Memorandum submitted by Global Witness
HIGHLIGHTING THREATS TO HUMAN RIGHTS BY UK
COMPANIES OPERATING IN CONFLICT OR HIGH RISK AREAS
1. Global Witness appreciates the opportunity
to make this submission to the Joint Committee on Human Rights.
2. We identify the circumstances that need to
be taken into account by UK-based companies that operate in conflict
or high risk areas where there is an abundance of natural resources.
The UK Government has failed to take action to prevent or deter
abuses by UK companies operating in these areas, in particular
in the Democratic Republic of Congo (DRC). As a result, the UK
Government should play a greater role in regulating and advising
these companies in order to minimise human rights violations and
other abuses. Drawing upon Global Witness' work, we highlight
five specific instances where current UK Government action has
been inadequate. A recommendations section and annex with five
case studies are also included.
3. Global Witness is an NGO that exposes
the corrupt exploitation of natural resources and international
trade systems. We obtain evidence which we use to drive campaigns
that end impunity, resource-linked conflict, and human rights
and environmental abuses. Global Witness was nominated for the
2003 Nobel Peace Prize for its work on conflict diamonds.
We work predominantly in conflict-affected countries, emerging
markets and in countries with totalitarian regimes and low levels
of transparency.
4. As articulated in Professor John Ruggie's
report "Protect, Respect and Remedy: a Framework for Business
and Human Rights" home states (i.e. countries where
companies are registered) need to play a greater role in minimizing
human rights abuses caused or contributed to by their companies
operat ing in conflict affected areas.
5. In 2007, Global Witness seconded a member
of staff to work with Professor John Ruggie and his team. As part
of this secondment, a policy paper and number of recommendations
were submitted pertaining to the regulative, advisory and facilitative
role that home states can play in minimizing human rights abuses
caused by their companies operating in conflict areas.
6. Global Witness believes that greater
regulatory and policy measures that have an extra-territorial
effect are required which will apply to UK-registered companies
operating in conflict or high risk areas.
7. We take the position that human rights
are non-negotiable regardless of the economic climate. We strongly
believe that the UK government should not loosen its ethical requirements
of UK business operating in conflict or high risk areas in order
to reduce the impact of the global recession.
8. Global Witness restates Professor's Ruggie's
position that companies have a responsibility to do "no harm"
when it comes to human rights. We also believe that when corporate
related human rights abuses occur, often as a result of core operations,
that these cannot be off-set by other philanthropic behaviour
such as building clinics or schools.
9. We support a number of submissions made
by other NGOs, including CORE's proposal for the establishment
of a new commission with sanctioning powers over UK companies.
UK companies are at risk of committing or contributing
to human rights violations in conflict or high risk areas
10. Currently, UK companies are operating
in conflict or high risk areas where there is fighting, widespread
repression and weak protection against human rights violations.
These volatile areas are not limited to areas of armed conflict,
as defined by international humanitarian and criminal law, but
also include areas experiencing civil war, an absence of rule
of law and accountability, brutal government regimes that seek
to repress human rights, or, those post-civil war countries with
sporadic violence, and localised areas of civil unrest.
11. Often in these conflict or high risk
areas the host government (ie the country where corporate
operations are being conducted) is unable or unwilling to
assume its responsibility in safeguarding human rights. Thus,
protections are weak and companies are at a greater risk of committing
and exacerbating human rights violations. In these areas, gross
human rights violations take place and criminal activity often
goes unchallenged. Without regulation and targeted policy developments
at the international level, and interventions made by the home
states of these companies, corporate involvement in human rights
abuses will continue unabated.
12. In addition, the lucrative "rents"[392]
available from natural resources are known to spur a state party
or warring factions to gain control over them, which can cause
or exacerbate conflict and human rights violations. A recent UN
report on the relationship between natural resources and conflict,
finds that forty percent of all intrastate conflicts since 1960 have
a link to natural resources. It also concludes that intrastate
conflicts linked to natural resources are twice as likely to relapse
within five years.
13. For example, Global Witness' field research
in eastern DRC and neighbouring countries in 2008 and 2009 uncovered
substantial evidence of the involvement of armed groups in the
exploitation and trade of cassiterite (tin ore), gold, and other
minerals in North and South Kivu. These economic activities are
perpetuating the instability in the region and UK companies are
involved.
