; and the Rabat Plan of Action on the prohibition of advocacy of national,
racial or religious hatred that constitutes incitement to discrimination, hostility or violence (A/HRC/22/17/Add.4, annex).
12 The following United Nations entities were involved in the drafting of the Strategy: Department of Global Communications, Department
of Political and Peacebuilding Affairs, Envoy of the Secretary-General on Youth, Executive Office of the Secretary-General of the United
Nations, Global Pulse, Office of Counter-Terrorism, the United Nations Office on Genocide Prevention and the Responsibility to Protect,
OHCHR, United Nations Alliance of Civilizations, UNDP, UNESCO, UNHCR, UNICEF and UN-Women. These entities, together with the
Department of Peace Operations, the Special Representative of the Secretary-General on Violence against Children and the International
Organization for Migration, form the United Nations Working Group on Hate Speech.
13 The language of “prevention” of hate speech would therefore suggest a “prior restraint”. Art. 19 (1) of the International Covenant on Civil
and Political Rights protects “the right to hold opinions without interference”, a right which to which the Covenant “permits no exception
or restriction”; see Human Rights Committee, general comment No. 34 (2011) on the freedoms of opinion and expression, para. 9.
8 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020with international law. This international legal While the Guidance is mostly designed for
framework encompasses both relevant and action at the national level, much of its con-
binding treaties and soft law (or non-bind-
14
tent can be used for cross-border responses.
ing standards), most notably on the right This is particularly important in situations
to freedom of opinion and expression. 15
where those who disseminate hate speech
have foreign links or are based outside the
country in diaspora communities, or where the
States are the primary duty bearers under content of hate speech is directed at foreign-
this international legal framework, and ers, those perceived as foreigners, or others
hence the main responsibility to address targeted because of their “foreign” identity.
and counter hate speech lies with State The circulation of hate speech online on social
actors. The Strategy provides an essential media platforms is also borderless. United
framework for how the United Nations — Nations country teams and peace operations
working with others, including civil society are therefore strongly encouraged to discuss
organizations, media outlets, tech com- their approaches to the implementation of
panies and social media platforms — can the Strategy under this Guidance with their
support and complement States in their counterparts, especially in neighbouring
efforts to address and counter hate speech. countries or countries with diaspora com-
munities. United Nations regional presences
are also encouraged to explore what role
they can play together, in the implementa-
The Guidance reflects critical lessons drawn
tion of the Guidance. Furthermore, United
from past experiences where hate speech and
Nations field presences should consider
incitement to discrimination, hostility or vio-
opportunities to involve regional multilateral
lence have fuelled or exacerbated widespread
organizations and networks of independ-
violations and provided an environment condu-
ent national human rights organizations or
cive to the commission of atrocity crimes.16
non-governmental organizations (NGOs).
14 Art. 19 of the Universal Declaration of Human Rights, and arts. 19 and 20 of the International Covenant on Civil and Political Rights; and
see Human Rights Committee, general comment No. 34.
15 See, especially, the Rabat Plan of Action; A/74/486; and the joint open letter on concerns about the global increase in hate speech,
signed by 26 special procedure mandate holders.
16 Gert Rosenthal, “A brief and independent inquiry into the involvement of the United Nations in Myanmar from 2010 to 2018”. See also the
Report of the Secretary-General’s Internal Review Panel on United Nations Action in Sri Lanka, of November 2012.
9 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020II. Understanding hate speech
A. What is “hate speech” under give rise to any binding obligations upon States.17
There is no universally accepted definition of
the Strategy?
hate speech under international law.18 Under the
Strategy, hate speech requires that the following
The Strategy defines hate speech as the three components be present (see figure 1).
following:
Any kind of communication in speech, 1. I T IS “ANY KIND OF
writing or behaviour, that attacks or uses COMMUNICATION”, WHETHER
pejorative or discriminatory language with IN THE FORM OF “SPEECH,
reference to a person or a group on the basis W RITING OR BEHAVIOUR”.
of who they are, in other words, based on
their religion, ethnicity, nationality, race, > Hate speech can be conveyed through
colour, descent, gender or other identity any form of expression, including images,
factor. This is often rooted in, and gener- cartoons, memes, art objects, gestures and
ates, intolerance and hatred, and in certain symbols.
contexts can be demeaning and divisive.
