civil liability. This responsibility for due diligence and the protection of human rights rests not only with businesses, but also with states. The UN Guiding Principles further emphasise that businesses must exercise due diligence throughout their value chain. This approach aims to identify the risks and human rights abuses that they may cause, contribute to or be linked to as a result of their business relationships, including with regard to the end use of their products. These same expectations are also reflected in the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, which have been in place since 201117 and were strengthened in 2023.18 The Myanmar junta has been subject to European sanctions since the 1990s.19 Whilst the regulations have evolved over time, the embargo on the supply of arms to the Myanmar junta has never been lifted. The 2013 regulation, for example, prohibited “to provide technical assistance related to military activities and to the provision, manufacture, maintenance and use of arms and related materiel of all types” or the supply of “equipment which might be used for internal repression”.20 These terms were reinforced by Regulation 2018/647, which stipulates that “Where the end-user is the Myanmar's/Burma's military, any dual-use goods and technology procured by it shall be deemed to be for military use”. 21 In addition to international frameworks, Thales is also subject to the 2017 French law on the duty of vigilance. This legislation imposes a proactive obligation on Thales to identify risks of human rights abuses, implement appropriate measures to mitigate them, and remedy any harm caused. Although as early as 2018, the “Group” identified export controls and economic sanctions as a legal risk, no mention of this is made in its due diligence plan.22 France’s choice of powerlessness, imposed on the European Union Despite the growing number of cases and legal frameworks, as mentioned above, and despite the State’s stake in Thales – which could be seen as a further guarantee of compliance with the existing legal framework – the ‘Group’ has not yet come under scrutiny. 17 OECD Guidelines for Multinational Enterprises | OECD (2011) OECD Guidelines for Multinational Enterprises on Responsible Business Conduct | OECD (2023) 19 The EU's relations with Burma / Myanmar | DG RELEX, European Commission (2004) 20 Council Regulation (EU) No 401/2013 concerning restrictive measures in respect of Myanmar/Burma and repealing Regulation (EC) No 194/2008 | European Union law (2013, May) 21 Council Regulation (EU) 2018/647 amending Regulation (EU) No 401/2013 concerning restrictive measures in respect of Myanmar/Burma | European Union law (2018, 26 April) 22 2017 Annual Report and Prospectus, including the annual financial report, section 1.1.2.2: Legal risks | Thales (2017) 18