14. Ultimately, the unaccountable exploitation
of natural resources can lead to states suffering the "resource
curse": the phenomenon by which the generation of natural
resource wealth from the exploitation of natural resources in
states captured by unaccountable elites, results in poor standards
of human development, bad governance, increased corruption and
state looting, and very often conflict.
15. In these instances home states, such
as the UK Government, need to assume both a proactive and sanctioning
role to fill in the "governance gaps" by taking steps
to ensure that their companies neither perpetuate nor are complicit
in human rights abuses arising by virtue of their operations in
these areas.
16. As highlighted by Professor Ruggie,
international law does not prevent the UK Government from playing
a role in protecting against corporate human rights abuses in
conflict or high risk areas. Moreover, because of the unique circumstances
associated with conflict or high risk areas, the UK may even be
entitled to take more assertive action.
17. Already, countries such as Norway and
Sweden have started to recognise their role as primary caretakers
for protecting human rights arising from their business in conflict
affected areas.[393]
18. In addition, responsible business has
asked for increased guidance for companies operating in weak governance
areas. The International Chamber of Commerce has stated that national
governments needed "
to create the underlying legal
framework for protecting human rights and to take action when
those rights are denied."[394]
CURRENT SHORTCOMINGS
RELATING TO
THE UK GOVERNMENT'S
ACTIONS IN
PREVENTING OR
DETERRING ABUSES
19. The UK Government's response to instances
where their companies are operating in conflict or high risk areas
has been on an ad-hoc basis. For example, in the past official
statements have been made by the UK Government warning UK-registered
companies against operating in Burma and Zimbabwe. We believe
such public statements are valuable, however, their infrequency
highlights the lack of a systematic approach.
20. In addition, the UK Government is a
signatory to a number of corporate and human rights related voluntary
initiatives including: the Voluntary Principles on Security and
Human Rights and the OECD Guidelines for Multinational Enterprises
(OECD Guidelines). However, voluntary initiatives are insufficient.
They must be supplemented with accountability mechanisms that
ensure compliance and whereby there are significant consequences
such as criminal sanctions where necessary.[395]
FIVE SPECIFIC
INSTANCES ARISING
FROM GLOBAL
WITNESS' WORK:
i) Global Witness complaint against Afrimex
under the OECD Guidelines (January 2007)(see: Annex "A"
Case Study 1)
21. Global Witness applauds the UK National
Contact Point's (NCP) final statement upholding allegations that
UK-registered Afrimex had failed to ensure that its trading activities
did not support armed conflict and forced labour in eastern DRC.
A significant part of NCP's conclusions rested upon the fact that
Afrimex had not exercised sufficient due diligence to its supply
chain, and that some of its suppliers had made payments to rebel
groups thus contributing to the conflict.[396]
Nevertheless, the NCP final statement in itself is insufficient.
22. In the final statement, issued in August
2008 the NCP made a number of recommendations to Afrimex.
However, by February 2009 the NCP had not received any information
from Afrimex about the implementation of its recommendations.
23. Since submitting the OECD complaint
in January 2007, information gathered by Global Witness confirmed
that Afrimex continued to trade in 2007 and 2008 with
at least one supplier identified in the December 2008 UN
Final Report of the Group of Experts for the Democratic Republic
of the Congo (UN Expert Report),[397]
as buying minerals produced by rebels and responsible for grave
human rights abuses.
24. In March 2009 Afrimex finally advised
the UK NCP that it had stopped trading in minerals from eastern
DRC in September 2008, after the final statement was issued. However,
this claim remains unsubstantiated by Global Witness and the UK
Government.
25. The UK government should take further
action to ensure that Afrimex fundamentally change its practices
regarding eastern DRC, and that the investigation and conclusions
of the NCP are more than just a theoretical exercise. At the international
level, the UK Government should report Afrimex and its directors
to the UN Sanctions Committee pursuant to UN Security Council
Resolution 1857. Global Witness believes that continued trade
by Afrimex justifies that it falls within the criteria of paragraph
4(g) of that Resolution.[398]
See: Recommendations Section paragraphs 43-44.
26. Global Witness believes the OECD Guidelines
remain a weak, non-binding mechanism. In particular, the NCP cannot
compel a company found to be in violation of the Guidelines to
change its corporate practices. This underscores the need for
the UK Government to monitor company behaviour after final statements
are issued and ensure compliance. Without doing so, breaches of
the OECD Guidelines may continue thereby perpetuating and endangering
human rights.
