Select Committee on Foreign Affairs Minutes of Evidence


APPENDIX 6

Memorandum from ArmorGroup Services Limited

A CONTRACTOR'S VIEW

  This document is presented to the Foreign Affairs Committee of the House of Commons sitting to consider the Green Paper on Private Military Companies. It is a shortened version of the positional paper submitted by the company to the Foreign and Commonwealth Office in May 2002 and is directed at the two key issues of "licensing requirements for bona fide suppliers of services to the government of the United Kingdom" and of "restricting uncontrolled elements". This paper is offered as a brief to the Committee from an experienced provider of contract security services. It is not a definitive paper, nor does it represent any market view other than that held by ArmorGroup.

FOREWORD

  1.  The British Government has published a Green Paper outlining options for the control of private military companies which operate in territories outside the jurisdiction of the British Government, in response to a recommendation for such made by the Foreign Affairs Committee in its report on Sierra Leone (HC116-1).

  2.  The Green paper is a discussion document that encourages interested parties to engage in dialogue with or to make comment on pertinent matters to the Foreign and Commonwealth Office. The Green Paper discusses matters that are of interest to ArmorGroup and the Green Paper specifically makes mention of Defence Systems Limited ("DSL"), which is a subsidiary company of ArmorGroup.

  3.  ArmorGroup welcomes the publication of this Paper and accepts the inevitability of inaccuracy in its content at this early stage of discussion. ArmorGroup also agrees with the tone of the Green paper and sees it as a most suitable catalyst for all-party discussion on the subject matter.

ARMOR DEFINITIONS

  4.  Armor Holdings Inc: a public company registered in the United States of America, whose headquarters is in Jacksonville, Florida and whose stock is traded on the New York Stock Exchange under indicator "AH".

  5.  ArmorGroup: the security services division of Armor Holdings Inc. Two other divisions, Products and Mobile Security, produce less-than-lethal munitions, body armour and other law enforcement products and armoured executive saloons, police, cash in transit and military vehicles. ArmorGroup is headquartered in Buckingham Gate, London and co-ordinates the activities of its 40 regional offices, its 9,000 employees and its service lines, which include risk management, guard services, integrated security systems, investigation, landmine clearance and humanitarian support services.

  6.  Armor Holdings Limited: the top UK registered company in ArmorGroup, whose board of directors co-ordinates the activities of Armor Group subsidiary companies and operations.

  7.  Defence Systems Limited ("DSL"): a company registered in England and Wales with its principal office in Buckingham Gate, London. DSL is a wholly owned subsidiary of Armor Holdings Limited and is the contracted security services division of ArmorGroup. DSL was formed in 1981, was acquired by Armor Holdings Inc in 1997 and provides some of the services that are the subject of the Green Paper. DSL changed its name to "ArmorGroup Services Limited" on 16 January 2002 to bring it in line with Armor policy on marketing and integration.

  8.  For clarity this paper will refer to DSL where that company was engaged in a historic context, and to ArmorGroup in the present.

OTHER DEFINITIONS

  9.  Mercenaries: ArmorGroup is aware that a great many media reporters and academics earn their living and educational qualifications through their pursuit of "mercenary matters". Each student of the subject has a unique interpretation of the word. Intellectual institutions and international agencies have endeavoured to define the word before and now, but ArmorGroup accepts that the public perception of a mercenary is, and is likely to remain, "a soldier of unreliable ethics hired in foreign service to fight for significant reward". ArmorGroup will not contribute to a futile debate on the definition of the word mercenary. ArmorGroup does accept, for the purpose of this exercise, the legal definition given in Article 47 of the First Additional Protocol of 1997 to the Geneva Convention shown in clause five of the Green Paper. ArmorGroup does come into contact with mercenaries from time to time and has necessarily studied the character and motives of mercenaries, who have on occasion operated in the same theatre as ArmorGroup, albeit in a very different way and for different reasons.

EXECUTIVE SUMMARY

Overview

  10.  ArmorGroup is in favour of the regulation of exports of military services through a system of licensing contracts. It may be possible to tag this on to current legislation for regulating arms exports rather than developing new legislation.

  11.  ArmorGroup contends that the use of large-scale corporate entities to prosecute war is a phenomenon that made only a brief appearance in the mid-1990s through the now defunct Executive Outcomes. The prosecution of war for profit is now largely the preserve of individuals or small groups from poorly regulated national jurisdictions to other similar jurisdictions.

  12.  Despite the small scale of the illegitimate[13] trade in military combat services[14], ArmorGroup recognises the export and use of such services as morally reprehensible, and, as such, the elimination of this trade is the legitimate concern of government and public alike.

  13.  ArmorGroup does not accept that the private sector can field "combat troops", but its experience in the provision of support to the United Nations and UK Government agencies clearly demonstrates that the private sector can provide cost effective, efficient and accountable third line support to legitimate military operations. This support includes the provision of armed security guards for the protection of key persons and installations to free up the government's "combat troops".

  14.  Nevertheless, ArmorGroup believes that public Sector/private sector partnerships (PPP) can be successfully employed to deliver legitimate peace support operations, to enable and sustain legitimate security and law and order services, or to train or support legitimate armed forces. Such partnerships are to be encouraged as a means to build economically sustainable capacity to help prevent conflict and to encourage peace and stability world-wide.

  15.  However, ArmorGroup believes that so long as the distinction between legitimate and illegitimate security and military services remains unclear to either government or the public, this will not be possible. Stereotyping, sensationalisation, polemic and dogma unhealthily restrict the debate on private sector involvement in the delivery of public sector or multilateral security services. A focus on illegitimate "mercenary" activities has characterised the debate and hindered objective research and unblinkered analysis of the subject in recent times.

  16.  Therefore, ArmorGroup believes that in addition to controlling illegitimate trade in combat services, some form of regulation will help open up the debate on PPP in the provision of UK supported international peace support and security operations and dispel unfounded fears about the use of commercial services to support, or in certain fields replace[15] the use of public sector armed forces and security services. Most importantly, it should neutralise misinformed or dogmatic positions, ultimately allowing UK Government to make best use of contracted services in support of initiatives to create or ensure international peace and stability.



OPTIONS FOR REGULATION

  17.  ArmorGroup has considered the options for regulation broadly described in paragraph 7 to Annex C to the Green Paper and holds the following views on each.