> Hate speech can be disseminated offline or
online.
This definition is for the purposes of supporting > With regard to behaviour, it is important to
a common basis for the implementation of the distinguish hate speech from hate crimes, as
Strategy by the United Nations, only. It does not well as from acts of discrimination (i.e. when
FIGURE 1. THE COMPONENTS OF HATE SPEECH UNDER THE STRATEGY
HATE SPEECH
for the purposes of the Strategy, requires that these three components be present
2. that attacks or uses pejorative language
1. Communication
(speech, writing
or behaviour)
3. with reference to one or more identity factors
17 United Nations Strategy and Plan of Action on Hate Speech, p. 2.
18 ARTICLE 19, “Hate Speech” Explained: A Toolkit (London, 2015), p. 10. For examples of various approaches to hate speech, see p. 12.
10 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020an individual is treated less favourably than national or social origin; property; birth or
others in a similar situation, on the basis other status, including indigenous origin
of an identity factor). Hate speech neces- or identity; caste; disability; health status;
sarily involves expression, whereas most migrant or refugee status; place of residence;
hate crimes do not, though they are often economic and social situation; marital and
preceded by hate speech. Furthermore, all family status; sexual orientation; gender iden-
hate crimes are criminal offences, whereas tity; intersex status; age; albinism; and HIV
hate speech will not always constitute a crim- status.19 As a general rule, United Nations
inal offence. field presences should focus on those
groups in situations of vulnerability due to
entrenched or historic stigmatization, dis-
2. I T “ATTACKS, OR
crimination, long-standing conflicts (e.g. over
USES PEJORATIVE OR
land or other resources), and exclusion and
DISCRIMINATORY LANGUAGE”.
marginalization from the political, economic
> Under the Strategy, hate speech is commu- and social life of the society.
nication which is biased, bigoted, intolerant
or prejudiced (“discriminatory”) or contemp- > Communication that makes reference to two
tuous or demeaning (“pejorative”) of an or more identity factors is common and can
individual or group based on their identity. increase the harm suffered by its targets.
For instance, women on Twitter face more
hateful abuse and harassment if they are
3. I T MAKES REFERENCE TO
of colour and openly lesbian or trans.20
AN “IDENTITY FACTOR”.
> Hate speech is communication that makes ref- > The bullying, including cyberbullying, of chil-
erence to a person or group’s “religion, ethnic- dren can be a manifestation of hate speech,
ity, nationality, race, colour, descent, gender or particularly when it involves one of the
other identity factor” — characteristics which above-mentioned identity factors, as it mirrors
are explicitly recognized in the Strategy. how hate speech operates in adult society.
> However, the list of identity factors (often > Hate speech is communication that refers to
called “protected characteristics”) laid the real, purported or imputed identity factors
down in the Strategy is clearly non-exhaus- of an individual or group in a negative way.
tive, given that “any other identity factor” is But it does not include communication that
included. In interpreting the Strategy, United refers to the State, its offices or symbols, the
Nations field presences should embrace an status of public officials, or religious leaders
inclusive approach, based on the specific and doctrine as well as tenets of faith. These
context in which they operate, and encom- entities and tenets cannot be the target of
pass such recognized identify factors as: hate speech, which can only be directed
language; political or other opinion; belief; at individuals or groups of individuals.21
19 ARTICLE 19, “Hate Speech” Explained: A Toolkit, p. 14; and Committee on Economic, Social and Cultural Rights, general comment No. 20
(2009) on non-discrimination in economic, social and cultural rights, paras. 18–35.
20 Amnesty International, #ToxicTwitter, Violence and Abuse against Women Online, ACT 30/8070/2018, pp. 19–21 and 26–29.
21 See Human Rights Committee, general comment No. 34, paras. 38 and 48. See also ARTICLE 19, “Hate Speech” Explained: A Toolkit, pp.
30–31.