27. Furthermore, the UK government should
send a clear signal to UK-registered companies that it expects
them to carry out thorough due diligence to ensure that their
trade is not funding any of the warring parties in high risk areas.
The UK Government should be able to define the conditions under
which companies should be permitted to operate in these areas.
It is not good enough that a company be transparent with respect
to its trading partnersdue diligence should be regularly
performed and updated throughout the lifecycle of operations.
With respect to Afrimex, the UK Government should have taken steps
to sanction the company long before Global Witness' interventionthese
important cases should not only be left to civil society to undertake.
See: Recommendations Section paragraphs 45-47.
ii) Amalgamated Metal Corporation (AMC) cited
in UN Expert Panel reports as funding warring factions in eastern
DRC(see: Annex "A" Case Study 2)
28. Stronger measures are required to supplement
current UK Government practice as demonstrated by the identification
of two UK based companies in the 2008 UN DRC Report.[399]
29. The 2008 UN Expert Report establishes
that one of main suppliers of THAISARCO (a subsidiary of AMC)
in eastern DRC has close links with an armed group responsible
for committing grave human rights abuses against civilians.
30. As early as 2002, AMC were included
in a list of companies considered by the UN Panel of Experts to
be in violation of the OECD Guidelines.
31. In December 2008, Global Witness wrote
to THAISARCO and its UK-registered parent company AMC inquiring
about their trade with the DRC and their due diligence policies.
AMC responded by letter dated 19 January 2009 outlining
its general policy toward the DRC.
32. Global Witness believes that THAISARCO
and AMC fall within the criteria of paragraph 4(g) of UN Security
Council Resolution 1857[400]
and urges the UK Government to investigate AMC and its four constituting
UK companies and, if warranted, recommend to the UN Sanctions
Committee that these companies, and their directors, be included
in the list of companies and individuals against whom sanctions
are imposed. See: Recommendations Section paragraphs 43-44.
iii) Turkmenistan and the UK Export Credits
Guarantee Department(see Annex "A" Case Study
3)
33. Within the context of the UK Government's
support for gas exploration projects in Turkmenistan, Global Witness
submits that the UK Government should ensure that human rights
concerns remain central to all exploration agreements made by
UK companies requiring its financial support. The UK Government
should: 1) set higher standards than those that currently exist
for UK companies; and 2) take measures to ensure that its funding
is not fuelling human rights abuses 3) require companies to provide
a Human Rights Impact Assessment (HRIA) and show that adequate
due diligence has been taken to ensure that they will not be complicit
in any human rights violations. As a precondition, export credit
should only be provided on the basis that UK companies disclose
payments made to foreign governments. See: Recommendations Section
paragraph 52.
34. Global Witness is especially concerned
by recent moves to downgrade the UK Government's ability to police
ethical and environmental standards when offering taxpayer-guaranteed
insurance to British companies wanting to work on overseas projects.
As reported by the press, the proposed new Industry and Exports
(Financial Support) Bill will be a step backwards with respect
to the UK Government's efforts to fulfil its obligations under
the State Duty to Protect.[401]
We call for strong human right standards particularly in places
where the UK Government is providing financial support through
export credit guarantees to UK companies operating in conflict
or high risk areas.
iv) Anvil Mining and DFID Funding in the DRC(see:
Annex "A" Case Study 4)
35. Global Witness and RAID have repeatedly
expressed concern relating to DFID's decision to work with Anvil
Mining on a proposed Public Private Partnership (PPP) with USAID
in Katanga.[402]
Our concern was that DFID was directly or indirectly supporting
a mining company which local prosecutors allege have been involved
serious human rights violations, and which has so far refused
to acknowledge any responsibility for its role. In 2006, the prosecutor
at Katanga's Military Court in the DRC indicted three former expatriate
employees of Anvil Mining Congo SARL for complicity in war crimes.[403]
In June 2007 the military tribunal acquitted the defendants.
In reference to the trial, the UN High Commissioner for Human
Rights, Louise Arbour, stated, "I am concerned at the
court's conclusions that the events in Kilwa were the accidental
results of fighting, despite the presence at the trial of substantial
eye-witness testimony and material evidence pointing to the commission
of serious and deliberate human rights violations." To
date, no prosecution has been started in the home states of the
indicted employees.
