WHEREAS: The United States and EU have imposed extensive sanctions and export controls against the  Russian state and its owned and affiliated businesses in response to the invasion of Ukraine.[1][2] On September 21, Vladimir Putin announced a “partial mobilization,” requiring all public and private organizations to assist in the conscription of eligible employees and provide material means to support the war effort[3];
The Royal United Services Institute (RUSI) reported that TI and Analog Devices were the original manufacturers of approximately 25% of the dual-use items found in 27 Russian weapons systems used in the invasion, including cruise and ballistic missiles, precision munitions, and electronic warfare. RUSI notes that “US exporters of these products [had] a due-diligence obligation to make sure they were not destined for a prohibited end user, or to be used in prohibited end use.”[4]
Iranian “kamikaze” drones, governed by export restrictions and used by Russia against Ukraine, contain circuit boards with TI processors.[5] Reports indicate these drones are being used against civilians and energy infrastructure, exacerbating the humanitarian crisis. [6]
The use of TI’s products during the Russian invasion of Ukraine may result in heightened human rights and financially material risks through potential violations of American and EU sanctions and export controls, the United Nations Guiding Principles (UNGP) on Business and Human Rights, and TI’s human rights policies, as well as complicity in Russia’s war crimes.[7]  
Because human rights risks can be particularly acute in conflict-affected and high-risk areas (CAHRA), characterized by widespread human rights abuses and violations of national or international law, the UNGPs call for heightened due diligence. The International Finance Corporation states that companies in CAHRA “face business risks . . . much greater than those in other emerging markets,” including destruction of assets, deaths and injuries, weak state control, lack of security, and supply-chain disruptions.
To mitigate risks associated with customer conduct, companies undertake “Know Your Customer” (KYC) due diligence coupled with sanctions compliance programs.