CAHRA are increasing globally, with 30 percent more people killed in 2024 than 2023 and conflict reaching its highest level since World War II.2 A survey of 1,200 CEOs indicates 97 percent altered investment plans due to geopolitical volatility.3 Another study found 84 percent of the world’s 26 largest investors identified “geopolitical confrontation” as a top three systemic risk.4 Meanwhile, surveillance technologies have proliferated, particularly in CAHRA, with a projected $235 billion market valuation in 2027, nearly double that of 2022.5 Dell’s Human Rights Policy (HRP) commits to responsible innovation and artificial intelligence “that prioritizes ethical considerations, societal impact, and long-term sustainability.”6 But research indicates Dell provides products and services to customers in CAHRA, which may contribute to violations of international humanitarian law (IHL) and HR. Dell reportedly works with state-owned Chinese Academy of Sciences’ Institute of Automation (CASIA), which has been linked to the development of surveillance technology used by the Chinese government, particularly in Xinjiang Uyghur Autonomous Region. Dell reportedly works with CASIA to develop data processing, biometric recognition, and voice recognition, enhancing state-run surveillance and censorship and exposing Dell to China’s documented HR harms.7 Dell provides servers and related services to the Israeli Ministry of Defense and Israel Defense Forces, including through a 2023 tender, exposing the company to allegations of facilitating HR abuses and IHL violations perpetrated by Israeli forces in Gaza.8 Dell’s venture capital fund9 has backed Flolive, which is entwined with hacking and spyware developer Circles Bulgaria.1011 Circles has been implicated in privacy violations and numerous HR harms in CAHRA including Honduras, Nigeria, Serbia, and Zimbabwe.12 Circles also supplies software exploits that facilitate remote access to personal devices for spyware maker NSO Group, sanctioned by the U.S. and successfully sued by Apple.13 Dell’s HRP states its approach to innovation “encourages transparency and accountability,” and commits to conducting HR impact assessments. However, there is no information on how company investments in surveillance, or military and surveillance uses of its products and services in CAHRA, expose the company to HR risks. The requested report will provide investors with meaningful insights into the company’s governance of these material risks.