36. Global Witness refers the Committee
to the joint publication it issued with Rights and Accountability
for Development (RAID) "Kilwa trial: a denial of justice.
A chronology, October 2004July 2007"[404]
which details the injustice faced by victims of the Kilwa Massacre
during the DRC Military Trial in 2006-07. See: Recommendations
Section paragraphs 53-54.
v) "Undue Diligence" and UK-registered
financial institutions(see: Annex "A" Case Study
5)
37. There are currently no laws in place
that require "due diligence" vis-à-vis the provision
of financial services to human rights violators nor guidelines
specific to conflict and high risk areas. Although not specifically
addressed by Professor Ruggie's framework, the UK Government should
clarify the human rights obligations of UK-registered financial
Institutions.
38. This need for clear guidelines is underscored
by the Apartheid Alien Tort Claims case currently being litigated
in the United States. It is alleged that the defendants, including
Deutsche Bank, Citibank and Barclays Bank "
actively
and willingly collaborated with the South African government to
perpetuate the repressive, race-based system of apartheid".[405]
Although defendants deny the charge, the case is still proceeding
through the courts.
39. Furthermore, Global Witness has uncovered
evidence that Citibank and Deutsche Bank, both of which have a
substantial presence in the UK with London-based headquarters,
have facilitated and enabled other forms of human rights abuses
to occur in the past: a) Citibank facilitated the funding of two
vicious civil wars in Sierra Leone and Liberia by enabling the
warlord Charles Taylor, now on trial for war crimes in The Hague,
to loot timber revenues. Citibank has a head office in the UK.[406]
b) Deutsche Bank assisted the late President Niyazov of Turkmenistan,
a notorious human rights abuser, to keep billions of dollars of
state gas revenues under his personal control and off the national
budget.
40. The UK Government should take a lead
in making reforms to the financial regulatory system to prevent
financial institutions from becoming complicit in human rights
violations in conflict and high risk areas. See Recommendations
Section paragraph 56.
RECOMMENDATIONS CALLING
FOR UK GOVERNMENT
ACTION
1) UK GovernmentAction at the international
level
41. The UK Government should support calls
for a UN Secretary General's report that examines the impact of
natural resource exploitation and trade on human rights in conflict
and post-conflict settings, including the lessons that can be
learned and the ways in which existing standards of conduct for
corporate and state actors may be strengthened.[407]
2) UK GovernmentRegulatory actions
at the national level
42. The UK Government should enforce and
compel compliance around minimum legal standards, including the
legal risks identified in the Red Flags document published
by FAFO and International Alert.[408]
This document successfully synthesises legal wrongs which Global
Witness has investigated in our own work. It captures nine liability
risks for companies to be aware of when operating in conflict
or high-risk areas. These represent a threshold and are based
on legal breaches sourced from both national and international
legal systems.
a) Enforce existing laws and legal obligations
43. Proactive action requires that the UK
Government enforce current laws that favour investigating and
prosecuting human rights abuses stemming from corporate activities
in conflict and high risk areas. This will require that domestic
criminal investigators and legal practitioners be more aware,
receptive, and better trained to take up these cases. For example,
the UK Government can call on legal experts to: draw out (in practical
terms) the elements required for establishing: i) the war crime
of pillage (i.e. theft of property affecting huma n rights
during armed conflict) or ii) the facilitation of state looting
either during or after a war, in UK courts.
44. The UK Government should focus on improved
enforcement and prosecution of individuals and companies that
violate UN Chapter VII sanctions. The UK Government should recognize
these as principles of international law and prioritize their
application. This requires that the UK Government actively investigate
UK companies identified by the UN, and report to the UN Sanctions
Committee any companies that fall within the criteria of UN Security
Council Resolutions.
b) Create new laws that apply extra-territorially
in conflict and high risk areas
45. The UK Government should introduce legislation
that requires companies that source natural resources produced
in conflict or high risk areasfor example cassiterite,
coltan, wolframite, and gold from eastern DRCto ascertain
the date of extraction and location where the minerals are produced.
46. The legislation should require that
UK companies operating in or buying from conflict or high risk
areas conduct sufficient due diligence in their supply chains
to ensure that they do not commit or contribute to human rights
abuses, or the facilitation of state looting and continuation
of bad governance. This obligation extends to a company's supply
chain, especially where the company is in a position to influence
any abusive human rights practices used by them.
