Grasping the nettle: Ending Europe’s Trade in Execution and Torture Technology 17 Above: “PKI 9360 stun-cuffs for hands” which has been promoted by PKI Electronic Intelligence GmbH. According to the catalogue the handcuffs have a maximum range of 300 metres and the “electric shock will only be released if it is activated by the security personnel with the encoded remote transmitter.” They can only be removed by security staff. 56 Following enquiries by Amnesty International and Omega, in January 2012 a representative from PKI Electronic Intelligence GmbH stated that the company had “never sold PKI 9355 / PKI 9360 [stun-cuffs]”.57 Although the PKI representative also stated that, “We have deleted electric shock batons from our product range and replaced [them with] non electric devices,”58 the company gave no indication of whether it produced stun cuffs, nor detailed the number of devices it possessed (if any) nor provided any details of whether it would continue to promote such devices. On 27 April 2015 in further correspondence to Amnesty International and Omega regarding the PKI 9360 stun cuffs, the company stated that: “PKI Electronic Intelligence GmbH has neither manufactured nor sold the products in question, although these products are displayed on our website. We are still working on a new catalogue, these items won’t be offered anymore.”59 Subsequent analysis of PKI’s website shows that although the PKI catalogue is no longer available, the company has continued to promote these devices – employing essentially the same descriptive text and images on its website - up until at least 14 May 2015.60 Correspondence from the Federal Office for Economic Affairs and Export Control (BAFA) dated 8 May 2015, in response to Amnesty International and Omega’s request for information regarding the promotional activities of PKI Electronic Intelligence GmbH, (and Clemen & Jung - see below), stated that, “BAFA enforces the prevailing legal norms and is bound by them. Right now neither the European nor the German export control law prohibits the promotion of goods controlled by annexes II or III of Council Regulation (EC) No 1236/2005. Hence, as of now BAFA has no means to interfere with the promotional activities of the mentioned companies…Only when the company attempts to export the goods in question beyond the borders of the customs territory of the European Union BAFA will get involved.” 61 56 PKI Electronic Intelligence GmbH website, http://www.pki-electronic.com/catalogue/downloads_en/PKI_Anti_Terror_Equipment_2010. pdf (accessed 26 June 2012) p.155 57 Email correspondence from a representative of PKI Electronic Intelligence GmbH, 9 January 2012 (copy on file with the authors) 58 Email correspondence from a representative of PKI Electronic Intelligence GmbH, 9 January 2012 (copy on file with the Omega Research Foundation). 59 Email correspondence from a representative of PKI Electronic Intelligence GmbH, 27 April 2015. 60 http://www.pki-electronic.com/products/police-customs-and-military-equipment/stun-cuffs-for-foot-stun-cuffs-for-hand/ (accessed 14 May 2015). 61 Email correspondence from the German Federal Office of Economics and Export Control (BAFA), 8 May 2015. Index: EUR 01/1632/2015 Amnesty International May 2015