11 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020B. What types of speech are speech to justify or endorse repressive meas-
ures against those exercising their freedom of
covered by the Strategy?
expression (and other rights, such as the right
The Strategy covers a range of unlawful and to peaceful assembly), such as against human
lawful types of expression rights defenders, women’s rights defenders,
journalists, dissenters, civil society activists,
The Strategy’s definition of hate speech cap- and persons belonging to minority groups.
tures a very broad range of both unlawful and
also lawful forms of hateful expression.
The types of hate speech covered by the
THE THREE LEVELS OF
Strategy can be divided into three categories, HATE SPEECH COVERED
according to the level of severity. Under inter- BY THE STRATEGY ARE:
national law, States have different obligations
and/or responsibilities when responding to
1. TOP LEVEL
these three categories of hate speech. United
Nations field presences should be aware of The severest forms of hate speech are prohib-
the differences between the three categories ited under international law. Such expressions
and what responses to them (legal and non- include, most notably: (a) “direct and public
legal) are required and/or permissible. This incitement to commit genocide”, as defined
is important particularly when engaging with by international criminal law; 22 and (b) “any
Governments seeking to adopt legislation that advocacy of national, racial or religious hatred
criminalizes hate speech, which often does that constitutes incitement to discrimination,
not meet the strict conditions of international hostility or violence”, as defined in article 20 (2)
law. United Nations field presences may also of the International Covenant on Civil and
be faced with State actors and political groups Political Rights.23 In addition, article 4 of the
weaponizing the idea of or the term hate International Convention on the Elimination of
FIGURE 2. THE SCOPE OF THE STRATEGY
Lawful Unlawful
Incitement
hate speech hate speech
22 Art. 3 (c) of the Convention on the Prevention and Punishment of the Crime of Genocide; and arts. 6 and 25 (3) (e) of the Rome Statute of
the International Criminal Court.
23 It is stated in art. 20 (2) that “any advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or
violence shall be prohibited by law”.
12 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020All Forms of Racial Discrimination imposes a emotions of opprobrium, enmity and detesta-
duty upon States to criminalize “all dissemi- tion towards the target group.
nation of ideas based on racial superiority or
hatred, incitement to racial discrimination, as > “Advocacy” should be understood as requir-
well as all acts of violence or incitement to ing an intention to promote hatred publicly
such acts against any race or group of per- towards the target group.
sons of another colour or ethnic origin”.
> “Incitement” refers to statements which
Incitement requires a triangular relationship create an imminent risk of discrimination,
between the hate speaker, an audience and hostility or violence against persons belong-
the target group, as in figure 3 below.24 ing to targeted groups.25
According to international standards on the United Nations field presences should be
meaning of “incitement to hostility, discrimina- aware that whether an expression of incite-
tion or violence”: ment to discrimination, hostility or violence
is severe enough to amount to a criminal
> The terms “hatred” and “hostility” should be offence depends on whether it fulfils all of
understood to refer to intense and irrational the criteria in the six-part threshold test set
FIGURE 3. THE TRIANGULAR RELATIONSHIP OF INCITEMENT
Advocacy of hatred
Public Audience Likely and imminent danger
based on protected of acts of discrimination,
characteristics Causation hostility, or violence
Knowledge of the likelihood
of the audience being incited
to an act of discrimination,
hostility or violence
Hate
Hate Speaker Target Group
SOURCE: ARTICLE 19, “Hate Speech” Explained: A Toolkit, p.73
24 ARTICLE 19, “Hate Speech” Explained: A Toolkit, p. 73.
25 Rabat Plan of Action, para. 21; and ARTICLE 19, The Camden Principles on Freedom of Expression and Equality (London,
2009), principle 12.
13 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020out in the Rabat Plan of Action on the prohi- based on their identity (e.g. as women, youth
bition of advocacy of national, racial or reli- or migrants) if the three-part test is met. Such
gious hatred that constitutes incitement to restrictions may be permissible under this test
discrimination, hostility or violence, which is and especially important at certain times, such
a high threshold. The criteria are: (a) the con-
26
as in the run-up to elections, or in relation to
text of the expression; (b) its speaker, (c) their certain contexts, in the broadcast media or in
intent; (d) its content and form; (e) its extent educational institutions. Restrictions on speech
and magnitude; and (f) the likelihood, including that may threaten national security, such as
imminence, of inciting actual action against the incitement to terrorism and violent extremism,
target group. The meaning of these criteria is which is often conflated with hate speech,
further explained in table 2 of this Guidance. also need to meet the same three-part test.
