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This report shows how Puma Energy, through wholly-owned PEAS and joint venture NEPAS, contributed to war crimes committed by the Myanmar military.

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MPPE/MPE

Since February 2021, MPE has been under military control. According to Puma Energy, following the military coup, MPE ran a tender for the supply and distribution of jet fuel to the Myanmar air force, in which Puma Energy did not participate.

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ASIA SUN GROUP

The evidence presented in this report clearly shows that Asia Sun Group is directly working with the military and may be serving as their proxy in order to import avgas and Jet A-1. Further, Cargo Link Petroleum (formerly Cargo Link Pongrawe), wholly-owned by the individuals behind Asia Sun Group, distributed aviation fuel to military air bases from December 2021 to at least August 2022.

NAYARA ENERGY AND TRAFIGURA

Nayara Energy and Trafigura both said they had not been involved in any shipment of Jet A-1 to Myanmar since the military coup of February 2021. Nayara Energy said that it could not provide any information about the shipment identified by Amnesty International, due to “client confidentiality obligations.” But also stated that “out of an abundance of caution and in line with its commitments …, Nayara Energy is committed to not supplying fuel to any parties in Myanmar”.

VOPAK

Vopak [...] explained that Vopak’s role as PITSB’s shareholder is the “safe storage of our customers’ products while it is in our terminals.” It did not disclose the name of its customer, the supplier of the aviation fuel.

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EXXONMOBIL

ExxonMobil is linked to a vessel that onloaded fuel at ExxonMobil’s berth (OM5) in Singapore and subsequently travelled to Myanmar where it offloaded it at the PEAS terminal in Thilawa port. When asked about this shipment, ExxonMobil only said that “[a]ny potential sale of aviation fuel related to Myanmar would be conducted in accordance with applicable law”. [...]

CHEVRON, ROSNEFT AND THAI OIL

Chevron, Rosneft and Thai Oil acknowledged having supplied Jet A-1 to a customer in Myanmar, although only Rosneft mentioned the name of its customer. According to Amnesty International’s findings, Chevron’s and Rosneft’s customer was NEPAS while Thai Oil’s customer was Asia Sun Trading. In the three cases, the suppliers stated that the customer gave them assurances that the fuel would be used for commercial purposes only.

Chevron provided that it “only sold one parcel of Jet A-1 fuel to a customer in Singapore that was ultimately delivered to Myanmar. This was loaded at SRC in Singapore and shipped on board the Super Hero in February 2022 for delivery in Myanmar. The customer in Singapore provided assurance that the Jet A-1 fuel was for commercial purposes only.” In a subsequent communication, Chevron added that it “ascertained that the jet fuel was to be supplied by the importer of the jet fuel to a commercial airline under a term supply contract”.

Rosneft was more explicit about the aviation fuel it sold, stating that “the shipment you mentioned earlier had been offloaded at the Puma Energy Asia Sun Co. Ltd. terminal in Thilawa area port to the benefit of National Energy Puma Aviation Services — the end user of the fuel.” The company later added: “We are confident of impeccable end-user reputation and we have no doubts about an accurate operation by Puma Aviation. The shipment you mentioned was used, exclusively and entirely, for civil aviation last year and bears no relation to your assumptions.” Amnesty International followed up with Rosneft asking them to clarify on what basis they could confirm that the aviation fuel sold by them was “exclusively and entirely” used for “civil aviation”. Rosneft did not respond to this point but reaffirmed its assertion that they “sell to credible market buyers who have an impeccable reputation, operate in line with global standards and adhere to all international legal requirements.”

Rosneft also explained to Amnesty International that “Myanmar’s aviation fuel consumption averages some 100,000 tonnes per year. For your information, we would also like to advise you of Myanmar’s own capacity (1.1 million tonnes) producing all types of fuel, including jet fuel. This, among other things, confirms the fallacy of your conclusion about the use of products for military purposes.” Amnesty International followed up to obtain a source for this information, but Rosneft did not provide it. Further, as stated above, media reports indicate that currently Myanmar does not produce aviation fuel domestically.

