Amnesty International’s investigation revealed that three EU-based companies – Morpho (now Idemia) from France, Axis Communications from Sweden, and Noldus Information Technology from the Netherlands- exported digital surveillance tools to China. These technologies included facial and emotion recognition software, and are now used by Chinese public security bureaus, criminal law enforcement agencies, and/or government-related research institutes, including in the region of Xinjiang. None of the companies fulfilled their human rights due diligence responsibilities for these transactions, as prescribed by international human rights law. The exports pose significant risks to human rights... Yet, the export of most digital surveillance technologies, including facial recognition, remains unregulated by the EU...

The results of this investigations were drawn up in preliminary findings that have been communicated with the companies through investigation letters. All companies provided Amnesty International with details on the transactions upon request at this or a later stage of the investigation. Based on all collected material, including the responses of the companies. Amnesty International assessed the risks of the business activities that were discovered in the public procurement databases. The findings relating to the business activities and the risks were shared with the companies and they were invited to respond to them. Where necessary these responses have been included in the results presented in Chapter 4...