The ICANN Business Constituency (BC) submits the attached comment on Work Stream 2 Recommendations to Improve ICANN Staff Accountability. ( ICANN comment page at https://www.icann.org/public-comments/accountability-recs-2017-11-13-en ) This comment was drafted by Stephanie Duchesneau, with edits by Marilyn Cade and Steve DelBianco. It was approved in accord with the BC Charter. — Steve DelBianco Vice chair for policy coordination ICANN Business Constituency