Dr Alessandra de Tommaso, Senior Lecturer in Law, Middlesex University

Introduction

On 3 July 2025, the UN Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967, Francesca Albanese, presented her report From Economy of Occupation to Economy of Genocide (hereinafter, the Report), which investigates the involvement of the corporate sector in the Israeli economy of ‘illegal occupation, apartheid and now genocide’.[1] The Report argues that this complicity is just ‘the tip of the iceberg’ and that ending it requires holding the private sector accountable.[2]

The report’s ambitious recommendations highlight the urgency of corporate accountability; this post explores how far existing international law on business and human rights addresses the challenge.

Indeed, the Special Rapporteur presents a staggering account of the relationship between business activities and atrocity crimes, illustrating  the profitability of evil. The Report exposes how corporations operating in conflict-affected and high-risk areas have not only facilitated, but in some cases directly contributed to serious human rights violations in pursuit of commercial gain.

This is not the first time such dynamics have come to light. Similar reports and investigations have emerged over the years, documenting corporate complicity in international crimes: from the case of Lafarge in Syria, where the company was accused of financing terrorist groups; to Lundin Energy’s alleged involvement in war crimes in Sudan. These cases reflect a troubling pattern in which economic interests are prioritised over human rights, and where the absence of binding legal frameworks enables corporations to operate with impunity, even in the context of mass atrocity.

This blog explores the content and key recommendations of the Report on corporate involvement in atrocity crimes. It then situates these findings within the broader legal framework governing corporate responsibility for human rights, aiming to identify potential avenues for pursuing corporate accountability. On the one hand, soft law instruments provide a foundation to advocate for corporate divestment and to push companies toward stronger human rights due diligence standards. On the other hand, criminal prosecution remains a possible tool against corporate executives and entities, though existing limitations may render  this approach less effective or feasible than alternative mechanisms.

1. The Report

      Presented on the occasion of the 59th session of the United Nations Human Rights Council, the Report From Economy of Occupation to Economy of Genocide (dated 30 June 2025) examines the role of corporate entities in sustaining Israel’s illegal occupation and its ongoing genocidal campaign in Gaza, focusing on how business interests underpin the ‘twofold logic of displacement and replacement aimed at dispossessing and erasing Palestinians from their lands’.[3] It claims that, after October 2023, entities that previously enabled and profited from the erasure of Palestinians through the occupation economy ‘are now involved in the economy of genocide’.[4]

      The Special Rapporteur relies on the concept of colonial racial capitalism to address Israel’s colonisation of Palestine, ‘its expansion into the Occupied Palestinian Territory and its institutionalisation of a settler-colonial apartheid’.[5] The term draws on and extends Cedric J. Robinson’s theory of racial capitalism, which argues that capitalism has always relied on racialisation to differentiate and stratify labour, rendering some populations exploitable and disposable.[6] When applied to colonial contexts, this insight highlights how settler-colonial projects and imperial domination are not merely political or territorial, but also economic systems premised on the systematic devaluation of colonised lives through racial categorisation.[7] In this context, settler colonialism and genocide are explained not as historical events but rather as systems or structures that perpetuate the erasure and destruction of native peoples as a precondition for settler colonialism and the expropriation of lands and resources.[8]

      The Report identifies eight corporate sectors as central to Israel’s  settler-colonial economy, which it argues is structured around two interrelated pillars: displacement and replacement.[9]

      1.1 Displacement

        The first pillar, displacement, refers to the systematic removal of Palestinians from their land and the destruction of the conditions necessary for their return. This process is enabled, first and foremost, by the military sector.[10] Israeli and international arms manufacturers play a key role. Their weapons systems, many of which are developed and tested in Gaza, have been integral to Israeli military campaigns, particularly the intensive bombing operations that have reportedly resulted in over 179,000 Palestinian casualties.[11]

        Alongside military firms, the technology sector, particularly companies specialising in surveillance and incarceration, also plays a prominent role in sustaining displacement.[12] Firms like IBM, Hewlett Packard, Microsoft, Alphabet (Google), Amazon, and Palantir develop and supply dual-use technologies, including tools for mass data collection, biometric surveillance, and artificial intelligence–based targeting. These systems are deployed in ways that facilitate discriminatory forms of control, movement restriction, and carceral governance.[13]

        The Report also highlights the role of heavy machinery manufacturers.[14] Companies such as Caterpillar Inc., HD Hyundai, and the Volvo Group produce and sell equipment used in house demolitions, land clearance, and urban destruction. While such equipment is nominally civilian in nature, it is routinely used for punitive and military purposes, with the aim of rendering Palestinian return physically impossible.

