Hi, Having read the documents provided and then withdrawn I feel safe saying: - ICANN does not appear to actually have a whistleblower program - it has a hotline for informing it about things that might endanger ICANN. It is not a accountability nor transparency mechanism. In some ways it seems more suited as a cover-up mechanism. - ICANN does not protect the whistle blower in any way for employment consequences. - ICANn does not make any results or statistics available on the Hotline program. There is NO transparency to its operations. - ICANN does not meet the requirements as contained in the One World Trust report and as recommended by ATRT1 consultations. Unfortunately ATRT1 was focused one the GAC and the Board, this is one of the things they ignored. I also find no explanations in the ATRT1 report or appendices on why they ignored this topic or the comments/recommendations that the ATRT1 received - The full details of any hotline reports are sent to:

Upon receipt of a report, Lighthouse shall simultaneously notif via email

ICANN’s Chief Operating Officer, ICANN’s General Counsel and Secretary, ICANN’s Deputy General Counsel responsible for employment matters, and ICANN’s Director of Human Resources (“Hotline Committee”).

It is my beleive that the continued absence of such a properly constituted program is a barrier to accountability and transparency. avri