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Comment on the Draft Recommendation of the Committee of Ministers to member States on combating hate speech

The National Council of Women of Finland wishes to thank the Committee of Experts on Combating Hate Speech on its work in drafting the Recommendation to member States on combating hate speech. The National Council finds the draft recommendation generally very well written and well able to catch the complex nature of the phenomenon of hate speech. 


The National Council especially wishes to thank the Committee for taking into consideration the following: 

  • That the Recommendation takes into consideration the gendered nature of the phenomenon, affecting women especially and in more severe and sexualized forms than others, that the definition of hate speech explicitly mentions sex, gender, and gender identity as characteristics which hate speech might target, and that sexist threats are mentioned as an example of acts that could be condemned under criminal law; 
  • That the Recommendation recognizes the need to tackle the phenomenon in an intersectional manner, as in addition to women, different minorities also face hate speech more often than others, recommends a gender sensitive approach, and advocates for support to victims and those affected by hate speech; 
  • That the phenomenon is recognized as international in nature, and that in order to tackle it efficiently, common definitions, actions and collaboration are needed both domestically and internationally; 
  • That the role of internet intermediaries is recognized as a crucial one, that responsibilities for internet intermediaries are suggested in combating hate speech, producing public transparency reports on hate speech cases and removals, reviewing their online advertising and targeting systems, and developing alternatives to de-amplify hate speech, and that Member States are advised to require internet intermediaries to fulfil their human rights due diligence; and 
  • That the phenomenon is recognized as complex and that a comprehensive approach is promoted to efficiently combat it and the chilling effect it causes, and that in addition to legislative measures, the Recommendation raises the importance of counter and alternative speech, education, training and awareness raising to combat the phenomenon. 

For further consideration 

The National Council of Women of Finland suggests the following points for further consideration in developing the draft Recommendation: 

  • That hate speech, when targeting women, is more often sexualized in nature, and should be seen as part of the continuum of violence against women; 
  • That certain individuals and groups are exposed to hate speech in particularly intense way, and explicitly naming such groups, including women, minorities, such as migrant women and disabled women, and persons in certain public professions, such as journalists, politicians, researchers, public prosecutors, and woman human rights defenders, in the text should be considered; 
  • That online hate speech targets especially young women and further marginalizes their position in the society, and that age should be considered as one important intersectionality in tackling the phenomenon; 
  • That in addition to encouragement and support to national human rights institutions, equality bodies, civil society organisations and other stakeholders to implement the Recommendation, it is of crucial importance also to ensure adequate resources for their work, including women’s organisations, and that an addition in this regard is made to the Recommendation part itself, in addition to being discussed in the Appendix, and that women’s organisations are explicitly mentioned in the text; 
  • That parliaments, other elected bodies and political parties are in a crucial position to articulate a zero tolerance policy for hate speech in the whole society in addition to having a special responsibility not to engage in it themselves, that political parties should establish support mechanism for candidates, especially those who are young, women or minorities and who may encounter hate speech due to their candidacy, and that institutions such as national and local parliaments as well as employers should establish similar support mechanisms for those who hold public positions; and 
  • That in monitoring and reporting special attention is paid to disaggregating data based on gender as well as other intersectionalities, to fully take into consideration differences in form and intensity of hate speech encountered by different people, to facilitate planning of effective policy measures, and to ensure that all people have equal access to justice and remedies. 

The National Council of Women of Finland thanks for the opportunity to participate to the public consultation on the draft Recommendation. 

The National Council of Women of Finland 

Eva Biaudet Terhi Heinilä 
Chair Secretary General 

For more information 

Merja Kähkönen 
Advocacy Coordinator 
[email protected]  
+358 50 546 6688 

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