        1.2 Replacement

          The second pillar, replacement, involves the substitution of Palestinian presence with Israeli settlement infrastructure and economic activity. The Report contends that construction and infrastructure companies are central to this process.[15] For example, Heidelberg Materials AG and Construcciones Auxiliar de Ferrocarriles have been involved in the development of settlements and related transport systems, which underpin the territorial expansion of Israeli control.

          Another key dimension of replacement is the control and exploitation of natural resources.[16] Water, fuel, gas, and electricity are not only essential for daily life but also weaponised as tools of domination. Companies such as Mekorot, Drummond Company Inc., Glencore PLC, Chevron, and BP are implicated in this dynamic. Their involvement enables Israel to systematically restrict access to essential resources in Gaza, intensifying humanitarian suffering.[17]

          The Report also addresses how corporations profit from what it terms ‘trading in the fruits of illegality’.[18] Indeed, agribusiness firms benefit from land expropriation and water appropriation, weakening Palestinian agriculture while bolstering settler farming.[19] Global retailers and logistics providers, including Amazon, facilitate the international sale of products originating in illegal settlements, often concealing the origin of these goods.[20] According to the Report, even the tourism industry plays a part, as platforms such as Booking.com and Airbnb promote rental properties in settlements, normalising and sustaining their economic viability despite their contested legal status.[21]

          Finally, the Report examines a broader category of actors it calls ‘enablers’, those institutions that legitimise or finance the entire system.[22] Financial institutions, investment firms, and large sovereign wealth and pension funds collectively direct substantial financial resources into Israeli government bonds and companies implicated in the occupation and related acts of violence. This financial entanglement persists despite many of these institutions publicly endorsing environmental, social, and governance (ESG) principles.

          Knowledge producers, particularly universities, also feature prominently among the enablers.[23] Such institutions are said to contribute in two key ways: by developing technologies that feed into the military and surveillance apparatus, and by maintaining partnerships and research collaborations that lend legitimacy to Israeli state policies and corporate activities. In this way, the Report contends, academia becomes complicit in both the technical facilitation and the ideological justification of the settler-colonial regime.

          1.3 The Report’s Conclusion and Recommendations

          The Report concludes that the Israeli occupation of the Occupied Palestinian Territory, particularly the current military campaign in Gaza, has transitioned from a prolonged occupation into what the Special Rapporteur terms an ‘economy of genocide’.[24] At the heart of this system lies a global network of corporate actors that materially sustain, profit from, and incentivise the Israeli settler-colonial project of displacement and replacement of the Palestinian people. According to the Special Rapporteur, these actors, rather than being neutral participants, form a ‘joint criminal enterprise’.[25] The Report warns that, unless the corporate complicity underpinning these violations is dismantled, efforts to end the genocide and uphold international law will remain ineffectual.

          The Special Rapporteur provides a series of targeted recommendations to a range of actors. To Member States, the call is  for immediate and comprehensive measures, including the imposition of sanctions and a full arms embargo on Israel, encompassing both military equipment and dual-use technologies.[26] States are urged to suspend all trade, investment, and cooperation with individuals and companies implicated in the illegal occupation, and ensure domestic laws allow for the prosecution of those complicit in serious violations of international law.[27] This includes establishing accountability for corporate executives and entities whose operations enable or benefit from Israel’s actions in the Occupied Palestinian Territory.[28]

          To corporate entities, the Report demands that all companies and financial institutions withdraw unconditionally from any activity linked to the illegal occupation, apartheid, or genocide.[29] Moreover, the Special Rapporteur calls on them to provide reparations to Palestinians, including the introduction of an ‘apartheid wealth tax’ to address decades of exploitation and harm.[30]

          The International Criminal Court (ICC) and national courts are urged to investigate and prosecute corporate actors involved in the perpetration of international crimes or in the laundering of related proceeds.[31] The Special Rapporteur also recommends that the United Nations, and in particular the Office of the High Commissioner for Human Rights (OHCHR), expand the existing database of business enterprises involved in settlement activity and ensure that it is publicly accessible and regularly updated.[32]

          Finally, the Report addresses civil society, including trade unions, legal professionals, and the general public. It encourages them to mobilise for justice by supporting efforts such as boycotts, divestment, sanctions, and legal action against corporations complicit in the occupation and genocide.[33]

          2. Framing Corporate Accountability: Legal and Normative Pathways

          The Special Rapporteur offers a number of valuable insights into the role of the business sector in the commission or facilitation of international crimes. While the phenomenon of corporate involvement in atrocity crimes is not new,[34] the issue has become increasingly visible and relevant in recent decades. From the involvement of corporations in the extraction of resources in conflict zones to their role in surveillance, construction, and logistics in situations of military occupation, the entanglement of business operations with human rights abuses has assumed multiple forms.