47. This will require that the UK Government
also be able to assess the level of due diligence carried out
by a company operating in these areas.
3) UK governmentPolicy measures at
the national level
48. In addition to regulation, the UK should
adopt a series of policy and due diligence measures, and issue
public statements to minimize UK corporate related human rights
abuses.
a) Proactive policy measures
49. The UK Government should take proactive
steps to clarify expectations and principles relevant to business;
to identify indicators to trigger alerts with respect to companies
operating in conflict affected areas. This will require that the
UK Government review and condense into one document all human
rights principles that currently apply to UK companies operating
in conflict areas. The UK Government should evaluate and determine
the effectiveness of these principles and further develop them.
These principles should include the nine Red Flags as a basis
for developing higher standards. This synthesis should act as
a framework of expectations for registered companies when operating
in conflict areas.
50. The Government should strengthen, formalize
and monitor the implementation of existing voluntary codes such
as the OECD Guidelines. The Government should ensure that companies
comply with these human rights standards. The UK should be prepared
to sanction those companies that fall below these standards, whether
intentionally or otherwise. The UK Government should uphold final
statements made by the UK NCP and take steps to ensure that they
are brought to the attention of all arms of government.
51. The UK should make use of tools available
to the government in exercising leverage over companies breaching
human rights. As one method, the Government should recommend that,
when appropriate, their public financial agencies divest from
companies that are found to violate human rights standards. To
achieve this, the Government should replicate and customise current
best practice models such as the Norway Pension Fund. In addition,
the Government should strengthen the human rights components of
the OECD Guidelines, which are currently very general.
52. As mentioned previously in this submission,
the UK Government should make more effective use of the ECGD by
requiring that they explicitly state that human rights are operational
principles applicable to companies seeking financial support and
insist that red flags are adhered to as minimum criteria for insurance.
The UK Government should act proactively and withdraw its support
altogether, when companies are found to be committing or complicit
in human rights abuses. Furthermore, UK Government can take steps
to ensure that complicit companies cannot get support from other
financial institutions.
b) Due diligence within UK government departments
53. The UK Government needs to ensure that
officials in government agencies who promote foreign investments
and provide development assistance are aware of the human rights
situations in volatile areas and explicitly require that corporate
human rights related due diligence be performed. This should be
assessed by the official before approval is provided. As one example,
DFID should ensure that the PPPs in which it is involved, include
businesses not alleged to be involved in human rights violations.
54. The UK Government needs to be able to
provide meaningful on-the-ground advice to companies, for example,
through their embassies in host countries, on whether or not they
should continue to conduct business in conflict or high risk areas
or how they should manage human rights risks. Professor Ruggie
recently stated that "the OECD has developed a generic risk-assessment
tool for companies operating in weak governance zones, but what
companies need is real-time information and advice."[409]
c) Public warnings
55. The UK Government should adopt and express
a "no-go" position where it is determined that direct
or indirect violations of human rights cannot be mitigated by
a UK-registered company. In these instances the UK should take
a public position stating its reasons for concern and calling
for companies to cease economic activity until the human rights
conditions improve. This would be short of sanctions, but can
be helpful in some cases. The UK has already used this technique
on an ad hoc basis, whereas a more systematic approach is necessary.
4) UK GovernmentGuidelines and integration
of human rights benchmarks for financial institutions
56. Calling for clear guidance to be given
to UK-based financial institutions and requiring that minimum
human rights standards be integrated into all their business with
companies that operate in conflict or high risk areas. The UK
Government can specifically engage in the following:
(a) Require that commercial banks integrate Red
Flags (ie minimum legal standards) into all dealings with companies
that operate in conflict areas. If banks have a client operating
in a conflict or high risk area, they should be required to undertake
enhanced due diligence, using the Red Flags' model to identify
potential abuses, and then to avoid doing business if risks were
identified.
(b) Ensure that their own credit agencies operate
on the same model and use their leverage as donors to the international
financial institutions to press for them to do the same.
(c) Engender a changed culture of "due diligence"banks
should only take the business if they have identified that the
ultimate beneficiary is not a known human rights violator or a
key government official or family member associated in state looting.
(d) Ensure that new global rules are put in place
to help banks avoid funds gained through the commission of human
rights violations. Every country should produce full public online
registers of the ultimate beneficial ownership of all companies
and trusts under its jurisdiction, to help banks identify and
avoid business with a human rights risk.
