From 2023, this article contains a change log, with a chronology of all changes made in the list. Find that log at the bottom of the article.

The list below is ordered at three levels of gravity, in terms of how serious WSRW assess the negative consequences of their involvement. The ordering is roughly done, based on a) the role of the company in the operation; b) the type of involvement (resource extraction, strategic infrastructure construction etc); c) the length/scope of the involvement.

1. PARTICULARLY SERIOUS INVOLVEMENT

OCP S.A., Morocco/Ireland
OCP is a state-owned Morocco phosphate production and export company. Most of OCP’s operations are uncontroversial, located within the internationally recognized borders of Morocco. One mine, however, is located in occupied Western Sahara. The Bou Craa mine has been operated by OCP since 1975. OCP’s bonds were floated on the Irish Stock Exchange in 2014.
The controversies, volume and value of OCP’s exports of phosphate rock from Western Sahara, is covered in the annual reports from Western Sahara Resource Watch called P for Plunder. Through the operation of the mine in Western Sahara, OCP is a key source of illegal income for the Moroccan government in the territory that it occupies.

Delek Group Ltd, Israel
Its subsidiary, NewMed Energy, on 6 December 2022 announced the signature of a gas exploration and production agreement offshore Boujdour, Western Sahara. Drilling is to take place within 2,5 years. The company's licence was condemned by Polisario in June 2023. 
NewMed has obtained a 37.5% stake in the license partnership, while the Moroccan government holds 25% and a private company holds 37,5%.
NewMed Energy was in November 2022 in the process of merging with Capricorn Energy - previously called Cairn Energy - which had ownership on the same Boujdour block. The merger plans later seemed to be abandoned.
The Norwegian government pension fund - which was possibly the second largest investor in the company - on 18 December 2023 announced the exclusion of the company from its portfolio due to the controversy in Western Sahara, with a 15 page explanation as to why.  
WSRW wrote Delek Group on 24.12.2022. Delek's subsidiary NewMed responded on 26.12.2022, but failed to answer follow-up questions sent 26.12.2022, 26.01.2023, 16.05.2023.

Ratio Petroleum, Israel  
Signed the 109,900 sq.km Dakhla Atlantique offshore block with the Moroccan government in October 2021, with option to be extended. Traded on the Tel Aviv Stock Exchange. The company consistently refers to the territory as part of Morocco. See press release from Ratio 26 Sept 2021 and extension 6 Oct 2022. In 2023, Ratio's subsidiary Ratio Gibraltar together with ONHYM submitted a request to extend the exploration agreement for another year to the Moroccan Ministry of Energy. The approval from the ministry for the extension of the research agreement was received by the company in October 2023. Ratio Gibraltar currently re-interprets 3D seismic data. Presently, according to its website, Ratio Petroleum partnership holds a 70% stake in the block. In 2022, it took in the energy company Navitas as partner to the licence. WSRW has not yet written the company.  

Navitas Petroleum, Israel
In 2022, Navitas entered into the Dakhla Atlantique licence, where Ratio Petroleum is operator. The company issued itself an announcement of 19 June 2022 to enter into the Dakhla block in "Morocco". Navitas is traded on the Tel Aviv Stock Exchange and has offices in USA and Israel. WSRW has not yet written the company.  

Incitec Pivot Ltd, Australia
In October 2022, the company received a shipment of phosphate rock from occupied Western Sahara. The company used to import through long-term contracts until 2016. From December 2016 to September 2022, no shipments took place to Incitec. Upon ending its imports in 2016, Incitec never responded to questions from WSRW nor from investors whether it would guarantee that no further imports would take place in the future. 
WSRW wrote the company on 20 September 2022. The company confirmed receipt of the letter, but failed to reply. WSRW wrote Incitec again on 24.09.2022, 06.02.2023, 04.05.2023, 16.09.2023 without response. The company confirmed to an Australian trade union on 27 Sept 2022 that the vessel was indeed for Incitec. 