          Examples abound: from the complicity of multinational corporations in the apartheid regime in South Africa,[35] to allegations against companies colluding with authoritarian regimes in Latin America,[36] and ongoing litigation involving corporate actors in relation to abuses in Sudan, ColombiaSyria,   and the Democratic Republic of Congo. Today, the situation in the Occupied Palestinian Territory raises urgent questions about the legal and moral responsibilities of corporate actors operating in conflict-affected areas.

          The conclusions and recommendations presented in the Report stress the urgency of breaking the persistent cycle of impunity for corporate actors and call for a proactive consideration of existing mechanisms for accountability. In order to evaluate the feasibility of addressing corporate complicity in the Occupied Palestinian Territory, it is essential to examine the international legal framework governing business and human rights and the potential venues for accountability.

          3.     Business Responsibility vis-à-vis Human Rights: A Soft Law Approach

          As the Report highlights, the current legal framework addressing corporate accountability for serious human rights violations is primarily grounded in soft law instruments, chief among them, the UN Guiding Principles on Business and Human Rights (UNGPs).

          Endorsed by the UN Human Rights Council in 2011, the UNGPs provide the authoritative global framework for understanding and implementing business responsibilities in relation to human rights. They are structured around three pillars: (1) the State duty to protect human rights; (2) the corporate responsibility to respect human rights; and (3) the right to remedy for victims of business-related human rights abuses. While the first pillar addresses the obligations of states under international human rights law, the second pillar, corporate responsibility to respect, applies independently of state action or enforcement.

          Under the second pillar, businesses are expected to avoid infringing on the human rights of others and to address adverse impacts with which they are involved. This requires companies to adopt a process of human rights due diligence (HRDD), which includes identifying, preventing, mitigating, and accounting for how they address their human rights impacts (Principle 15).[37]

          In conflict-affected areas, the UNGPs impose a heightened expectation on companies. Principle 7 acknowledges that conflict situations pose a particular risk of gross human rights abuses, such as war crimes and crimes against humanity, and that the risk of corporate involvement in such abuses is significantly elevated.[38] Businesses are therefore expected to exercise heightened due diligence and to take proactive steps to ensure they are not directly or indirectly contributing to human rights violations. This includes carefully assessing the conflict dynamics, understanding the roles and actions of state and non-state actors, and avoiding complicity in violations through their operations, partnerships, or supply chains. Where companies cannot operate without contributing to abuses, the UNGPs suggest that they may need to suspend or withdraw from operations.

          It is within this framework that the Special Rapporteur’s recommendations to corporate actors must be understood, specifically, the call to immediately ‘cease all business activities and terminate relationships directly linked with, contributing to, and causing human rights violations and international crimes against the Palestinian people’.[39]

          While non-binding in nature, the standards set by the UNGPs in relation to human rights due diligence have clearly reshaped the legal framework on corporate liability, introducing quasi-legal obligations on corporations in the area of business and human rights. Furthermore, the authoritative standards established by the UNGPs have increasingly been reinforced through domestic legislation. Notable examples include France’s Duty of Vigilance Law (2017), which requires large companies to identify and prevent human rights and environmental risks in their global operations, and Germany’s Supply Chain Due Diligence Act (2023), which imposes similar obligations on companies to conduct due diligence across their supply chains. Similarly, the newly adopted EU Corporate Sustainability Due Diligence Directive (CSDDD) is expected to create binding obligations for companies operating in the European market. These developments reflect a growing trend towards the legal codification of corporate human rights responsibilities and provide the basis to scrutinise corporate conduct in contexts such as the Occupied Palestinian Territory.

          In this sense, the Report provides an important additional element for assessing the position of companies. The Special Rapporteur emphasises that recent international legal developments concerning the Occupied Palestinian Territory have significantly reshaped how corporate responsibility and potential liability are evaluated.[40] In particular, the growing body of evidence pointing to the commission of international crimes suggests that corporate actors are, or ought to be, aware of the context in which they operate. This, in turn, establishes a prima facie case for corporate complicity, as their continued engagement may amount to knowing contribution to unlawful conduct.

