the junta. As has previously been exposed by Justice For Myanmar, Shwe Byain Phyu Group has business links to the military conglomerate Myanma Economic Holdings Limited (MEHL) including for the import to Myanmar of petroleum and the company and its founders are sanctioned by the USA and Canada.40 In a reply to Justice For Myanmar, Investcom claimed that ATOM does not “design, direct &/or conduct mass, unlawful surveillance” and that it applies internal humanrights due-diligence procedures aligned with the UN Guiding Principles”. The company noted that it was “aware of claims relating to third-party technologies in Myanmar” but, referring to company policy, refused to “confirm or deny the existence of third-party systems”. Ooredoo Myanmar Limited Ooredoo Myanmar Limited (OML) is one of the four nationwide mobile network operators in Myanmar. It has implemented Geedge systems in Yangon and Mandalay. It was established as a fully owned subsidiary of Ooredoo Q.P.S.C., domiciled in Qatar and majority owned by the state of Qatar.41 Founded in 2014, OML along with Telenor entered Myanmar when there were no laws in place to regulate the use of interception technologies. Before and immediately after entering Myanmar, concerns were raised publicly regarding the human rights risks of operating a telecommunications company in Myanmar, including with Ooredoo Group's CEO directly.42 On September 8, 2022, Ooredoo announced the entry into a sales agreement for OML through its parent company, Ooredoo Asian Investments Pte. Ltd. (OAI), domiciled in Singapore, to Nine Communications Pte. Ltd., a Singapore-domiciled special project vehicle.43 Ooredoo's exit was completed on May 31, 2024.44 According to Singaporean registry data accessed in August 2025, Nine Communications biggest shareholder is Nyan Win through the Singaporeregistered company, Sunny Aqua Mountain Pte. Ltd., followed by Aion Ventures Limited and then the Myanmar companies National Telecommunication Development Co. Ltd., Pyi Taw Tha Pyi Telecom Co. Ltd. and Mahar Kyunt Mong Co. Ltd. Aion Ventures Limited is domiciled in the British Virgin Islands, a jurisdiction that is required to comply with UK sanctions on Myanmar. Frontiir Company Limited (Myanmar Net) Frontiir is one of Myanmar's largest ISPs and it has implemented Geedge technology in Yangon. Founded in 2013 by two US citizens and a Canadian, it is led by Myanmar-born US citizen Godfrey Tan (Wai Lin Tun).45 Frontiir provides 20

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