Siemens Energy AG, Germany and Siemens AG, Germany
Siemens AG in 2012 announced that it had won several tenders of the Moroccan government for construction of wind parks in occupied Western Sahara. The parks are commissioned by Morocco’s national agency for electricity, ONEE. Siemens collaborates on all projects with the Moroccan wind energy company NAREVA – which is owned by a holding company of the King of Morocco. Several new projects have been won and commenced since 2012. 
Most controversial of all the Siemens constructions, is the Foum el Oued wind park raised in 2013. Foum el Oued, consisting of 22 wind mills, today supplies 95% of the energy needs of the phosphate mine of Phosboucraa. In other words: practically all energy required for the exploitation and transport of the phosphate rock in Western Sahara, is generated by wind mills delivered by Siemens. The green energy production is thus making Morocco’s plunder of the territory even more lucrative.
In 2016, Western Sahara Resource Watch (WSRW) wrote a report on Siemens’s operations in Western Sahara. In 2018, Siemens built the 200 MW wind farm Aftissat in the occupied territory.
Siemens has failed to answer questions on whether it has obtained consent from the representatives of the Saharawi people, both in letter correspondence by WSRW, by investors, and by shareholders at the AGM.
In September 2020, Siemens Gamesa announced that it had entered into a new agreement for a park in Boujdour in what it refers to as “Southern Morocco”. WSRW condemned the operation and the lack of will to address concerns of international law, and changed recommendation to investors from engagement to divestment. Questions raised at the AGM in 2021 and 2022 were not answered. 
Siemens Gamesa's shipments of masts into the territory for the Boujdour licence started in July 2021 and the park was finalised in July 2023. 
In 2023, all shares of Siemens Gamesa had been taken over by Siemens Energy AG, and Siemens Gamesa was delisted from the Spanish Stock Exchange. As of 2024, Siemens AG controls 17% of Siemens Energy AG. 
In 2024, Siemens Gamesa expressed an interest in an EPC tender for the Moroccan government's HVDC project that will transport energy generated from renewable power plants in occupied Western Sahara to Morocco's economic heartland, Casablanca.
WSRW wrote Siemens AG on 06.03.2012, 19.06.2012, 03.07.2013, 26.09.2016, 07.12.2017, and received response from Siemens AG on 10.05.2012, 10.10.2016, 08.01.2018. WSRW wrote Siemens Gamesa, 01.10.2018 and 20.08.2021. Siemens Gamesa wrote WSRW on 16.11.2018, 24.04.2020, 07.04.2021 and 27.09.2021. WSRW wrote Siemens Energy on 18.02.2021, 30.11.2023 and 20.11.2024. Siemens Energy wrote WSRW 23.03.2021 and 03.12.2024.
Siemens Energy was confronted over the matter at the AGMs in 2021, 2022, 2023, and 2024. Siemens Gamesa at the AGM in 2022 and 2023, and Siemens AG at the AGMs in 2017, 2018, 2020.

Enel SpA, Italy
Enel has since 2012 taken part part in the construction of wind parks. Its 100% subsidiary Enel Green Power Morocco has entered into a holding company called “Nareva Enel Green Power Morocco” (NEGPM) with Nareva – the energy company owned by the Moroccan monarchy – to develop, build and operate 5 wind farms under the 850 MW Integrated Wind Project. Two of these farms, of a combined 400 MW, will be in occupied Western Sahara: the 300MW Boujdour wind farm and the 100 MW Tiskrad Wind Farm. 
The Tiskrad Wind Farm is still in permitting stage. The Boujdour farm was completed in July 2023. To implement the Boujdour wind farm, NEGPM created a joint venture with ONEE. On Nareva’s website, this joint venture is referred to as the Boujdour Wind Farm, but the document creating it, as published by the Moroccan Conseil de la Concurrence refers to it as “Société de Projet Boujdour”. 
A similar joint venture will be created for Tiskrad.
As such, Enel co-owns all projects under the 850MW Integrated Wind Project, including the two in occupied Western Sahara. 
It is NEGPM which as the developer consortium placed the order for the 301MW turbines with Siemens Gamesa. The power generated by each of the wind farms will be sold to ONEE under a power purchase agreement for a period of 20 years.
The role of Enel is described in the report 'Greenwashing Occupation' by Western Sahara Resource Watch (WSRW) in 2021.
WSRW has repeatedly asked the company what steps have been taken to obtain the consent from the people of the territory (see letters 03.07.2013, 27.09.2016, 11.10.2016, 02.06.2020, 03.09.2021). The company has never responded to that key-issue in its letters (see letters 10.10.2016, 30.06.2020 and 13.09.2021). Enel's sustainability reports refer to a so-called 'consultation' process with what it refers to as the local population. As elaborated by the EU Court of Justice on 29 September 2021, this can not replace the act of obtaining consent from the representatives of the people, Polisario.