  18.  ArmorGroup considers Option (a)—an outright ban on military activity abroad to be uneconomic in terms of British business, governmental and defence interests. It would also be morally unjustifiable given a nation's right to defend itself from aggression. Finally it would be ineffective where organisations are registered and exist, or where "mercenaries" reside outside UK jurisdication.

  19.  ArmorGroup considers Option (b)—a ban on recruitment for military activity abroad misses the point and will prove expensive to police for such a small-scale concern. Better the threat of an International Tribunal for breach of human rights in a conflict zone, or UK courts where British subjects are alleged to have committed an offence under English Law.

  20.  ArmorGroup considers Option (c)—a licensing regime for military services to be the most feasible and effective option. It should operate in a similar way to the current regime for licensing military exports (indeed certain military services can simply be added to current legislation). However, as a note of caution, ArmorGroup recognises that a poorly conceived[16] or inadequately administered regime could easily cripple speed of response, which is a key value of contracted security services.

  21.  ArmorGroup considers Option (d)—for registration and notification is too closely allied to Option (c) for separate consideration. Notification without licence will offer up another obstacle to UK companies engaged in a competitive, time sensitive bid for legitimate services. This gives the edge to foreign organisations, particularly from the US who can act on immediate response from the US government within the context of their licence.

  22.  ArmorGroup considers Option (e)—a general licence for PMCs/PSCs to be closely allied to Option (c) but less effective. An open licence might be no more relevant than a New York vehicle licence plate in Mogadishu. Why bother? It is the nature of the proposed activity allied to the identity of the region and context that is the issue, not the entity. It must be the context that is regulated, therefore, not the participant. AmorGroup would certainly see an open licence for services provided to designated organisations including the United Nations, European Commission, North Atlantic Treaty Organisation or UK Ministry of Defence and/or their respective subsidiary agencies.

  23.  ArmorGroup considers Option (f)—self-regulation: a voluntary code of conduct to be attractive in as much as a code may be easily followed, or not followed dependent upon the mood. Nevertheless, such a regime would fail to meet the needs of the government, and fail to placate critics of PMCs and mercenaries. This Option is therefore discounted.

  24.  Consideration has been given to licensing the individual participant rather than the company, which is not seen by ArmorGroup to be practical. It is the company that enters into a contract with the client and the company that must enforce standards of performance of its employees. The maintenance of a contingent of licensed and prospective employees is not feasible where the company is not certain what trades it will be requested to provide. In Yugoslavia ArmorGroup provided support staff from 24 countries under nearly 100 different job descriptions ranging from communications, through civil engineering to quality assurance, as well as drivers, mechanics and security staff. Individual licences simply could not be granted in the short time that they are required (days on occasion, rather than weeks) by the client to deploy.

LICENSING MECHANISMS

  25.  ArmorGroup does not view itself as a Private Military Company. ArmorGroup is a risk management company and there is nothing whatsoever illegitimate or "mercenary" (in the popular sense of the term) about its contracts, services or employees. ArmorGroup, and in particular its subsidiary ArmorGroup Services Limited (formerly Defence Systems Limited—DSL) is a provider of contracted risk management services; services that are limited in extent by the controls and guidelines imposed by itself or upon it by others.

  26.  In supporting an initiative to licence military services, ArmorGroup acknowledges the UK Government's interests, while recognising that no other option described will have any impact on the "mercenaries", yet every other option promises to waste time, energy and cost to no effect. The process of legal definition will itself consume the careers of lawyers and the government's budget, without satisfactory result. It is, after all not necessary to register a company to fund, recruit for and conduct a war.

  27.  ArmorGroup will leave it to the government to define categories of military service to be licensed, but is itself concerned with the fine, yet distinct line between legitimate commercial security and/or military support services, and the supply of uniformed and armed soldiers for the expressed purpose of engaging in combat to alter a prevailing political or military balance. It is, after all, the latter activity that gives rise to public expression of concern.

  28.  ArmorGroup recommends that licences for military activities be given in blanket form for services provided to and carried out under the auspices of the UN, EC or UK Government. Military services provided to US agencies should be free from restriction save for a requirement for the company to duly inform UK Government of its intention to provide certain services to a US government agency before they are delivered.

  29.  ArmorGroup considers that parties like the UN and EC will never be able to respond to an emergency if key service providers are delayed by a ponderous bureaucracy seeking to process a complex application. Any mechanism established to administer regulation must be the subject of published performance criteria so that a contractor may expect an answer to its application within, say, 10 working days. Commercial bidding is an expensive process, so it will be important for contractors to know that their time-sensitive applications will be dealt with in a prompt manner.

  30.  ArmorGroup considers that the introduction of a self-regulating code of conduct will prove relatively straightforward and a reasonable step towards regulation. Regulation will take time to prepare and the subsequent establishment of controls even slower.

  31.  Meanwhile, a voluntary code can clearly lay down national expectation in line with the nation's moral stance. British engagement in troubled regions is not the sole prerogative of the British government. The general population has its say with each citizen supporting the actions of humanitarian agencies and NGOs, military units and negotiators, as they will. The implications of a breach of a morally justifiable voluntary code will prove to be a major motivator for compliance by any company concerned for its reputation. Publicly broadcast breach will lead to isolation and loss of business for offenders. Illegitimate and/or immoral companies and individuals, for whom, and for whose clients the matter of reputation is of lesser concern than the promised financial return will continue their activities regardless of national regulation.

  32.  ArmorGroup offers its resources to the continuing debate on this matter and its relevant expertise to the detail of any draft regulation.

  33.  ArmorGroup long ago reached the conclusion that it needed to be clear about its business practices and its ethics and it subsequently put in place clear guidelines and controls to secure its reputation as a provider of quality, ethical services. ArmorGroup is confident that it is a properly managed and entirely compliant company offering premium services to respectable clients.

  34.  ArmorGroup clients, together with professional bodies and academic institutions associated with it, including the UK Government's Foreign and Commonwealth Office and Department for International Development, have reached the same conclusion and make best use of the opportunity presented by a quality contractor to supplement government resources.

  35.  ArmorGroup provides a range of services unparalleled in the security industry. On the one hand it provides contract security personnel and management and explosive ordnance disposal services to commercial enterprise (mostly in an international context). On the other hand it provides training, equipment and facility management to armed forces. Finally it has particular expertise in providing all these services to diplomatic missions, UN agencies and NGOs.

