...[T]Institute for Human Rights and Business (IHRB)...[conducted a] case study...on the efforts of Safaricom...which devised its own code of conduct to prevent spreading hate-filled messages through its bulk SMS service.... In the run up to the 2013 elections, concerns of...[an] outbreak of violence and fears over the potential of SMS to simultaneously send messages that incite violence led Safaricom to take action...The findings, prepared in consultation with key stakeholders in Kenya and elsewhere, show that...rapid development of the ICT sector highlights the need for companies to understand the responsibilities associated with respecting freedom of expression around user-generated content as this may be central to their business model in the near future...[C]riminalising many forms of speech...results in the public expectation that many people will be prosecuted. This puts pressure on both the government and companies to act, which may result in legitimate views being restricted and citizens being unduly arrested. [also refers to Facebook & YouTube]