affected environments because of the heightened risks of violations of international human rights law and international humanitarian law.86 This is especially so in situations like present-day Myanmar, where a military junta is waging a terror campaign against civilians with repeated and significant disregard for international human rights law and international humanitarian law. Notably, the Commentary to Guiding Principle 23 notes that conflict-affected areas may increase the risks of enterprises being complicit in gross human rights abuses committed by others and asks companies to treat this risk as a legal compliance issue, given the expanding web of potential corporate legal liability arising from extraterritorial civil claims, and from the incorporation of the provisions of the Rome Statute of the International Criminal Court in jurisdictions that provide for corporate criminal responsibility.87 The commentary also makes clear that corporate directors, officers and employees may be subject to individual liability for acts that amount to gross human rights abuses. Geedge Networks' active engagement with the Myanmar military junta exposes individuals in directive positions within the company to criminal liability for aiding and abetting serious international crimes. Justice For Myanmar considers that the available evidence points to a preliminary case that Geedge is aiding and abetting in the commission of international crimes carried out by members of the junta. Those international crimes are likely to be crimes against humanity including specific acts of torture and killing within a widespread or systematic attack by the junta on a primarily civilian population. In this nexus, if Geedge's technology assists the junta to identify and gather information on Myanmar's civilian internet users, a case for complicity can be made. In knowingly enabling this pipeline, individuals in directive or leadership positions within Geedge Networks become complicit in international crimes carried out by the Myanmar junta. Under international criminal law, a company or individual is criminally liable if it provided practical assistance or means (in this case surveillance technology) that is more than likely to substantially contribute to the commission of a crime (such as torture of detained activists, whose activities and whereabouts have been identified using Geedge-supplied technology) with knowledge that their assistance would aid in the commission of the crime. The evidence is plentiful that crimes against humanity are being committed in Myanmar, and that acts, orders, and command can be attributed to individual members in, and associated with, the junta. With ongoing credible documentation and reporting at the United Nations of the human rights crisis in Myanmar,88 Geedge Networks must have known that its collaboration with the the junta’s ministry of transport and communications is taking place in a context in which the military junta is committing repeated grave violations of international human rights and humanitarian law. 31