  36.  ArmorGroup is part of a truly pan-Atlantic commercial corporation which engages with the authorities of both the United States of America and the United Kingdom, but which maintains distinctly separate reporting lines to preserve the national interests of either state. Collectively, however, ArmorGroup is able to weigh up the relative merits of its role from the national perspective of each state and is aware that US practice is further developed when it comes to contracting out security and para-military activity than it is in the UK.

  37.  ArmorGroup has the global presence to observe private/commercial military activity first-hand in the territories in which it operates, yet ArmorGroup does not believe that there is a significant issue at the time of writing. Very little significant "mercenary" activity currently takes place and there appear to be very few actors on the corporate stage. The EO and Sandline burst of activity in the early 1990s appears to have subsided.

  38.  Thus, attention should now focus on future developments; the single most important issue appears to be the UK dilemma over the government's option to contract-out military or security functions to the private sector. ArmorGroup respects the dilemma posed and the safeguards that government offices must require in the public interest. It is ArmorGroup's experience that these functions can safely be contracted out to the private sector without loss of state control. Examples of success are myriad, while failures have been very few. One factor that remains consistent throughout is cost with the private sector offering significant reduction in cost over government services (the one caveat to this being the need for the private sector to be able to harness the expertise of former government servants. A significant reduction in the numbers of a standing army has a knock-on effect on the subsequent recruitment of basically trained former soldiers by the private sector. This may be less of a problem for states that have retained compulsory military service).

ENGAGEMENT

  39.  ArmorGroup welcomes the Green Paper and the initiative created by it whereby interested parties are invited to comment on the matter of the Foreign and Commonwealth Office and Foreign Affairs Committee.

  40.  The Voluntary Code of Conduct is supported by ArmorGroup, which by way of consultancy participated in the preparation of the code. Again it is noteworthy that ArmorGroup was not invited to comment on the code, or to participate in the exercise as ArmorGroup in its own right even though ArmorGroup is considered a major provider of the very services that are the subject of the code.

  41.  ArmorGroup is a supplier of services to UK Government agencies and to the United Nations and to many of its established agencies and temporary missions, yet there is still confusion within the offices of both organisations as to whether ArmorGroup is a company of suitable standing to engage with, let alone contract to. ArmorGroup is not viewed with ambiguity by the US Departments of State and Defense.

  42.  ArmorGroup has maintained a policy of positive engagement with interested parties since 1998 and decries any attempt by any party to misuse information on the company for any purpose, or to publish any erroneous material on the company, or to make any defamatory statement about or accusation of any kind against the company without having first given the company an opportunity to comment on the matter. In line with this policy, ArmorGroup routinely engages in dialogue with the following interested parties.

    (a)  National: the Foreign and Commonwealth Office (UK), the Foreign Policy Centre (UK), The Department for International Development (UK), The Department of State (USA) and the Department of Defense (USA).

    (b)  Supra national: The United Nations and its agencies, the European Union and its agencies.

    (c)  Human Rights: International Committee of the Red Cross, Human Rights Watch, International Alert and Amnesty International (restricted engagement).

    (d)  Others: Selected academia as individual researchers and as institutions such as Cranfield University at Shrivenham, objective media such as The Financial Times and professional journals including Janes Information Group Limited.

  ArmorGroup will only engage with parties taking an impartial approach to a given subject with a view to producing an objective conclusion. ArmorGroup will not engage with parties seeking to support a pre-conceived opinion or to publish subjective material. This necessarily rules out political parties, certain pressure groups and non-government organisations and irresponsible media.

EXPERIENCE AND MISCONCEPTIONS

  43.  ArmorGroup believes that core issues raised in the Green Paper for discussion cannot be successfully tackled in an atmosphere of uncertainty and mistrust. Much has been written of "mercenaries", "private military companies" ("PMCs"), and "Private security companies" and most of it is grossly exaggerated and inaccurate. It is the very stuff of fantasy and thrives on the mystery ascribed to it by uneducated commentary. The orderly archives of the company and its relatively low turnover of senior executives ensure that corporate memory is comprehensive and accurate. The company is bound by confidentiality clauses with its clients, but is able to disclose the type and location of its contracts and thus it is prepared to disclose to approved interested parties the precise nature of activity it has engaged in pertinent to the Green Paper. By operating a policy of disclosure the company promotes free debate on its business. The Green Paper attaches an Annex A that describes mercenary/PMC interventions in Africa since the 1950s, yet the list contains as many inaccuracies as are necessary to invalidate its worth for anything other than a broad illustration and introduction to the subject.

  44.  ArmorGroup therefore maintains its own Annex A describing business activity in Africa that it feels may be relevant to the debate, while excluding contracts that are clearly of a commercial security nature only. Where similar activity took place in other theatres outside Africa this too is included as relevant to the debate.

  45.  Annex A is submitted to the Foreign and Commonwealth Office for their record and to dispel the fears of officials who may for lack of information have applied the term "mercenary" to past DSL activity in Africa.

  46.  ArmorGroup takes exception to its inclusion in Annex A to the Green Paper under a column entitled "Mercenaries involved". ArmorGroup has no doubt those similarly legitimate businesses will feel equally annoyed at this unjustifiable labelling. A more appropriate heading might have been "Participants".

  47.  In addition to disclosure on its activity, ArmorGroup can demonstrate a responsible attitude towards its business through an explanation of key corporate functions. These may not address the issue of licensing of PMCs et al, but they do help explain why it is that ArmorGroup has been able to steer clear of unethical and/or immoral activity, or any activity that is contrary to the interests of the governments of the United Kingdom and United States or to international human rights.

PERSONNEL AND RECRUITMENT

  48.  ArmorGroup operates a quality management system that features policies on employment and, in particular, on recruitment. This latter policy is approved by the Board of Directors of Armor Holdings limited and is managed by the Vice President, Human Resources and Administration in conjunction with a Human Resource Manager. The Vice President, Human Resources and Administration is also the Company Secretary of all UK registered group subsidiaries and sits on the executive management committee of ArmorGroup.

  49.  This degree of participation in ArmorGroup business by the Human Resources function reflects the value placed by the board on the quality of manpower employed by the company. The Human Resource function abides by the Recruitment Policy, which specifically prohibits the recruitment of persons suspected of mercenary activity and other such persons with a colourful past, whose demonstrated personal conduct and morals displayed abroad may be considered unreliable and whose assignment to a client may prove an embarrassment to that client.