It should be noted that certain speech acts
2. INTERMEDIATE LEVEL
may constitute discrimination as such (e.g. an
Certain forms of hate speech may be prohib- instruction by an employer to an employee to
ited under international law, even if they do not discriminate against someone because of their
reach the above-mentioned threshold of incite- identity) and should be legally proscribed.
ment, in specific circumstances. Under article
19 of the International Covenant on Civil and
3. BOTTOM LEVEL
Political Rights, certain types of biased expres-
sion may be restricted if such restrictions meet The least severe forms of hate speech
certain strict conditions. Such limitations need must not be subject to legal restrictions under
to: (a) be provided by law; (b) pursue a legitimate international law. Legal restrictions should not
aim, such as the respect of the rights of others, be imposed on the dissemination of the following
including the right to equality and non-discrimi- types of speech (even though they may contribute
nation, or the protection of public order; and (c) to spreading hatred):
be necessary in a democratic society and pro-
> Expression that is offensive, shocking or
portionate (the “three-part test”).27 Restrictions
disturbing
on freedom of expression may therefore be
imposed to protect individuals from hate speech > The condoning or denial of historical events,
based on their protected characteristics (or including crimes of genocide or crimes
identity factors) in order to ensure their rights to against humanity
equality and non-discrimination, but as long as
the conditions of the three-part test are met. > Blasphemous speech, including insult to reli-
gious feelings, lack of respect for a religion
For instance, restrictions on freedom of or other belief system, and defamation of
expression may be imposed to protect individ- religions28
uals from threats of violence or harassment
26 See www.ohchr.org/EN/Issues/FreedomOpinion/Articles19-20/Pages/Index.aspx.
27 Art. 19 (3) of the International Covenant on Civil and Political Rights.
28 In general, however, blasphemous expression should not be considered hate speech. Furthermore, under international law, States are
obliged to prohibit incitement to terrorist acts. See ARTICLE 19, “Hate Speech” Explained: A Toolkit, pp. 29–30.
14 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020> Disinformation (and misinforma-
FIGURE 4. ARTICLE 19’S HATE SPEECH PYRAMID
tion and malinformation) 29
unless such forms of expression also consti-
tute incitement to hostility, discrimination or Applicable
International
violence under article 20 (2) of the International Legal
Covenant on Civil and Political Rights.30 Instruments
Laws banning such expression are likely to
result in the shutting down of public inter-
est debate and civic space, to have a chilling
effect on legitimate expression, and to help Incitement
Genocide
to genocide
to shield powerful figures from scrutiny and and other
Convention
+
allow for the targeting of journalists, human violations of Rome Statute
International Law
harm
rights defenders, the opposition and minorities. MUST be
Advocacy of restricted
Though such types of expression do not war- Article 20(2)
ity of
discriminatory ICCPR
rant legal restrictions, they may nonetheless hatred constituting
Sever
incitement
demand non-legal responses if considered as to hostility,
hate speech under the Strategy (see table 1). discrimination
or violence
United Nations field presences should encour- Hate speech MAY be Article 19(3)
age States and non-State actors to respond to which may be restricted restricted ICCPR
to protect the rights
such forms of hate speech through a “plurality or reputations of others,
or for the protection of national
of policies, practices and measures nurturing security or of public order, or of
social consciousness, tolerance and under- public health or morals
standing change and public discussion”.31
Lawful “hate speech” Must be Article 19
The commitments in the Strategy require a raising concerns PROTECTED ICCPR
comprehensive approach, as indicated by the in terms of intolerance
actions and recommendations set out in this
Guidance, in order to address the root causes
and counter the impacts of hate speech,
including such forms at the bottom level. The Strategy’s three levels of hate speech
Bottom Level Intermediate Level Top Level
The three levels of hate speech are
reflected in ARTICLE 19’s Hate Speech
SOURCE: Based on ARTICLE 19, “Hate Speech” Explained: A Toolkit, p.19
Pyramid, which is indicated in figure 4.32
29 A recent UNESCO report differentiates three related concepts: misinformation, disinformation and malinformation. Misinformation is
“information that is false, but the person who is disseminating it believes that it is true”. Disinformation is “information that is false, and
the person who is disseminating it knows it is false”. It is “a deliberate, intentional lie, and points to people being actively disinformed
by malicious actors”. Malinformation is information that is based on reality, but that is used to inflict harm on a person, organization
or country. See Cherilyn Ireton and Julie Posetti, Journalism, Fake News and Disinformation: A Handbook for Journalism Education and
Training, pp. 45–46.