          This is a significant consequence of the recent ICJ’s Advisory Opinion of 19 July 2024, in which the Court found Israel’s prolonged presence in the entire territory, including its military occupation, settlement enterprise, infrastructure, and resource control, to be illegal. This conclusion carries serious implications for corporate actors whose operations or investments are linked to the Occupied Palestinian Territory. Businesses involved in or benefiting from the occupation’s infrastructure are now clearly on notice of the risk of contributing to, or being complicit in, grave breaches of international law, including international crimes.

          Additionally, the atrocities committed since October 2023 have triggered proceedings for genocide before the International Court of Justice – South Africa v. Israel and Nicaragua v. Germany –, and for war crimes and crimes against humanity before the International Criminal Court. These cases significantly raise the threshold for corporate due diligence under the UNGPs and place corporate entities under a clear and urgent responsibility to disengage from any activity linked to the situation.

          These developments open the door to civil litigation as a means to hold corporations accountable for their contribution to atrocities, including in contexts such as the Occupied Palestinian Territory. Civil society organisations and affected communities may leverage domestic due diligence laws to initiate proceedings against companies whose operations or business relationships contribute to international crimes.

          4.     Criminal Liability for Corporate Actors: A Work in Progress.

          A separate consideration is warranted in relation to the Report’s call on the International Criminal Court (ICC) to investigate and prosecute corporate executives and ‘corporate entities’ for their role in international crimes.[41] While the issue of corporate accountability under international criminal law has been debated for decades, the international criminal justice system continues to struggle with the challenge of holding businesses accountable.

          In the immediate aftermath of the Second World War, tentative efforts were made to address corporate complicity through legal means. Several criminal trials were conducted against German industrialists for their involvement in Nazi atrocities.[42] Notable examples include the cases against the executives from the Flick, IG Farben, and Krupp firms. Yet, even in these precedents, the focus remained on individual responsibility, while corporate entities themselves were left outside the reach of international criminal prosecution.

          After the fall of the Berlin Wall, an attempt was made to establish the international criminal liability of legal persons for atrocity crimes within the Statute of the International Criminal Court. Despite the efforts, the proposal on the liability of juridical persons was ultimately withdrawn due to time constraints and difficulties in reaching an agreement on the definition of a suitable model of corporate liability.[43] A notable regional effort to fill this gap emerged with the adoption of the Malabo Protocol by the African Union in 2014, which, if ratified, would establish a regional criminal court with jurisdiction over legal persons, including corporations, for international crimes such as genocide, war crimes, and crimes against humanity. However, to date, the Protocol has not been ratified by the required number of states to enter into force, leaving its potential unfulfilled.

          Although corporations cannot be investigated or prosecuted by international or hybrid tribunals, the ICC may investigate and prosecute individual business executives and corporate officers who contribute to the commission of international crimes. Under the aiding and abetting standard of liability, individual actors may be held responsible if they provide substantial assistance to a crime (actus reus) and do so with knowledge or intent that their conduct would facilitate that crime (mens rea). While the ICC has not yet pursued corporate actors, its legal framework allows for such prosecutions, and the potential for corporate accountability through individual criminal responsibility remains in place.

          This potential was tested in the context of corporate complicity in atrocity crimes committed in Colombia. In May 2017, three non-governmental organisations submitted an Article 15 Communication to the ICC, urging the Office of the Prosecutor to expand its preliminary examination in Colombia to include senior executives of Chiquita Brands International, Inc. The Communication alleged that Chiquita officials knowingly authorised regular payments to the paramilitary group Autodefensas Unidas de Colombia (AUC), despite being aware that the AUC was committing widespread crimes against humanity. However, the submission did not result in an ICC investigation into Chiquita’s role, illustrating the limitations of the Court in holding corporations accountable in practice.

          In the absence of an effective international criminal law framework for corporate accountability, an alternative suitable venue is offered by national criminal courts. Recently, domestic courts have increasingly become testing grounds for holding corporate actors accountable for atrocity crimes. A pivotal example is provided by the LaFarge case, in France. In May 2022, the Paris Court of Appeal upheld the charges against the cement group Lafarge (now Holcim) for aiding and abetting crimes against humanity. The decision was subsequently confirmed by the French Supreme Court, in October 2023. Lafarge is the first company in the world to ever face such a charge. Similarly, the ongoing trial of Lundin Energy executives in Sweden for alleged war crimes in Sudan underscores a growing willingness to prosecute corporate officials. However, these efforts remain isolated and often depend on political will, resource availability, and the strength of national legal frameworks.