  50.  Candidates are vetted to determine their reliability and ethical orientation and suitable employees then fully documented. The Company traditionally employees former servicemen, or skilled tradesmen and professionals whose worth has been proven in hazardous circumstances through services with humanitarian organisations. The company does not expose the unexposed to hazardous conditions and the fallout rate of employees encountering conditions that they cannot endure is minimal. The company also briefs new employees on the reality of the situation to which the employee is to be assigned and does not apply an unrealistic "gloss" to the conditions, nor endeavour to "sell" the job.

  51.  ArmorGroup employees are recruited from parts of the armed forces and government agencies that have required them to be signatories to the Official Secrets Act. This degree of confidentiality is owed to the government and is respected by the company, which positively encourages compliance. ArmorGroup does not knowingly employ actual or would-be authors, whose acts or intentions mark them down as unreliable.

  52.  ArmorGroup is a popular employer, whose employees tend to remain with it year after year. It is considered to be a reliable payer, to be meticulous in the insurance arranged for employees and to be supportive of employees in difficult times. The effort put into employee conditions by the company pays dividends in the recruitment of and the subsequent performance of quality employees.

  53.  The conclusion reached by a number of ill-informed "experts" that ArmorGroup is a private military company by virtue of the quantity of former servicemen employed on uniformed security tasks is countered by the company; which cites the NGOs of countries (Scandinavia for example) that continue to require their citizens to undergo compulsory military service, as having a far greater proportion of former military amongst their employees, yet which are not deemed to be military companies. Indeed, the success of many NGO operations today may be due to the mix of employee background including greater numbers of commercial and former military managers to supplement logisticians.

PERSONAL CODES OF CONDUCT

  54.  Employees of ArmorGroup are bound by strict conditions to ensure that they are aware of their responsibilities and aware of the consequences if conditions are breached. The following measures are taken to ensure the standards of employee performance:

  (a)  Service Agreement: issued to all employees, this contract of employment defines the standard of behaviour expected of employees and the disciplinary measures that may be applied in the event of non-compliance.

  (b)  Staff Handbook: issued to all employees, lays down rules and regulations governing the day-to-day activity of employees at work.

  (c)  Code of Conduct: issued to all employees serving outside the UK and US, lays down in ten pages strict conditions for compliance with the laws of the host nation, for respect of its culture for the issue and use of firearms, and for the prohibition of any offensive action. The company commits to assisting the host nation investigate breach of law and the company commits to assisting international war crimes investigators.

  (d)  Client Codes: issued to employees engaged by the company in support of United Nations peacekeeping operations, or by UK Government departments. These codes and regulations are comprehensive and any breach of them by an employee results in disciplinary proceedings monitored by the client. Serious breaches may give way to investigation by the authorities of host nations and such investigation shall be conducted in accordance with the degree of protection afforded the employee by the client's memorandum of association or diplomatic status.

  (e)  Records: of employees, including date of birth, National Insurance number, passport number and address are maintained and can be used to support investigation into subsequent allegation of breach of law by employees whilst in the service of the company.

  Conditions of service are strictly applied. Offenders are warned of the consequences of repeated breach and/or are discharged in accordance with their terms of employment. The company does not hesitate to enforce carefully considered conditions of service to protect its own reputation or that of its clients. The company is also committed to co-operation with international criminal investigators.

CORPORATE CODES OF CONDUCT

  55.  The company further reinforces its moral position by compliance with a number of published or self-expressed codes of conduct.

  (a)  Code of Conduct of the International Red Cross and Red Crescent: ArmorGroup voluntarily subscribes to this code of conduct for humanitarian operators to demonstrate its support for these principles of field operation. While the company is not an NGO, and cannot therefore technically register its support, the matter has been discussed with ICRC and its endorsement approved in principle.

  (b)  Foreign and Corrupt Practices Act: compliance is required of the parent company by the US government and all ArmorGroup executives likely to be exposed to business decisions governed by the Act are required to sign up to the Act.

  (c)  Anti-terrorism, Crime and Security Act 2001: reinforces the above and creates an offence where inducements are offered in any territory regardless of whether it is within UK jurisdiction.

  (d)  Voluntary Principles on Security and Human Rights: proposed by the Department of State and seconded by the Foreign & Commonwealth Office this is a code that was contributed to and which has been supported by ArmorGroup every bit as much as it is by its designated overseers who comprise a number of the company's major clients in the oil and gas extraction sector.

  (e)  United Nations Mine Action Procedures: the company helped compile these in 1995 and has been an exponent of them and of the UN's pre-eminent position in this field of activity ever since. The company's excellent safety record has justified compliance with regulations to the letter.

CORPORATE ACCOUNTABILITY

  56.  ArmorGroup has evolved through several marked stages since its establishment in 1981, from private ownership, through UK corporate ownership, through ownership by management and into public ownership with a US quoted corporation (www.armorholdings.com). Its long-serving executives have been given the opportunity to closely observe the effect of different management structures and are pleased to note an increase in accountability with public ownership. Thus, irrespective of new legislation brought in to control the activities of mercenaries/PMCs, it can safely be said that the following aspects of corporate life in a legitimate contractor such as ArmorGroup will continue to provide the strictest degree of accountability as is presently the case.

  (a)  Board of Directors: of Armor Holdings Inc. and Armor Holdings Limited are principally drawn from American and British executives who have no military background. Indeed, the majority are professionally qualified lawyers or accountants. Directors are now charged by law to be personally accountable for all manner of matters including health and safety.

  (b)  Management: of ArmorGroup is vested in an Executive Committee comprising core corporate executives and regional management numbering twenty, whose nationalities presently include American, British, Russian and New Zealand and whose past service includes senior appointments in the military, diplomatic and security services of those countries as well as with international humanitarian agencies and NGOs. Such diversity has its strength in that any deviation from corporate ethics on the part of one or more would lead to rapid censure by the others.

  (c)  Shareholders: of Armor Holdings Inc. take a closer interest in their investment of choice and will not tolerate unethical activity. Armor Holdings stock presently receives many recommendations from market analysts as an investment of choice and it is a choice that attracts serious corporate investment.

  (d)  Auditors: always one of the big five and presently PricewaterhouseCoopers. A complex international structure spread across a number of tax regimes and using a multitude of foreign currencies attracts a more diligent approach to audit than lesser straightforward operations. ArmorGroup Services Limited in particular has changed ownership three times in the past ten years, attracting detailed due diligence by potential owners and their lawyers, and necessitating the close scrutiny of every aspect of the company and its activities.

