Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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The attachment explains the IPC's rational for objecting to the proposed version of the Code of Conduct for SOIs. The filing includes legal citations, governance and public policy concerns. We fear that the drafters of the proposed policy have not considered these issues and should consider them before moving forward.
The IPC understands that ICANN is engaged in a bona fide effort to promote transparency and ethical conduct with ICANN’s Multi Stakeholder Model. However laudable the intention, this effort lacks the required specificity and enforcement mechanisms to form a workable policy. Further, the language of the policy violates ICANN’s by-laws and the right to representation by qualified counsel and other professionals in complex business transactions. The IPC stands ready and willing to work with the ICANN community on strengthening ethical guidelines that are appropriate, compliant with ICANN’s bylaws, and have meaningful impact.