30 See Human Rights Committee, general comment No. 34, paras. 48–49; and ARTICLE 19, The Camden Principles on Freedom of
Expression and Equality, principle 12.
31 Rabat Plan of Action, para. 35.
32 ARTICLE 19, “Hate Speech” Explained: A Toolkit, p. 19.
15 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020TABLE 1. LEGAL RESTRICTIONS AND NON-LEGAL MEASURES
Table 1 distinguishes the circumstances in which legal prohibitions and restrictions are required, possible
or unacceptable under international law. It also provides examples of non-legal measures which may be
taken in response to any kind of hate speech.
Responses possible under international law
Legal
Hate speech restrictions Other responses
TOP LEVEL The promotion of an enabling environment for the exercise of freedom of
Legal expression, and of the right to equality and non-discrimination, through:
Direct and public prohibitions
• Anti-discrimination legislation that • Access to information
incitement to are required is in compliance with international
• Protection of civic space
genocide human rights norms and
Sanctions standards, and its implementation • Political and religious leaders,
Advocacy of • Criminal scholars, and other public
• Decriminalization of
hatred that figures avoiding statements
(if six-part blasphemy and defamation
promoting discrimination and
constitutes test is • Accountability (i.e. the absence promptly speaking out against
incitement to fulfilled) of impunity) for attacks on hate speech, including hate
discrimination, • Civil journalists, human rights speech targeted at their political
hostility or defenders, including women’s opponents, while making it
• Administrative human rights defenders, clear that violence cannot be
violence
activists, civil society actors, justified by prior provocation and
and others exercising their avoiding statements promoting
INTERMEDIATE Legal freedom of expression discrimination or intolerance
LEVEL restrictions
The adoption of public policy measures to promote diversity, including:
may be
Threats of • A public policy framework for community leaders, and religious
imposed if
media pluralism and diversity and faith leaders and actors
violence they meet
strict criteria • Curriculum reform to promote • Training of journalists and
Harassment the positive value of diversity in media professionals on freedom
of legality, order to ensure understanding of expression and the right to
motivated
legitimacy, of a broad plurality of peoples equality and non-discrimination
by bias
necessity and and groups, public education
• Official recognition of past
proportionality and information campaigns to
atrocities (such as memorials,
combat negative stereotypes,
dedication of public sites, and
and education initiatives to
BOTTOM development of relevant education
complement anti-bullying
and research programmes)
LEVEL policies, promote social cohesion,
and celebrate diversity • •Foster individuals’ critical
thinking, social and emotional
Offensive • Training on freedom of expression
skills and responsible
and the right to equality and
speech* engagement in order to make
non-discrimination for public
them less vulnerable to incitement
officials, politicians, teachers,
Blasphemous (including through tools such as
members of the armed forces,
speech* global citizenship education and
the police and the judiciary, legal
media and information literacy)
and medical professionals, the
Denial of representatives of minorities,
historical
events (e.g. of No legal
restrictions The promotion of stakeholders’ initiatives, including:
genocide)*
• Civil society initiatives (e.g. • Internet intermediaries’ initiatives
Disinformation, human rights education, peer- on addressing hate speech (as
to-peer learning, monitoring and long as they are transparent and
misinformation
reporting of hate speech, and in accordance with international
and malinforma- storytelling by victims/targets) human rights standards)
tion*
• Alliances formed between • Initiatives to promote
State and influential actors intergroup dialogue and
(such as religious leaders, intergroup understanding
faith actors and artists)
• Supporting children, educators
• Promotion of an independent and and the school system broadly to
pluralistic media (with diversity promote the value of diversity
of content and workforces)
* Such speech is protected expression and should only be considered as hate speech when used as a vehicle for hatred against individuals
or groups based upon protected characteristics.