  (e)  Security Exchange Commission: the governing body of quoted US corporations, adds another layer of control by requiring quarterly reporting in compliance with strict conditions of trading protocol.

  (f)  National legislation: in the US and UK, where the majority of Armor subsidiaries are registered, requires proper disclosure of the details of stock holding, directors and officers and of annual reports and accounts producing another element of transparency. This is repeated overseas where Armor subsidiary offices are required to comply with host nation legislation. The company is also registered to comply with UK legislation governing Data Protection and complies with laws on Employment, Health and Safety.

  (g)  National security: ArmorGroup has confidential contracts with sovereign governments that require senior company executives to be given security clearance to high levels. Possession of security classification is in itself a measure of the reputation of management.

  (h)  Legal Counsel: is maintained by Armor Holdings Inc. in-house, backed by firms of lawyers of high repute in both UK and US jurisdictions. Thus the company is properly represented and properly advised.

  (i)  Tax: is paid in the UK and US and in all countries where subsidiaries are registered to comply with host nation regulation. The company requires its tax liabilities to be transparent.

  (j)  Insurers: are selected for their reliability and market standing. The company places its insurance requirements through the world's second largest broker and with insurers having the expertise to properly rate the company's risk and the capacity to withstand the liability. Armor Holdings maintains high levels of insurance, the liability component of which is placed with the world's largest carrier. Armor Holdings adopts a policy of complete disclosure to its insurers, and has retained its present broker for the past ten years.

  (k)  Clients: who exert the single most powerful influence over the company's activity. "Reputation" has become the key watchword in business and the need to protect a reputation is the prime motivator towards legitimate and ethical performance and service delivery. Loss of reputation is, in ArmorGroup's business, always followed by a significant loss of business.

BUSINESS APPROACH

  57.  ArmorGroup, as a public company, is required by its shareholders to bid for as much profitable business as can be commercially handled and as can be managed to the high standards adopted by the company without damage to reputation.

  58.  ArmorGroup is usually required to qualify to bid for the majority of its business, on the strength of its practical experience, its financial and resource base and its excellent references going back several years. It then bids in open competition for corporate and government contracts. The majority of clients adopt strict and transparent bid assessment processes. Where ArmorGroup wins a contract, that contract takes the form of a written agreement, a copy of which must be made available to company auditors.

  59.  ArmorGroup does not accept all work offered to it. ArmorGroup has turned down requests to provide pipeline security in a country where there was perceived to be a conflict with human rights; to transport gold and diamonds where the matter of ownership was unclear; to investigate individuals where to do so would break the law; and to supply non-lethal equipment to governments, where there was a chance that they may be used to suppress democratic movements.

  60.  Competitive bidding ensures that costs, including profit, are controlled by market forces. Salaries of individual contractors are similarly competitive. Arrangements for travel and accommodation are similarly modest. In addition to low start-up and running costs, those for winding up the contract are most advantageous to the client who will issue notice under the terms of the contract and incur no further liability. Employees will be laid off after due notice and repatriated. There are no complex pension arrangements to wind up, nor expensive redundancies. Employee salary rates will have included a provision for self-administered pension contributions and an attraction to long-serving contract staff employed in remote regions may be the possibility of exemption from UK income tax if they qualify for that status.

PRINCIPLES OF OPERATION

  61.  ArmorGroup has laid down a set of operating principles to protect itself from reputational issues and to comfort full-time and contract employees that they will not be asked to undertake any activity, nor be associated with the same, that may cause them moral or ethical dilemmas. These principles are laid out below:

  62.  The company and its employees may not undertake any activity that would be formally censured by the Foreign and Commonwealth Office, or US Department of State.

  63.  The company and its employees may not plan or actually conduct or in any way participate in offensive military operations.

  64.  The company and its employees may not seek to, nor actually alter the prevailing political or military balance in a host nation (except in so much as the presence of sound commercial security may inevitably stabilise a geographical region or economy).

  65.  The company may not supply lethal equipment, nor its employees bear arms except for those carried for personal defence with the agreement of and possession of a licence from the host government.

  66.  The company will not unnecessarily expose employees to danger and the company promotes its Health & Safety policy and provides safety garments and basic healthcare for all employees, local and expatriate.

  67.  The company will comply with the direction of shareholders that the business is essentially one dedicated to defensive measures (vehicle and body armour and security services) and a less-than-lethal approach (less-than-lethal munitions sales and protective security).

  68.  The company will not engage in any activity that falls outside its insurance umbrella.

  69.  The company will comply with host nation laws and establish transparency by registering subsidiary companies with local participation in management and by paying local taxes.

CONTROVERSIAL ACTIVITY

  70.  ArmorGroup does provide services that are the subject of this Green Paper, but only the ill-informed would find sufficient fault with these services as to consider them to be controversial. Each of these contracts is conducted in accordance with the company's principles and codes of conduct, is known to the British Embassy or High Commission in the territory concerned and is conducted with the expressed permission of the host nation.

  Such activities include:

  (a)  The training of military personnel of the defence forces of countries committed to non-aggression and in non-lethal activities including parachuting, navigation and communications.

  (b)  The training of para-military personnel in tactics and weapon handling, where the force concerned will not be employed in offensive action (eg Game Wardens).

  (c)  The training of law enforcement officers and of tactical intervention units for ministries of justice and police forces in all disciplines including counter hi-jack tactics and firearms handling.

  (d)  The provision of civilian support personnel to peacekeeping forces, including trades and a degree of involvement described in the UNPROFOR exercise described below.

  (e)  The provision of security management, or of armed, uniformed and trained local security guards to protect sovereign embassies and legitimate commercial activity in high risk areas, subject to strict compliance with orders for opening fire and the carriage of defensive weaponry (eg shotguns, bolt action rifles and handguns).

  (f)  The clearance of landmines and unexploded ordnance as part of a humanitarian or post-conflict reconstruction programme, but not in support of military planning or manoeuvre.

  71.  It has been suggested that the efforts of "PMCs" have no lasting impact. This is not ArmorGroup's experience. ArmorGroup training of local landmine clearance teams in Bosnia Herzegovina and Mozambique on behalf of international donors has left a sustainable capability not dependent upon complex technologies.