Voltalia SA, France
In July 2020, Moroccan media wrote that Voltalia had received a contract for a 75 MW wind farm to be constructed in Ghrad Jrad, near El Aaiún. Took part in the desalination tender that was awarded to Engie in 2022. WSRW wrote to the company on 20.07.2020 and 17.06.2021, but has not received a response. 

General Electric Company, United States
GE's subsidiary GE Renewable Energy, announced in a press release on 30 September 2021 that it had received a large contract for the installation of the 200 MW "Aftissat 2" wind park in Western Sahara. In February 2021, the company had been contracted for the delivery of two substations to the 300 MW Boujdour wind farm - described in the company's press release as located in “the south of Morocco”. The substations will evacuate power from the Boujdour farm and from "renewable energy projects in neighbouring communities, as well as connect it to the national grid of Morocco". 
In May 2023, the construction of the Aftissat 2 wind farm was about to be completed.
In 2015, General Electric acquired the power and grid business of the French company Alstom. The latter's equipment and operations have several times been seen in the occupied territory. On 08.12.2020, WSRW reached out to Alstom to inquire whether the firm has a policy in place that will prevent any involvement in projects in occupied Western Sahara, unless with the explicit consent of the Polisario Front as representative of the people of Western Sahara. No reply was received. WSRW also contacted Alstom on 02.07.2013, and got a response on 17.07.2013.
WSRW wrote to GE Renewable Energy on 05.10.2021, 10.11.2021 and 15.05.2023 and has to this point only received this response of 20.10.2021. 
GE Renewable Energy was merged into GE Vernova in 2024. Read more about GE Vernova further down in this article. 
WSRW was also wrote with General Electric in 2013, to request the company to withdraw from a tender on renewable energy. The company responded positively. 

TAQA Group, United Arab Emirates
Its Moroccan subsidiary, TAQA Morocco, has, according to the company itself and according to the Moroccan government interests in energy production in Dakhla. According to a Moroccan government report in 2023, TAQA is to install a renewable energy plant for the production of green hydrogen and derived products (70,000 ha), as well as a 300 megawatt (MW) wind farm on 7,940 ha. TAQA Morocco elaborates on 600 MW plans in a financial report and a media report from 2023, naming the project ‘Boujmil’. 
TAQA bid on the Tiskrad tender in 2013. WSRW wrote the company on 03.07.2013, the company did not reply. 

Société d'Exploitation des Ports SA, Morocco (or Marsa Maroc)
A Moroccan company registered on the Casablanca Stock Exchange, that operates the El Aaiún and Dakhla ports - both key hubs for exports of resources out of the territory. 
WSRW has not yet written to the company. 

Metalex Ventures Ltd, Canada
Metalex has since 2004 had mineral exploration rights in occupied Western Sahara. Metalex is listed on the TSX Venture Exchange. WSRW wrote Metalex on 24.12.2022, 04.05.2023 and 21.08.2023. No answer has been received.

Engie S.A, France
In 2018, the French electric utility company won a tender for a desalination plant in the occupied city of Dakhla. The tender was won in partnership with the company Nareva, which is owned by the Moroccan king's holding company. In May 2023, the Chinese company Envision Energy announced that it will be supplying 60 MW of wind turbines to the wind-powered desalination project, and the construction was already on its way. In September 2023, when the first the windmills entered the occupied territory, Engie announced the location of the operation to be in “Morocco”. It was also clear in September 2023 that the Environmental Impact Assessment - which claims to be addressing legal aspects, totally ignores that the operation is in Western Sahara at all, and speaking uncritically about the future arrival of new immigrants - obviously from Morocco - as consequence of the project. This document has been refered to earlier by Engie as a serious document that supports the establishment of the operation. 
The company supposedly in 2016 signed a comprehensive agreement [or download] with the same Nareva in the renewable energy sector. According to the website thewindpower.net, the company has a co-ownership stake (together with NAREVA) in two wind farms in the occupied territories of Western Sahara: the Foum El Oued [or download] wind farm and the Aftissat [or download] wind farm.
In 2016, according to its own website [or download], Engie announced its participation in a Moroccan university complex 13 km from the occupied capital of Western Sahara, El Aaiún. The company calls the location as “in the Moroccan desert”.
In 2013, the company (at the time called GDF Suez) took part in the tender for the Tiskrad and Boujdour wind parks, but did not win it. WSRW wrote the company on 2 July 2013 regarding its participation in the tender, without receiving an answer. The letter was directed at International Power PLC from the UK - then a subsidiary of GDF Suez, today renamed Engie Energy International, and wholly owned by Engie.
Western Sahara Resource Watch and the French association APSO wrote the company on 11.01.2019 and on 09.12.2020. Engie responded on 13.04.2021. WSRW sent a new letter on 17.05.2021, 22.05.2023 and 22.09.2023. The letter was responded to on 28.09.2023, without the company addressing any of the questions it had been asked. WSRW wrote Engie again on 13.10.2023, responded by Engie 16.10.2023.