16 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020C. How should the severity of consistently analyse the nature and measure
the severity of any instance of hate speech
hate speech be assessed?
that they might encounter, and to calibrate
United Nations field presences’ responses to their actions and interventions in response.34
hate speech should be calibrated according to
its severity Different degrees of severity call for different
legal and policy responses. To determine the
The seriousness or severity of hate speech severity of any instance of hate speech, United
may be assessed on the basis of six criteria, Nations field presences should ask them-
originally identified as the “six-part threshold selves the questions indicated in table 2. It is
test” in the Rabat Plan of Action. Though 33
emphasized that the questions merely provide
this test was conceived to identify incite- a framework for gauging the severity of hate
ment to discrimination, hostility or violence speech under the conditions of any particular
that ought to be criminalized, its six criteria context. They do not provide a scientific formula
can be drawn upon and applied by United for assessing the severity of the hate speech.35
Nations field presences as a framework to
TABLE 2. HOW SEVERE IS HATE SPEECH?
A framework for assessing the severity of hate speech, derived from the Rabat Plan of Action: the
Rabat threshold test 36
Criteria of
severity Indicators Questions to ask
1. The legal, > Is there an ongoing conflict or are there incidents of violence against
Context political, social the targeted group?
and economic
context > Does the law recognize the targeted individual’s or group’s identity?
> Is there any anti-discrimination legislation and is it aligned with inter-
national human rights norms and standards?
> How does the media report on the targeted group, if at all?
> Is the media independent?
> Are there upcoming elections?
> What is the role of identity politics in electoral campaigns?
> Are there any challengers to the hate speech? If so, who are they?
33 Rabat Plan of Action, para. 29.
34 OHCHR, One-pager on “incitement to hatred”, available in several languages from www.ohchr.org/EN/Issues/FreedomOpinion/
Articles19-20/Pages/Index.aspx.
35 It is now easier for the six-part threshold test, or “Rabat threshold test”, to be used as a tool and be disseminated more widely by United
Nations field presences, as it has now been translated into 32 languages; see www.ohchr.org/EN/NewsEvents/Pages/Hate-speech-
threshold-test.aspx.
36 See www.ohchr.org/EN/Issues/FreedomOpinion/Articles19-20/Pages/Index.aspx.
17 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020Table 2 (continued)
2. The position or > Does the speaker have power or influence in society?
Speaker status of the
speaker in society
> Are they a national leader, politician, public official, religious or faith
and their authority leader, or social media influencer?
or influence over > What is their reputation and standing in society?
their audience
> What is their relationship with targeted groups?
3. The state of mind > Did the speaker intend to engage in advocacy of hatred against an
Intent of the speaker individual or group on the basis of a protected characteristic?
> Was there a triangular relationship, that is, did the speaker intend to
incite the audience against the target group? (in the case of incitement
only)
> Was the speaker merely negligent or reckless in their expression?
> Was the speaker’s communication in poor taste or showing a lack of
judgment?
4. Nature and style of > To what extent was the speech provocative and direct?
Content and the expression
form
> What was the form, style and nature of arguments deployed in the
speech?
> Was there any balance of arguments deployed in the expression?
> Was the expression in the public interest?
> Was it artistic or academic expression?
5. Reach of the > How public was the expression when it was made?
Extent and expression
magnitude of
> How widely was the expression disseminated?
the expres- > How large was the audience that was exposed to the expression?
sion
> Was the expression disseminated offline and/or online?
6. Degree of risk of > Was there a reasonable probability that the speaker’s communication
Likelihood, harm would succeed in inciting actual action by the audience against the
including target group? (in the case of incitement only)
imminence
> Was there a reasonable probability that harm would result from the
expression? (e.g. physical and/or psychological harm to an individual
or group, or harm to social cohesion)
> Would the harm have affected particular individuals within the targeted
group (e.g. women, children or youth) more than others?
> Would the harm have a different impact upon women and men?