          A special mention is warranted for the recent legal proceedings targeting Booking.com in the Netherlands, which offer an illustrative case study in emerging approaches to corporate accountability in the context of the Occupied Palestinian Territory. On 8 November 2023, SOMO (the Centre for Research on Multinational Corporations), together with a consortium of civil society organisations, filed a criminal complaint with the Dutch Public Prosecutor accusing Booking.com of laundering proceeds derived from the commission of war crimes in the Occupied Palestinian Territory. Uniquely, this case invokes Dutch anti-money laundering legislation as an indirect means of addressing the company’s alleged complicity in international crimes. If successful, it would represent one of the first attempts to apply anti-money laundering frameworks to corporate operations in an occupied territory, setting a potentially significant precedent.

          While the outcome remains pending, the case reflects a growing willingness to creatively test the limits of domestic legal frameworks to hold corporations accountable for their role in sustaining unlawful regimes. It also reinforces the Report’s broader call for urgent legal innovation and robust enforcement to address the accountability gap that continues to shield corporate actors from meaningful scrutiny.

          Despite these promising national-level developments, the broader landscape of corporate accountability for international crimes remains fragmented and inconsistent. The absence of a binding international legal framework capable of prosecuting legal persons leaves a substantial gap in the global justice system, one that is only partially filled by domestic proceedings. While cases such as Lafarge in France and Lundin Energy in Sweden demonstrate that corporate actors can be prosecuted, they remain the exception rather than the norm. Moreover, reliance on national courts introduces significant disparities in enforcement, with outcomes often shaped by political will, judicial independence, and institutional capacity.

          In the absence of a coordinated international response, corporate complicity in atrocity crimes risks continuing unchecked, protected by jurisdictional loopholes and legal ambiguity. This state of affairs ultimately undermines the Special Rapporteur’s call for decisive and systematic accountability mechanisms to confront corporate involvement in international crimes.

          In sum, the Report serves as a timely reminder of the need to harness both international and domestic legal tools to ensure that corporate actors do not escape accountability.

          Conclusion: From Exposure to Enforcement

          The Report lays bare the systemic entanglement between corporate power and atrocity crimes in the Occupied Palestinian Territory. It challenges the long-standing assumption that businesses are neutral actors in conflict zones, revealing instead a complex web of complicity that spans industries, borders, and institutions. From arms manufacturers and surveillance firms to financial institutions and tourism platforms, the Report documents how profit-driven operations have not only sustained but actively enabled a regime of displacement, replacement, and erasure.

          Yet, as the Report makes clear, exposure alone is not enough. The global legal framework remains ill-equipped to translate visibility into accountability. While soft law instruments like the UN Guiding Principles have shaped expectations, they lack the teeth to compel compliance. The emergence of binding due diligence laws in Europe marks a critical shift, but enforcement must be robust, and loopholes must be closed.

          The international criminal justice system still lacks the necessary tools to effectively address corporate complicity in atrocity crimes. Emerging developments, such as the inclusion of provisions on the liability of legal persons in the Draft Articles on Crimes Against Humanity, signal a step in the right direction. However, the path toward corporate accountability at the international level is still long and uncertain.

          In this vacuum, civil society and domestic courts have stepped in. Strategic litigation, shareholder activism, and consumer pressure have begun to challenge corporate impunity from below. Cases like Lafarge in France, Lundin Energy in Sweden, and the criminal complaint against Booking.com in the Netherlands illustrate the growing willingness to test legal boundaries and innovate accountability mechanisms. These efforts, while promising, are not yet systemic. They must be supported by coordinated legal reform, ethical investment strategies, and a transformation of the financial and regulatory ecosystems that currently shield corporate wrongdoing.

          Ultimately, the Report is a call to action. It demands that states, institutions, and individuals confront the uncomfortable truth: that the machinery of genocide and apartheid is not only political, it is economic.


          [1] From economy of occupation to economy of genocide, Report of the Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967 (Advance unedited version) (hereafter From economy of occupation to economy of genocide), A/HRC/59/23, 30 June 2025, p. 1.

          [2] Ibid.

          [3] From economy of occupation to economy of genocide), A/HRC/59/23, 30 June 2025, p. 2, para 2.

          [4] Ibid, p. 6, para 26.