Thai Oil also relied on its customer’s assurances: “prior to the supply of the fuel, our responsible unit obtained binding written contractual warranties and undertakings from its customer in Myanmar that the fuel being purchased and delivered is and will be solely and ultimately for the purpose of commercial and civilian use in Myanmar, and that in no event will the fuel be used for any military purpose whether in Myanmar or otherwise.”

SINGAPORE PETROLEUM COMPANY

Singapore Petroleum Company, wholly-owned by PetroChina, did not respond to Amnesty International’s letters. Nevertheless, Amnesty International was able to definitively link it to at least one shipment of aviation fuel transported from the SRC terminal in Singapore to the PEAS terminal in Thilawa in December 2021.

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VESSEL OWNER

Although every vessel featured in this report has its respective owner, Amnesty International has only disclosed the owner of two of these vessels, Super Hero and Super Infinity, as they are linked to three separate shipments of Jet A-1 to Myanmar. Korean shipping company Pan Ocean is the owner of the two vessels.

Pan Ocean did not respond to any of Amnesty International’s letters. [...]

SHIPPING AGENT

Although several shipping agents were likely used to manage the various Jet A-1 shipments that arrived at PEAS terminal in Thilawa port, only one shipping agent is featured in the report, Wilhelmsen Myanmar. This is because we have stronger evidence linking this company to shipments managed by PEAS and NEPAS.

Wilhelmsen acknowledged that its entity in Myanmar acted as “Owner’s Protective Agent for tankers discharging aviation fuel at the PEAS terminal in Thilawa port with HS Code: 10198210 Aviation Turbine Fuel (Jet A-1)”. It said that “[i]n this capacity, WSS Myanmar act as Owner’s Representative on behalf of the vessel owner/operator for the transmission of proforma disbursement accounts and port captaincy on the berth.”

Although Wilhelmsen did not specify which shipments of Jet A-1 it was involved in, it stated that “[t] he aviation fuel imported to PEAS Terminal for NEPAS is clearly described for domestic airline sales only.” As this report shows, however, even if the import is “described” as being for commercial use, the aviation fuel may in fact be ultimately used by the Myanmar military.

In response to Amnesty International’s findings, which were shared with Wilhelmsen prior to the publication of this report, the company stated on 18 October 2022 that it was going to stop handling jet fuel in Myanmar:

“Having thoroughly reviewed the latest information provided by Amnesty International with our case handling team, our ships agency colleagues in Myanmar, and senior management, we have determined that Wilhelmsen Ships Service Myanmar will not risk contributing in any way towards the human rights violations outlined by your report.

Therefore, Wilhelmsen Ships Service Myanmar will immediately cease to provide agency services of any kind for vessel or cargo owners discharging Jet A-1 aviation fuel at ports in Myanmar, irrespective of designations regarding end use. This will remain the case until further notice.”

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MARINE INSURERS

Amnesty International identified and wrote to the P&I clubs that provide insurance to each of the vessels identified in this report; five of the parents companies of the clubs are UK based.

(Note: Footnote 434 provides: The following P&I clubs provided insurance to the vessels at the time they transported aviation fuel: UK Mutual Steam Ship Assurance Association (Bermuda) Ltd. affiliated to UK P&I (Yu Dong); Japan Shipowners Mutual Protection & Indemnity Association affiliated to Japan P&I Club (Santya); Steamship Mutual Underwriting Association (Bermuda) Ltd. affiliated to Steamship Mutual (Swarna Mala); QBE Asia Pacific (Synergy); The Britannia Steam Ship insurance Association Ltd. associated to Britannia P&I (Super Hero); Shipowners Mutual Protection & Indemnity Association (Luxemburg) affiliated to Shipowners’ Club (Bhureemas); and North of England P&I Association affiliated to UK North P&I Club (Super Infinity). See Lloyds vessel reports and IHS Seaweb.)