  72.  DSL's training of commercial protection forces in Mozambique in the late 1980s, in conditions of civil war, facilitated the reconstruction of a country-wide economy, thereby contributing to the peace process. These security forces secured projects of utmost economic importance around the country, reassured international investors, provided pockets of stability that allowed the establishment of schools and clinics and the return of refugees, secured lines of communication and contributed to the process of peace and reconciliation for this newest member of the British Commonwealth.

THE UNPROFOR EXPERIMENT

  73.  In considering where the limit of involvement of contract personnel provided by a commercial company might be, it is worth considering the UNPROFOR experiment conducted by the United Nations in circumstances of dire need. New by British standards, the exercise was considered routine by US competitors, the like of DynCorp, which competed with DSL and provided a similar service to UNPROFOR.

  74.  In 1992 the United Nations sought to establish a significant peacekeeping presence in the former Yugoslavia and, finding that it did not have the ability to field sufficient support staff from its own resources, the United Nations contracted five companies to identify, employ and administer (ultimately 2,000) skilled international civilian staff. The need for so many international staff arose from the complexity of the conflict zone, where the prospect of deploying locally recruited staff across the many front lines was considered to be too dangerous.

  75.  DSL was asked to bid to provide support staff and subsequently maintained for UNPROFOR a strength of 425 international staff from 24 nations, including planning officers, quality assurance, architects, civil, mechanical and electrical engineers, plant operators, drivers, communicators, computer programmers and network installers, facility and camp managers in addition to traditional DSL personnel including security officers assigned to crime prevention, crime detection, close protection and border security duties. This contact continued for four years till 1996, when NATO forces assumed primary responsibility from the UN.

  76.  As the mission grew, so did the diversity of tradesman supplied by DSL. Of particular relevance to the Green Paper is the provision of drivers and mechanics for armoured personnel carriers ("APCs"). The deployment of peacekeepers from Asia and Africa, without their own indigenous armour, required UNPROFOR to acquire surplus armoured (OT64) vehicles from the Czech Republic. These infantry battalions also lacked the expertise to maintain and operate the APCs, so UNPROFOR instructed DSL to supply APC mechanics and drivers, which it did from the Czech Republic. Thus DSL became engaged in operational peacekeeping duties with DSL drivers in armoured vehicles, maintained and fuelled by DSL support teams, out of bases constructed and maintained by DSL and co-ordinated by DSL planners in Zagreb. Many of the DSL employees were recruited from Scandinavia where, typically, a volunteer would complete a six-month uniformed military peacekeeping tour, then return to the region as a contractor in his professional capacity with DSL. It was a case of employing fully qualified and experienced personnel to fill gaps created by the dearth of regular UN civil and military personnel.

  77.  DSL employees were, during the four-year exercise, deployed throughout the region in conditions of extreme danger and discomfort. They wore civilian pattern UN uniform with UN badges and identification papers and were fully integrated into the UNPROFOR organisation. They did not serve six-month tours as regular soldiers did; instead serving up to four years and becoming the experts on local situations, safety and security. Much publicity was given to the more glamorous (not that there was much glamour in Bosnia Herzegovina) blue helmets, but very little to the support staff, who prepared their barracks, established theatre communications and delivered fuel, rations and ammunition into bases (sometimes under small-arms and artillery fire). UN medals were awarded to every participant in the mission, with the exception of contract staff. Certain nations (notably Australia) have now recognised the contribution of these men and women with national awards for service with UNPROFOR. DSL found that its employees, whose average age was some ten years greater than for regular troops, were motivated by the desire to make a difference in this tragedy and that their levels of dedication and of personal and team performance equalled or exceeded those of regular UN employees and peacekeepers.

  78.  The United Nations considers the exercise to have been a complete success. Skilled international staff could be rapidly deployed, effectively administered and their performance and compliance with UN practice and procedure adequately controlled. These contractors merged seamlessly with the UN regular operation at every level and were necessarily given access to classified information. When it came to winding up the mission these contacted employees were given one month's notice and laid off without further liability for benefits or pension.

  79.  DSL determined, from its experience, that it is prepared to provide qualified close protection officers, uniformed security guards, police officers and combat support elements (for transport, maintenance communications and engineering roles) for UN-sponsored peacekeeping missions, but draws the line at "combat troops" and "vehicle turret crew".

  80.  By way of precedent, ArmorGroup has now provided security and logistic support to UN missions in Yugoslavia (UNPROFOR), Mozambique (ONUMOZ), Angola (UNAVEM) and the Democratic Republic of Congo (MONUC). ArmorGroup closely followed NATO intervention in Kosovo to provide emergency landmine and unexploded ordnance clearance on behalf of the UK Government and has provided similar services to UN and EC agencies across the Balkans, Africa and the Middle East.

CONCLUSION

  81.  ArmorGroup long ago reached the conclusion that it needed to be clear about its business practices and its ethics and it subsequently put in place clear guidelines and controls to secure its reputation as a provider of quality, ethical services. ArmorGroup is confident that it is a properly managed and entirely compliant company offering premium services to respectable clients since 1981.

  82.  ArmorGroup clients, together with professional bodies and academic institutions associated with it, including the UK Government's Foreign and Commonwealth Office and Department for International Development, have reached the same conclusion and make best use of the opportunity presented by a quality contractor to supplement government resources.

  83.  ArmorGroup does not view itself as a Private Military Company. ArmorGroup is a risk management company and there is nothing whatsoever illegitimate or "mercenary" (in the popular sense of the term) about its contracts, services or employees. ArmorGroup, and in particular its subsidiary ArmorGroup Services Limited (formerly Defence Systems Limited—DSL) is a provider of contracted risk management services: services that are limited in extent by the controls and guidelines imposed by itself or upon it by others.

  84.  ArmorGroup provides a range of services unparalleled in the security industry. On the one hand it provides contract security personnel and management and explosive ordance disposal services to commercial enterprise (mostly in an international context). On the other hand it provides training, equipment and facility management to armed forces as do may US logistics companies and one or two major players in the UK. Finally it has particular expertise in providing all these services to diplomatic missions, UN agencies, NGOs and peacekeeping missions.

  85.  ArmorGroup has determined that it will not act unilaterally in conflict zones. ArmorGroup will only operate in conditions of armed conflict under mandate from and with active participation of "allied" governments, who shall provide diplomatic support, operating parameters and first line medical support including facilities for air evacuation.

