In contrast, the German company NOWAR® security equipment GmbH – which specialises in “development, production and sale of equipment to Police, Justice, Army and private Security Firms at home and abroad”214 – as of January 2018, continued to promote thumb cuffs on its website. It described its products as “suitable for plainclothes policemen or in addition to handcuffs. Owing to the compact style it can be worn in each trouser pocket and can be carried along inconspicuously.”215 5.2.2.2. Promotion of thumb cuffs in CoE arms and security fairs Non-CoE companies have also been documented promoting thumb cuffs at CoE arms and security exhibitions. Two Chinese companies, Jinniu Police Equipment Manufacturing Co. Ltd, and Jiangsu Anhua Police Equipment Manufacturing Company Ltd promoted thumb cuffs at Milipol 2015, whilst another Chinese company, China Xinxing Import & Export Corporation, promoted thumb-cuffs in its product catalogue distributed at Eurosatory 2016 in Paris, France in June 2016.216 Image of thumb cuffs taken from Shan Chun Company Ltd promotional page on IWA Outdoor Classics 2018 website. The website for the German security and recreational shooting exhibition, IWA Outdoor Classics 2018, provided details of the Taiwanese company, Shan Chun Company Ltd, and its products, on its exhibitor and product listing pages.217 The products promoted by the Taiwanese company included thumb cuffs. The promotion of such devices on a European company website appears to breach EU Regulation 2016/2134. The Omega Research Foundation has written to both Shan Chun Company Ltd and to IWA alerting them of this matter. Following this correspondence, a holding answer was received from IWA, and the images were subsequently removed from the IWA website.218 5.2.2.3. Recommendations  CoE member States should prohibit the manufacture, promotion, import, export, brokering or other transfer of thumb or finger cuffs intended for use by prison or law enforcement officials. The use of such restraints by CoE law enforcement and prison officials should be prohibited, and all existing devices should be removed and verifiably destroyed. 214 Company profile, Norwar, available at http://www.nowar.de/profil_uk.htm (accessed 28 November 2017). Nowar catalogue, available at http://www.nowar.de/katalog/standard/001_pers_equipment_accessoires/114_hand_und_fussfesseln/nowar_dau menfessel/dauemfessel_uk.htm (accessed 18 January 2018). 216 Company brochures on file with the Omega Research Foundation. 217 Shan Chun Company Ltd products, as displayed on: Exhibitors & Products IWA Outdoor Classics 2018 website, https://www.iwa.info/en/ausstellerprodukte/iwa18/product-9939757/batons-handcuffs-foot-shackles (accessed 30 November 2017; images subsequently removed). 218 Correspondence from the Exhibitions Executive Director and Sales Manager, IWA Outdoor Classics to the Omega Research Foundation, 22 December 2017. 215 45

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