          [5] Ibid, p. 1, para 1.

          [6] Cedric J. Robinson, On Racial Capitalism, Black Internationalism, and Cultures of Resistance (H. L. T. Quan, 2019).

          [7] Susan Koshy, et al., (eds.) Colonial Racial Capitalism (Durham: Duke University Press, 2022).

          [8] Nahla Abdo, ‘Racial Capitalism: From British Colonialism to the Settler Colonial Apartheid State’ (2024) 23(2) Journal of Holy Land and Palestine Studies 190.

          [9] From economy of occupation to economy of genocide), A/HRC/59/23, 30 June 2025, p. 2, para 2.

          [10] Ibid, pp. 7-9, paras 29-35.

          [11] Ibid, p. 8, para 32.

          [12] Ibid, pp. 9-12, paras 36-43.

          [13] Ibid, p. 11, para 42.

          [14] Ibid, pp. 12-13, paras 44-47.

          [15] Ibid, pp. 14-15, paras 49-52.

          [16] Ibid, pp. 15-17, paras 53-60.

          [17] Ibid, p. 17, para 60

          [18] Ibid, p. 17.

          [19] Ibid, pp. 17-19, paras 61-64.

          [20] Ibid, p. 19, paras 65-68.

          [21] Ibid, p. 19-20, paras 69-71.

          [22] Ibid, pp. 20-25, paras 72-86.

          [23] Ibid, p. 23-25, paras 82-86.

          [24] Ibid, p. 25, para 91.

          [25] Ibid.

          [26] Ibid, p. 25, para 94.

          [27] Ibid.

          [28] Ibid.

          [29] Ibid, p. 25, para 95.

          [30] Ibid.

          [31] Ibid, pp. 25-26, para 96.

          [32] Ibid, p. 26, para 97.

          [33] Ibid, p. 26, para 98.

          [34] Nick Robin, The Corporation that Changed the World: How the East India Company Shaped the Modern Multinational (Pluto Press, 2012). For an analysis of corporate complicity in Nazi crimes see, inter alia, Alessandra De Tommaso, Corporate Liability and International Criminal Law (Routledge, 2023), at 8-47, Joanna Kyriakakis, Corporations, Accountability and International Criminal Law: Industry and Atrocity (Edward Elgar, 2021) 46-103, Leora Yedida Bilsky, The Holocaust, Corporations, and the Law: Unfinished Business (The University of Michigan Press, 2017), Annika van Baar, ‘Corporate involvement in the Holocaust and other Nazi crimes’ in Judith van Erp et al. (eds.), The Routledge Handbook of White-Collar and Corporate Crime in Europe (Routledge 2015).

          [35] Annika van Baar, ‘Corporate involvement in atrocity crimes – trends and patterns in regulation’ (2024) 82 Crime, Law and Social Change 989, 999; Anita Ramasastry, ‘Corporate Complicity: From Nuremberg to Rangoon – An Examination of Forced Labor Cases and Their Impact on the Liability of Multinational Corporations’ (2002) 20 Berkeley Journal of International Law 91, 103;

          [36] ECCHR, ‘Volkswagen in Brazil: Automobile group collaborated with military dictatorship’ (ECCHR, n.d.) https://www.ecchr.eu/en/case/volkswagen-in-brazil-automobile-group-collaborated-with-military-dictatorship/ Accessed 25 April 2025; ECCHR, ‘Mercedes Benz supported the Argentine military dictatorship’(ECCHR, n.d.) https://www.ecchr.eu/en/case/mercedes-benz-supported-the-argentine-military-dictatorship/ Accessed 25 April 2025.

          [37] OHCHR, Guiding Principles on Business and Human Rights, Implementing the United Nations “Protect, Respect and Remedy” Framework, HR/PUB/11/04, 2011, Principle 15.

          [38] OHCHR, Guiding Principles on Business and Human Rights, Implementing the United Nations “Protect, Respect and Remedy” Framework, HR/PUB/11/04, 2011, Principle 7.

          [39] From economy of occupation to economy of genocide, A/HRC/59/23, 30 June 2025, p. 25, para 95.

          [40] Ibid, p. 35-36, paras 35-39.

          [41] From economy of occupation to economy of genocide, Report of the Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967 (Advance unedited version), A/HRC/59/23, 30 June 2025, p. 25, para 96.

          [42] Alessandra De Tommaso, Corporate Liability and International Criminal Law (Routledge, 2023) 23-39.

          [43] Ibid, 72-101.