  86.  ArmorGroup is part of a truly pan-Atlantic commercial corporation which engages with the authorities of both the United States of America and the United Kingdom, but which maintains distinctly separate reporting lines to preserve the national interests of either state. Collectively, however, ArmorGroup is able to weigh up the relative merits of its role from the national perspective of each state and is aware that US practice is further developed when it comes to contracting out security and para-military activity than it is in the UK.

  87.  ArmorGroup has the global presence to observe private/commercial military activity first-hand in the territories in which it operates, yet ArmorGroup does not believe that there is a significant issue at the time of writing. Very little significant "mercenary" activity currently takes place and there appear to be very few actors on the corporate stage. The EO and Sandline burst of activity in the early 1990s appears to have subsided.

  88.  Thus, attention should now focus on future developments and the single most important issue appears to be the UK dilemma over the government's option to contract-out military or security functions to the private sector. ArmorGroup respects the dilemma posed and the safeguards that government offices must require in the public interest. It is ArmorGroup's experience that these functions can safely be contracted to the private sector without loss of state control. Examples of success are myriad, while failures have been very few. One factor that remains consistent throughout is cost with the private sector offering significant reduction in cost over government services (the one caveat to this being the need for the private sector to be able to harness the expertise of former government servants. A significant reduction in the numbers of a standing army has a knock-on effect on the subsequent recruitment of basically trained former soldiers by the private sector. This may be less of a problem for states that have retained compulsory military service).

RECOMMENDATIONS ON PROCESS

  89.  ArmorGroup recommends to the Foreign and Commonwealth Office that it consider the following matters in connection with the general debate on PMCs and their regulation.

  90.  Engage with interested parties, including those that are the subject of the Green Paper to ensure that as many as possible of the facts necessary for deliberation of key issues are verified as being accurate.

  91.  Avoid expending valuable time and resource endeavouring to define terms the like of "mercenary" or "PMC" when a thousand journalists and ten thousand academics will continue to do it for themselves. Press articles published in the wake of the Green Paper only serve to support this view as self-styled experts leap to their feet to deliver more ill informed comment.

  92.  Advance core and related issues, including:

    Restriction on the proliferation of small arms, the major instruments of terror and death in Africa from countries like Bulgaria and the Ukraine.

    Restriction on the scale of combat vehicles and aircraft from those same countries into Africa. As the pan-African song goes "there are more tanks than food in the Ogaden; looks like Russia got it wrong again".

  93.  Centrally collate information on private individuals and companies offering "controversial" or "quasi-military" services and equipment, much in the same way as law enforcement agencies now share intelligence, to ensure that relevant departments have timely access to relevant data.

  94.  Investigate (with the Department of Trade and Industry) the activities of British individuals or companies offering "controversial" or "quasi-military" services and equipment wherever and whenever they are reported to be operating in territories outside UK jurisdiction and where the registration of companies and accounts is not open to public inspection.

  95.  Accept that British subjects will continue to volunteer for military service in search of excitement and gain. Some will find their place in legitimate activities, while the wilder "Walter-Mitty" will find himself in circumstances like those with the Croatian Army from 1991 to 1994-engaged in an ever dirtier war and likely to be investigated by the International Criminal Tribunal for the Former Yugoslavia.

  96.  Accept that its citizens may wish to offer security to people in distress as much as they might food or shelter. Lack of security is acknowledged to be a root cause of poverty or starvation and the right to contribute to a degree of security through the short-term sponsorship of private security may be preferable to long-term expense in vulnerable aid such as food, medicine and shelter.

  97.  Support the establishment of a permanent International Criminal Tribunal, for this is the proper forum for the trial of alleged war criminals. Nothing is more likely to curb the illicit activity of "mercenaries" than the very real prospect of an international trial if they come close to breach of human rights.

  98.  Acknowledge the principle that when time dictates that "something must be done" in rapid onset complex emergencies (eg Rwanda, Sierra Leone and Bosnia Herzegovina), then a rapid and professional private response must not be hindered by academic debate, nor cumbersome bureaucracy. Governments and self-styled experts produced a thousand reasons why not to take firm action in Bosnia Herzegovina when there was only one good reason to go in—to relieve grievous human suffering.

  99.  Act positively to ensure that the valuable "enabling" capability provided to the UK Government, commercial investors, humanitarian and peacekeeping efforts by contractors in times of dire need is not unnecessarily restricted.

RECOMMENDATIONS ON REGULATION

  100.  ArmorGroup is in favour of regulation through licensing contracts.

  101.  ArmorGroup contends that the use of large-scale corporate entities to prosecute war is a phenomenon that made only a brief appearance in the mid-1990s through the now defunct Executive Outcomes. The prosecution of war for profit is now largely the preserve of individuals or small groups from poorly regulated national jurisdictions to other similar jurisdictions.

  102.  Despite the small scale of the illegitimate[17] trade in military combat services[18]. ArmorGroup recognises the export and use of such services as morally reprehensible, and, as such, the elimination of this trade is the legitimate concern of government and public alike.

  103.  ArmorGroup does not accept that the private sector can field combat troops, but its experience in the provision of support to the United Nations and UK Government agencies clearly demonstrates that the private sector can provide cost effective, efficient and accountable third line support to military operations.

  104.  Nevertheless, ArmorGroup believes that public sector/private sector partnerships (PPP) can be successfully employed to deliver legitimate peace support operations, to enable and sustain legitimate security and law and order services, or to train or support legitimate armed forces. Such partnerships are to be encouraged as a means to build economically sustainable capacity to help prevent conflict and to encourage peace and stability world-wide.

  105.  However, ArmorGroup believes that so long as the distinction between legitimate security and illegitimate military services remains unclear to either government or the public, this will not be possible. Stereotyping, sensationalisation, polemic and dogma unhealthily restrict the debate on private sector involvement in the delivery of public sector or multilateral security services. This focus on illegitimate "mercenary" activities has characterised the debate and hindered objective research and unblinkered analysis of the subject in recent times.

  106.  Therefore, ArmorGroup believes that in addition to controlling illegitimate trade in combat services, some form of regulation will help open up the debate on PPP in the provision of UK-supported international peace support and security operations. It will also dispel unfounded fears about the use of commercial services to support, or in certain fields replace[19] the use of public sector armed forces and security services. Most importantly, it should neutralise misinformed or dogmatic positions, ultimately allowing UK Government to make best use of contracted services in support of initiatives to create or ensure international peace and stability.

  107.  ArmorGroup has considered the options for regulation broadly described in paragraph seven to Annex C to the Green Paper and holds the following views on each.