2. SERIOUS INVOLVEMENT
 

GE Vernova Inc, United States
GE Vernova, a spin-off of General Electric announced on 31 January 2024 that it had partnered with Morocco's national agency for electricity and water (ONEE) and the Moroccan king's energy firm Nareva in a green hydrogen project in the occupied territory. The company's original press release was removed shortly after being contacted by WSRW.
WSRW wrote GE Vernova on 05.02.2024. The company answered on 14.02.2024, without responding to any of the questions. 
WSRW wrote GE Vernova again on 20.11.2024, in relation to Moroccan media reports that the company had expressed an interest in the EPC tender for the Moroccan government's HVDC project that will transport energy generated from renewable power plants in occupied Western Sahara to Morocco's economic heartland, Casablanca. No response was received.
GE Vernova was formed from the merger of three General Electric businesses in 2024, among them GE Renewable Energy. GE Renewable Energy completed the Aftissat 2 wind farm. Read more about that Aftissat/GE Renewable Energy involvement under the company section of General Electric above. 

Acciona SA, Spain
Part owner of the company ORNX which according to a Moroccan government statement [or download] dated 11 May 2023 is planning to install a wind farm and a green hydrogen production unit in Boujdour over an area of 145,333 ha, in partnership with Nordex SE. Acciona had shown interest for the Tiskrad wind farm in 2013, a tender it did not win. WSRW wrote Acciona at the time, without obtaining a response. Acciona also showed interest in a tender in the occupied territory in 2009. WSRW has not yet contacted the company regarding the ORNX project.

Nordex SE, Germany
Part owner of the company ORNX which according to a Moroccan government statement [or download] dated 11 May 2023 is planning to install a wind farm and a green hydrogen production unit in Boujdour over an area of 145,333 ha, in partnership with Acciona SA. WSRW wrote Nordex on 31.10.2023, but without having received an answer.

Veolia Environnement S.A., France
Veolia, together with fellow French company Voltalia, bid in 2018 to develop a planned desalinisation plant in the occupied city of Dakhla, only to lose out to the Engie-Nareva partnership. See here and here.
The company built a 26,000 m³/day reverse osmosis desalination plant in occupied El Aaiún in 2010 (according to this Veolia presentation from 2017 [or download]). According to a 2013 press release by Veolia, the company tried to “sell its Moroccan water, wastewater and electricity services, operated by concession companies Redal and Amendis” to British private equity firm Actis. Although Veolia and Actis reached a deal the Moroccan Ministry of Interior vetoed this sale. In 2014, the company filed an update on the US Securities and Exchange Commission noting that the sale to Actis was turned down, and the new plan of action would be to sell subsidiaries Redal and Amendis back to the Moroccan government.
Took part in the desalination tender that was awarded to Engie in 2022. 
Veolia took part in a desalinisation conference in El Aaiún in 2008. WSRW received in approximately 2015 a picture of what appears to be Veolia equipment in Western Sahara.
WSRW asked the company in December 2020 whether it has any policies in place to avoid becoming involved in projects in the occupied territory, but has not received any response.
 
Worley Ltd, Australia
The Australian company Worley Ltd. is a co-owner with Phosboucraa of an integrated fertilizer production platform and a new phosphate wharf. The operation is done through a 50/50 joint-venture company with OCP called JESA (Jacobs Engineering SA). The latter is described as a Moroccan construction and engineering firm. JESA has projects in Morocco, and in other African countries. JESA is also described as the project owner of the Foum El Oued Technopole project. In December 2021, it was known that a Worley subsidiary was commissioned regarding a study of a gas pipeline from Nigeria to Morocco via Western Sahara. In September 2022, it was known that the pipeline will cross Western Sahara overland. WSRW wrote to Worley in 09.12.2019, 17.03.2021, 27.12.2021 and 05.05.2022, and 22.09.2022, but has not yet received a response. 

