WHEREAS: According to Royal United Services Institute, ADI manufactured 50 components found in 27 Russian weapons systems used in the invasion, including cruise missiles, reconnaissance drones, and other targeting systems.[1] The KSE Institute reports that in the last five months of 2023, ADI has been the second top producer of critical components for Russian drones and Iranian “kamikaze” drones;[2]
Thirteen of these components are classified as “dual-use,” creating a “due-diligence obligation to make sure they were not destined for a prohibited end-user, or to be used in prohibited end use.”[3] However, reports implicate ADI-supported missiles and drones in attacks against civilians and infrastructure[4] in violation of international humanitarian law;[5]
Between April 1, 2022 and June 30, 2023, third-party intermediaries in China and other Asian states exported 72,312 shipments worth $299.6 million of ADI's products to Russian companies sanctioned at the time of sale;[6]
Since CAHRA are characterized by widespread human rights abuses and violations of national or international law, the UN Guiding Principles on Business and Human Rights (UNGPs) call for hHRDD;[7]
CAHRA also include more financially material risks. The International Finance Corporation states that CAHRA “face business risks that are much greater than those in other emerging markets,” including destruction of physical capital, deaths and injuries, weak state control, and supply-chain disruptions.[8] A survey of 1,200 CEOs indicated 97 percent of respondents altered investment plans due to rising global tensions and over one-third relocated operations based on conflict-related risks.[9] The US and EU imposed an unprecedented array of sanctions and export controls[10] against Russia and state-owned businesses in response to the invasion;[11]
ADI trails industry peers’ measures to mitigate these risks, including Qualcomm’s Human Rights Working Group, human rights impact assessments, and identification of “product misuse” as a salient risk and Intel’s human rights steering committee and customer screening based on human rights risks; and
The use of ADI’s products in CAHRA may result in human rights and material risks through violations of regulatory measures, the UNGPs, and ADI’s human rights policies, and complicity in Russia’s violations of international law.
 
[1] https://static.rusi.org/RUSI-Silicon-Lifeline-final-updated-web_1.pdf
[2] https://kse.ua/wp-content/uploads/2023/08/230823-Drones-for-KSE-site.pdf
[3] https://static.rusi.org/RUSI-Silicon-Lifeline-final-updated-web_1.pdf 
[4] https://www.business-humanrights.org/en/latest-news/ukraine-missiles-used-in-attack-on-uman-that-killed-23-civillians-contain-western-made-components/
[5] https://www.washingtonpost.com/world/2022/12/02/drones-russia-ukraine-air-war/
[6] https://www.exportgenius.in/
[7] https://www.undp.org/publications/heightened-human-rights-due-diligence-business-conflict-affected-contexts-guide
[8] https://www.ifc.org/wps/wcm/connect/07cb32dd-d775-4577-9d5f-d254cc52b61a/201902-IFC-FCS-Study.pdf?MOD=AJPERES&CVID=mzeJewf
[9] https://assets.ey.com/content/dam/ey-sites/ey-com/en_us/topics/ceo/ey-ceo-outlook-pulse-survey-january-2023-global-report.pdf
[10] https://home.treasury.gov/news/press-releases/jy0608
[11] https://www.theguardian.com/world/2022/sep/23/russia-has-committed-war-crimes-in-ukraine-say-un-investigators