On 22 December 2025, the Business & Human Rights Centre invited Memento Labs (formerly Hacking Team) to respond to our guide for investors "Hidden risk is the most expensive: What investors need to know about high-risk surveillance technology".

For all of the allegations mentioned in the guide, companies had previously been contacted to provide a response either by the BHRC or the authors of the piece cited. However, we wanted to provide companies with the opportunity to give any updates on addressing individual cases or changes made at the systemic level to avoid similar cases from arising. Furthermore, we invited companies to respond to the due diligence questions (starting on page 31 of the guide) that responsible investors should ask of investee companies that develop or sell high-risk surveillance technologies.

Memento Labs (formerly Hacking Team) responded stating the following:
"...From the beginning of Memento Labs the company was completely restructured in attitude and posture. It has a completely new governance, brand new product, brand new team, brand new customers.

The continuous presentation as just a rebranding, especially after 7 years, is absolutely not reflecting the reality.

Any approach to potential foreign intelligence and/or law enforcement agencies is verified first with according to our internal Compliance Program that is continuously updated on sanction, political rights, etc.. Only at the end of this process, we explore the request received from a specific potential customer..."

Memento Labs, however, did not respond to any of the due diligence questions intended for investors to more adequately assess corporate governance and respect for human rights. Read the full response below.