Caterpillar Inc., United States
Supplies the Bou Craa phosphate mine with vehicules for the mining operation. WSRW wrote the company in April 2020, March 2021, February 2022 (and a reminder of those letters in March 2023), but has never received an answer.

Hitachi Ltd., Japan and ABB, Switzerland/Sweden
Swedish-Swiss company ABB was selected to build the first hybrid substation for a wind farm in Western Sahara. The company declared on 7 July 2017 its operation, but without specifying its location. Find the original press release here.
The work relates to the construction of Morocco’s so-called Aftissat wind farm. ABB confirmed to the association Terre des hommes on 11 June 2018 that the power station was indeed intended for the Aftissat wind farm in Boujdour, Western Sahara. See also NZZ.
ABB’s power grids sector was taken over by Hitachi in 2020. From 1 July 2020, ABB’s ownership in that joint-venture, called Hitachi ABB Power Grids, is 19,9% owned by ABB, with Hitachi owning the remaining 80,1%. WSRW sent a letter to the new joint-venture in August 2020, requesting it to clarify its current contractual obligations in Western Sahara. No reply was received.
A letter was sent from Friends of Western Sahara Japan, terre des hommes schweiz, Switzerland, Emmaus Stockholm, Sweden to Hitachi on 19 December 2019. The company responded that "Negotiations regarding the acquisition of ABB's power grid business are proceeding smoothly. Hitachi is promoting the clearance of competition laws around the world, and advancing as scheduled toward the completion of the acquisition in the first half of 2020. Therefore, we are very sorry we can't answer at this time."

Repsol S.A., Spain
The Spanish oil company has been exporting petroleum products into the occupied territory for a number of years. WSRW documented the trade in annual investigations for the years 2023, 2022, 2021, 2020, 2019. Repsol in 2022 and 2021 also most likely exported gas into the territory. WSRW wrote to Repsol on 21.02.2022. The letter was not responded to.  

Allianz SE, Germany
The German insurance company Allianz has a branch in Dakhla in the occupied territory. Via the social media platforms of Allianz Maroc, the company has repeatedly posted very strong political statements defending the illegal occupation of the territory. WSRW wrote the company on 09.09.2023. 

Heidelberg Materials AG, Germany (formerly HeidelbergCement AG)
Operates a cement factory near El Aaiún, the capital city of Western Sahara. WSRW wrote HeidelbergCement on 01.03.2018, and the company's subsidiary Italcementi on 20.10.2016, 19.02.2017 and 05.12.2017. No response was received.
The matter of Western Sahara was addressed at the company's AGM of 2019, in 2020, 2022 and 2023, but the company did not respond to questions regarding consent of the Saharawi people.

Holcim Ltd, Switzerland (formerly LafargeHolcim Ltd)
Operates a grinding unit for cement in El Aaiún, which started operating in 2017, with a 200.000 tonnes/year capacity. See also NZZ. In 2016, LafargeHolcim took part in the construction of OCP's port terminal in El Aaiún. Its maps fail to draw the international border between Morocco and Western Sahara, and the company refers to the city of Laayoune to be located in "Sud du Maroc". Its 100% owned subsidiary Lafarge Ciments Sahara has address in the occupied territory. LafargeHolcim's subsidiary in Morocco is 50% owned by the Moroccan king's holding company La Mada. WSRW has so far not confronted the company. A letter from terre des hommes to Lafarge on 18 June 2018 was responded to in this way.

Volkswagen Group, Germany
Volkswagen's subsidiary in Sweden, Scania, is offering services for trucks in occupied Western Sahara. WSRW wrote Scania on 14.06.2023 and 12.07.2023. Scania failed to answer most questions in the correspondence. 
In 2015, the Volkswagen subsidiary MAN Diesel & Turbo obtained a contract in the occupied territory by the Moroccan government for four diesel generators with a combined power of 72 MW. WSRW wrote MAN Diesel & Turbo on 26.06.2015. The company responded on 10.07.2015. 