  108.  ArmorGroup considers Option (a)—an outright ban on military activity abroad to be uneconomic in terms of British business, governmental and defence interests. It would also be morally unjustifiable given the company's position in paragraph 63 above. Finally it would be ineffective where organisations are registered and exist, or where "mercenaries" reside outside the UK jurisdiction.

  109.  ArmorGroup considers Option (b)—a ban on recruitment for military activity abroad misses the point and will prove expensive to police for such a small-scale concern. Better the threat of an International Tribunal for breach of human rights in a conflict zone, or UK courts where British subjects are alleged to have committed an offence under English Law.

  110.  ArmorGroup considers Option (c)—a licensing regime for military services to be the most feasible and effective option. It should operate in a similar way to the current regime for licensing military exports (indeed certain military services can simply be added to current legislation). However, as a note of caution, ArmorGroup recognises that a poorly conceived[20] or inadequately administered regime could easily cripple speed of response, which is a key value of contracted security services.

  111.  ArmorGroup considers Option (d)—for registration and notification is supportable, but too closely allied to Option (c) for separate consideration. Notification without licence will offer up another obstacle to UK companies engaged in a competitive, time-sensitive bid for legitimate services. This gives the edge to foreign organisations, particularly from the US who can act on immediate response from the US government within the context of their licence.

  112.  ArmorGroup considers Option (e)—a general licence for PMCs/PSCs to be closely allied to Option (c) but less effective. An open licence might be no more relevant than a New York vehicle licence plate in Mogadishu. Why bother? It is the nature of the proposed activity allied to the identity of the region and context that is the issue, not the entity. It must be the context that is regulated, therefore, not the participant. ArmorGroup would certainly see an open licence for services provided to designated organisations including the United Nations, European Commission, North Atlantic Treaty Organisation or UK Ministry of Defence and/or their respective subsidiary agencies.

  113.  ArmorGroup considers Option (f)—self-regulation: a voluntary code of conduct to be attractive in as much as a code may be easily followed, or not followed dependent upon the mood. Nevertheless, such a regime would fail to meet the needs of the government, and fail to placate critics of PMCs and mercenaries. This Option is therefore discounted.

OPTION 7 (C)

  114.  In supporting an initiative to licence military services, ArmorGroup acknowledges the UK Government's interests, while recognising that no other option described will have any impact on the "mercenaries", yet every other option promises to waste time, energy and cost to no effect. The process of legal definition will itself consume the careers of lawyers and the government's budget without satisfactory result.

  115.  ArmorGroup will leave it to the government to define categories of military service to be licensed, but is itself concerned with the fine, yet distinct line between legitimate commercial security and/or military support services, and the supply of uniformed and armed soldiers for the expressed purpose of engaging in combat to alter a prevailing political or military balance. It is, after all, the latter activity that gives rise to public expression of concern.

  116.  ArmorGroup recommends that licences for military activities be given in blanket form for services provided to and carried out under the auspices of the UN, EC or UK Government. Military services provided to US agencies should be free from restriction save for a requirement for the company to duly inform UK Government of its intention to provide certain services to a US Government agency before they are delivered.

  117.  ArmorGroup considers that parties like the UN and EC will never be able to respond to an emergency if key service providers are delayed by a ponderous bureaucracy seeking to process a complex application. Any mechanism established to administer regulation must be the subject of published performance criteria so that a PMC may expect an answer to its application within, say, 10 working days. Commercial bidding is an expensive process, so it will be important for PMCs to know that their applications will be dealt with in a prompt manner.

  118.  ArmorGroup considers that the introduction of a self-regulating code of conduct will prove relatively straightforward and a reasonable step towards regulation. Regulation will take time to prepare and the subsequent establishment of controls even slower.

  119.  Meanwhile, a voluntary code can clearly lay down national expectation in line with the nation's moral stance. British engagement in troubled regions is not the sole prerogative of the British government. The general population has its say with each citizen supporting the actions of humanitarian agencies and NGOs, military units and negotiators, as they will. The implications of a breach of a morally justifiable voluntary code will prove to be a major motivator for compliance by any company concerned for its reputation. Publicly broadcast breach will lead to isolation and loss of business for offenders. Illegitimate and/or immoral companies and individuals, for whom, and for whose clients the matter of reputation is of lesser concern than the promised financial return will continue their activities regardless of national regulation.

  120.  ArmorGroup offers its resources to the continuing debate on this matter and its relevant expertise to the detail of any draft regulation.

  121.  Moving on from the "mercenary" debate, ArmorGroup would like to see academic and Government dialogue concentrate on the number of lives that can be saved through prompt and decisive government action and to the development of "enabling" capability to support that action. Indeed in this context there is often no validity in the cry "lack of resources" in responding to crises, as the common limiting factor is "cost".

ArmorGroup Services Ltd

17 June 2002



13   As against those which are provided within national laws (of both the supplying nation and nations in which the intervention takes place) and international humanitarian law (the Geneva conventions and subsequent protocols) Back

14   Since the heydays of Sandline and Executive Outcomes in the early to mid 1990s, most mercenary activities have been carried out by small companies or individuals, operating from poorly regulated jurisdictions. However, the illegitimate trade in military hardware and non-combat services is highly significant. Back

15   In the training of allied nations troop contributions to UN or coalition forces or the provision of logistics, communications and rear area security, for example. Back

16   In particular, ArmorGroup suggests that contracts with certain pre-approved clients be made exempt from such licensing. These could include members of the UK's main strategic economic and military alliances such as NATO, the EU and OECD. It should also cover services delivered on behalf of official UK government or United Nations agencies. Back

17   As against those which are provided within national laws (of both the supplying nation and nations in which the intervention takes place) and international humanitarian law (the Geneva conventions and subsequent protocols). Back

18   Since the heydays of Sandline and Executive Outcomes in the early to mid 1990s, most traditional mercenary activities have been carried out by small scale or individual groups, operating from pariah nations. However, the illegitimate trade in military hardware and non-combat services is highly significant. Back

19   In the training of allied nations troop contributions to UN or coalition forces or the provision of logistics, communications and rear area security, for example. Back

20   In particular, ArmorGroup suggests that contracts with certain pre-approved clients be made exempt from such licensing. These could include members of the UK's main strategic economic and military alliances such as NATO, the EU and OECD. It should also cover services delivered on behalf of official UK government or United Nations agencies. Back


 
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