Contd. Myanmar and Geedge The planning document notes data centers for every ISP, state-owned or private, present in the country. The “big four” ISPs, MyTel, Ooredoo, MPT and ATOM, are listed as well as entries for smaller providers like Frontiir, Global Technology Group, Golden TMH Telecom, Stream Net, IM-Net, Myanmar Broadband Telecom, Myanmar Telecommunications Network Public Company Limited, Campana and China Unicom. Documents also contains reports for link tests for all the ISPs. These reports provide information on website connectivity tests conducted in different dates throughout 2024. The objective of the tests seems to be to evaluate the effectiveness of the censorship on each ISP’s network. ISP Denial of Geedge Hardware and a Focus on VPN Blocking In May 2025, Finance Uncovered and Myanmar Now reported that the ISP Frontiir, which received foreign investment from the governments of Denmark, Norway, and the United Kingdom, was operating Geedge technology capable of “tracking people online, blocking websites” and VPNs in their data center.66 A Frontiir spokesperson denied that it had ever “built, planned, or designed anything related to surveillance” on its network. The leaked documents, however, indicate that Geedge hardware is installed inside the buildings of all the ISPs in Myanmar including Frontiir. The documents provide details on these installations and how the ISP links are interconnected. The network planning document diagram below, shows how the Geedge system is integrated inside the Frontiir data center. It is crucial to note that there is no way for Geedge to install its hardware without the knowledge and collaboration from ISPs. With evidence from the leaked documents, we know that denials from ISPs like Frontiir, claiming that they are not aware of surveillance equipment deployed on their networks, are factually incorrect.  Our team contacted Myanmar ISPs referred in this report. We received an answer from Investcom Holding, the parent company behind ATOM (formerly Telenor Myanmar). Investcom Holding stated in their letter that ATOM’s network does not design, direct &/or conduct mass, unlawful surveillance. They also said that as ATOM operates a telecommunications network it must comply with binding laws and regulations and that ATOM applies internal human-rights due-diligence procedures aligned with the UN Guiding Principles (UNGPs). The full content of the Investcom Holding can be found in the Annex.

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