392 "Rents" are unearned funds that are used
by governments or controlling factions for financial gain-they
reflect revenues that exceed costs or what would be normal profit
margins for that resource. In conflict or high risk areas these
profits are often larger because actual costs are lower due to
underpaid labour and/or illegal operations. Back
393
Both countries have adopted a zero tolerance approach for state
investments in project finance deals that have a negative impact
on human rights. Notably, Norway's Pension Fund and Ethical Guidelines
for investment implemented by the Council of Ethics. Back
394
IOE, ICC and the Business and Industry Advisory Committee (BIAC)
submission "Business and Human Rights: The Role of Business
in Weak Governance Zones, Business Proposals for Effective Ways
of Addressing Dilemma Situations in Weak Governance Zones"
(December 2006). Back
395
See: Global Witness publication "Oil and Mining in Violent
Places" located at http://www.globalwitness.org/media_library_detail.php/580/en/oil_and_mining_in_violent_places. Back
396
Final statement by the UK National Contact Point for the OECD
Guidelines for Multinational Enterprises: Afrimex (UK) Ltd, 28 August
2008; Department for Business Enterprise and Regulatory Reform
(BERR) press release "Mineral trade helped fund rebels",
28 August 2008. Back
397
http://daccessdds.un.org/doc/UNDOC/GEN/N08/618/77/PDF/N0861877.pdf?OpenElement
(last accessed 29 April 09). Back
398
UN Security Council Resolution 1857 (2008), 22 December
2008 S/RES/1857 (2008) calls for the renewal of the
arms embargo with respect to the DRC and financial and travel
restrictions against those acting in breach of the embargo, until
30 November 2009. The basis for our request rests in paragraph
4(g) of the Resolution, which states that the criteria for sanctions
extend to "individuals and entities supporting illegal
armed groups in eastern DRC through illicit trade in natural resources."
Sanctions would include an assets freeze and travel ban. Afrimex
has been named by UN Panel of Expert Reports for the DRC since
2002. Back
399
The two named UK companies included Afrimex and AMC. Back
400
See explanation in footnote 398-the basis for our request rests
in paragraph 4(g) of the Resolution 1857, which states that the
criteria for sanctions extend to "individuals and entities
supporting illegal armed groups in eastern DRC through illicit
trade in natural resources." Sanctions would include
an assets freeze and travel ban. Back
401
The Times "Lord Mandelson accused of weakening rule on
ethical exports" 13 April 2009 located at April
http://www.timesonline.co.uk/tol/news/politics/article6082922.ece
(last accessed 27 April 2009). Back
402
We understand that DFID has subsequently discontinued its work
with Anvil Mining. Back
403
For details of the local prosecutor's allegations see: http://www.globalwitness.org/media_library_detail.php/560/en/kilwa_trial_a_denial_of_justice;
it should be noted that Anvil Mining Congo SARL is a subsidiary
of Canadian/Australian Anvil Mining Limited. A holding company
for Anvil is located in the UK. Back
404
http://www.globalwitness.org/media_library_detail.php/560/en/kilwa_trial_a_denial_of_justice Back
405
Global Policy Forum (May 13, 2008) located at: http://www.globalpolicy.org/intljustice/atca/2008/0513apartheid.htm Back
406
See: Global Witness's report, "Undue Diligence: How banks
do business with corrupt regimes," 2009 located
at http://www.globalwitness.org/media_library_detail.php/735/en/undue_diligence Back
407
In June 2007 the UN Security Council convened a first ever
thematic debate on natural resources and conflict and called for
more international action to address the issue. The Belgian government
has since proposed that the UN General Assembly (UNGA) convenes
a debate on the same topic. The immediate objective would be a
UNGA resolution calling for a UN Secretary General's report. Back
408
The FAFO and International Alert, Red Flags document states
that Red Flags exist when actions result in: displaced peoples;
forced labour; the handling of questionable assets; making illicit
payments; engaging with abusive security forces; trading goods
in violation of UN international sanctions; providing the means
to kill; and the financing of crimes. Back
409
"Prepared Remarks by SRSG John G. Ruggie Public Hearings
on Business and Human Rights Sub-Committee on Human Rights European
Parliament" (Brussels, 16 April 2009). Back
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