18 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020D. How is the Strategy relevant missions. While all these actors have responsi-
bilities to implement the Strategy, the basis of
to United Nations field
these responsibilities varies according to their
presences?
respective duties or the various components of
All field presences have a common respon- the mandates establishing their presence (e.g.
sibility to implement the Strategy Security Council resolutions for peacekeeping
operations or special political missions). In
The Strategy should be considered as part addition, the regional offices of entities of the
of the United Nations system’s responsibili- United Nations system — such as the Office
ties on human rights. In his call to action for of the United Nations High Commissioner for
human rights, the Secretary-General empha- Human Rights (OHCHR), the United Nations
sizes that “human rights are the responsibility Development Programme (UNDP), the United
of each and every United Nations actor” and Nations Educational, Scientific and Cultural
that “a culture of human rights must perme- Organization (UNESCO) and the United Nations
ate everything we do, in the field, at regional Entity for Gender Equality and the Empowerment
level and at Headquarters”. In the document, of Women (UN-Women) — can play an impor-
he calls on United Nations leaders in the field, tant role in supporting field presences.
including heads of mission and resident coor-
dinators, to play their part.37 The Secretary-
General’s call to action reflects and builds
upon Human Rights Up Front, the follow-up R ESIDENT COORDINATORS
to the Rosenthal report, and the Secretary-
38
AND COUNTRY TEAMS
General’s broader priorities “which emphasize
prevention, protection and human rights in our Resident coordinators and coun-
awareness, decision-making and programming
try teams have responsibilities
at field, regional and Headquarters levels”.39
to uphold and promote freedom
The responsibility for the implementation of the of expression and the right to
Strategy in the field lies with both the leadership equality and non-discrimination
and staff within United Nations country teams,
including humanitarian country teams, and The United Nations resident coordinators,
United Nations peacekeeping and special politi- their offices (RCOs) and the United Nations
cal missions. The following actors are especially country teams have a clear responsibility to
relevant: (a) resident coordinators and heads implement the Strategy, for several reasons.
of agencies in United Nations country teams
(including in their role as humanitarian coordina- First, as the highest-ranking representatives of
tors when there is a humanitarian country team); the United Nations at the country level, resident
and (b) special representatives, special envoys, coordinators are the designated representa-
personal envoys, representatives and special tives of, and hence directly accountable to, the
coordinators in political and peacekeeping Secretary-General for the implementation of the
37 Secretary-General of the United Nations, “The highest aspiration: a call to action for human rights” (2020), p. 4.
38 The report by Gert Rosenthal entitled “A brief and independent inquiry into the involvement of the United Nations in Myanmar from 2010
to 2018”.
39 Secretary-General of the United Nations, “The highest aspiration: a call to action for human rights”, p. 6.
19 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020Strategy. The resident coordinators are also at > The resident coordinator and country
the heart of the 2030 Agenda for Sustainable team promote fundamental values, stand-
Development, since they coordinate the United ards and principles of the Charter of the
Nations Sustainable Development Group agen- United Nations, including respect for and
cies, funds and programmes working on protection of human rights and gender
development (i.e. the United Nations country equality, and advocacy on the commit-
teams).40 Second, the resident coordinators and ment to “leave no one behind” and reach-
country teams cover the broadest geographical ing the furthest behind first, ensuring
scope of the United Nations field presences. a strategic and coherent approach;
(As of February 2020, there were 129 resident
coordinators and 131 country teams). Failing > Country team members promote norma-
to respond effectively to incidents of hate tive and advocacy work in the areas of
speech can undermine the work of the United their mandate, in line with agreed spe-
Nations in upholding and promoting human cific working arrangements and in con-
rights, including freedom of expression and sultation with the resident coordinator
the right to equality and non-discrimination, in exceptional and sensitive cases;
in both non-mission and mission settings. 41
> The resident coordinator leads the country
The Management and Accountability team in fostering a coherent and strate-
Framework of the United Nations Development gic engagement on, and pursuance of, the
and Resident Coordinator System, which normative agenda of the United Nations,
outlines United Nations country teams’ as per international and regional treaties
roles and responsibilities, indicates that: and conventions, and in support of national
capacity development, in accordance with
> The resident coordinator works with country relevant mandates and responsibilities;
team members to align agency programmes
for development and pooled funding with > The performance assessment systems
national development needs and priorities as that apply to the resident coordina-
well as with the United Nations Sustainable tor and country team members include
Development Cooperation Framework performance indicators relating to pro-
and international norms and standards; moting norms and gender equality.42
> The resident coordinator, together with the Consequently, the Strategy should be fully
country team, builds strategic partnerships integrated into the work of the resident
around United Nations collective support for coordinators and country teams, including
the 2030 Agenda, enables active, meaningful with the support of peace and development
participation of local communities, particu- advisers, by forming a consistent part of the
larly those left behind or at risk of being left common country analysis that they under-
behind, and recognizes the United Nations take under the United Nations Sustainable
system’s accountability to the public; Development Cooperation Framework.
40 See https://unsdg.un.org/2030-agenda.
41 United Nations Development Group, Guidance Note on Human Rights for Resident Coordinators and UN Country Teams (January 2017),
p. 10.
42 United Nations Sustainable Development Group, “Management and accountability framework of the UN development and resident coor-
dinator system” (18 March 2019, with editorial revision carried out from 1 to 26 April 2019), pp. 9–11.
20 UNITED NATIONS STR ATEGY AND PLAN OF ACTION ON HATE SPEECH: DETAILED GUIDANCE | SEPTEMBER 2020reasonably considered to have a heightened
PEACEKEEPING MISSIONS level of responsibility in implementing the
commitments contained in the Strategy.
Peacekeeping missions with an
Yet peacekeeping missions whose mandates do
explicit mandate on hate speech
not contain such explicit language concerning
have a heightened responsibility hate speech or incitement still have an important
to implement the Strategy role in implementing the Strategy, one that is
reinforced by their mandate on the protection of
Some Security Council resolutions establishing civilians.48 The increase in hate speech within
or extending the mandates of peacekeeping a peacekeeping context may itself be an early
missions include explicit language on “hate warning indicator of a growing threat to the
speech”, 43 or reference “incitement to eth- protection of civilians and the onset of serious
nic and religious hatred and violence” and human rights violations. The November 2019
“incitement to violence”44 or “hate speech” policy on the implementation of mandates on the
and “incitement to violence”.45 Such direct protection of civilians further states that, as part
language indicates that these peacekeeping of the strategy of protection through dialogue
missions have an obligation vis-à-vis hate and engagement, “public information activities
speech in the implementation of their mandate and strategic communications will be used to
and in reporting back to the Security Council. influence behaviour, prevent or stop attacks on
The mandate of the United Nations Mission civilians and respond to issues such as hate
in South Sudan, for instance, authorizes it to speech which may lead to threats to civilians”.49
“use all necessary means to”, among other It specifically indicates that it is one of the core
things, “monitor, investigate and report on responsibilities of heads of strategic communi-
incidents of hate speech and incitement to vio- cations “to gather and share relevant information
lence”.46 The United Nations Multidimensional with mission protection-of-civilians coordina-
Integrated Stabilization Mission in the Central tion forums… on the use of hate speech”.50
African Republic is authorized “to support
the Panel of Experts established pursuant to
resolution 2127 (2013) in collecting informa-
tion about acts of incitement to violence, in SPECIAL POLITICAL MISSIONS
particular on an ethnic or religious basis, that
undermine the peace, stability or security”.47 Fostering peaceful, inclusive and just societies is
Peacekeeping missions with such explicit key to addressing the root causes and drivers of
mandates on hate speech may therefore be hate speech.
43 Security Council resolution 2502 (2019), concerning the mandate of the United Nations Organization Stabilization Mission in the
Democratic Republic of the Congo.
44 Security Council resolution 2499 (2019), concerning the mandate of the United Nations Multidimensional Integrated Stabilization
Mission in the Central African Republic.
45 Security Council resolution 2459 (2019), concerning the mandate of the United Nations Mission in South Sudan.
46 Ibid., para. 7 (c) (iii).
47 Security Council resolution 2499 (2019), para. 34 (c).
48 Department of Peace Operations, “Policy: the protection of civilians in United Nations peacekeeping” (effective date: 1 November 2019).
49 Ibid., para. 53.
50 Ibid., annex.
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