Fugro NV, the Netherlands
The Dutch company Fugro in December 2019 assisted in the laying of a subsea telecom cable offshore Dakhla, despite having promised in 2010 “to abstain from any further involvement in Western Sahara until the political situation has been resolved". Fugro had not obtained consent from Polisario, but stated it had contacted Polisario prior to the engagement. WSRW corresponded with Fugro in December 2019 about the matter. 

Nokia, Finland 
The French company Alcatel Submarine Networks SpA, partially owned by Nokia, laid telecom cables in occupied Western Sahara in March-April 2021 and new works were carried out in 2023 and in 2024 (posters observed hanging in the Dakhla port, and followed by the entry of the vessel to Saharawi waters in March 2024). On 14 April 2021, a letter was sent by the French association APSO, the Finnish Peace Committee and Western Sahara Resource Watch (WSRW) to Alcatel, with copy to Nokia. The letter was not responded to. From what WSRW understands, the Western Sahara republic wrote a protest letter to Alcatel in March 2021.

Larsen & Toubro Ltd, India
The Indian multinational in 2020 erected energy infrastructure near Dakhla. WSRW wrote the company in 2020, without response.
WSRW wrote Larsen & Toubro again on 20.11.2024, in relation to Moroccan media reports that the company had expressed an interest in the EPC tender for the Moroccan government's HVDC project that will transport energy generated from renewable power plants in occupied Western Sahara to Morocco's economic heartland, Casablanca. No response was received.

Deutsche Post DHL Group, Germany
Deutsche Post's subsidiary DHL opened an express branch in El Aaiún in 2016. In media statements and on its website, the company refers to Western Sahara as located in Morocco. The company was challenged about the matter at the 2020 AGM, and commented on the engagement to the newspaper Responsible Investor on 28.08.2020.
WSRW wrote the company on 18.05.2020, but has not received a reply. 

BNP Paribas S.A., France
French bank with office in occupied territory, through its subsidiary BMCI. Complaint lodged by Polisario against the company with the State Prosecutor at the High Court in Paris on 18 October 2018. WSRW has written to the bank on 16.12.2021 but has not received a reply.

Société Générale S.A., France
French bank with office in occupied territory. Complaint lodged by Polisario against the company with the State Prosecutor at the High Court in Paris on 18 October 2018. WSRW has written to the bank on 16.12.2021 but has not received a reply.

Crédit Agricole Group, France
French bank with office in occupied territory. Complaint lodged by Polisario against the company with the State Prosecutor at the High Court in Paris on 18 October 2018. WSRW has written to the bank on 16.12.2021 but has not received a response.

Attijariwafa Bank, Morocco
The Moroccan bank has a large market share in the economy of the occupied territories, they boast of “having almost a 25% market share in the Southern Provinces”[or download], with 8 offices in el El Aaiún, 3 in Dakhla and others in Smara and Boujdour. The bank is reportedly also building a “Dar Al Moukawli” center (business hub initiative by AWB Group) in El Aaiún, and it is opening up a fourth office in Dakhla. Attijariwafa is also focusing on supporting investment project holders as well as SMEs with public markets in the occupied territories. The Attijariwafa bank Group has a market share in the occupied territories of around a quarter in both the distribution of loans and the collection of deposits.
Attijariwafa Bank reportedly gave loans to build the Aftissat wind farm near Boujdour in the occupied territory [or download]. The loans were given to Energie Eoliene du Maroc (75% owned by Nareva) who is developing the Aftissat wind farm.
In 2014 the bank put up a conference to explore and attract the increasing of business activities in the territory [or download]. Main points were the potential for doing businesses mainly in Dakhla and El Aaiún (in the phosphates, fisheries and tourism sectors) and opening up the occupied territories to international businesses. WSRW has so far not confronted the company.

BMCE Bank, Morocco
As of 12 Dec 2018, the Moroccan bank's website lists 8 offices in Western Sahara (4 in El Aaiún, 1 in Smara, 1 in Boujdour, 2 in Dakhla). The bank holds a partnership with the French Chamber of Commerce in Morocco, whereby they jointly train and form people in the finance sector in El Aaiún, and promote a "Club" for small and medium sized enterprises in El Aaiún (see here [or download] and here [or download]). WSCUK confronted the company on 22 January 2019.

Vinci Group, France
The Moroccan government in February 2021 contracted the French company VINCI to construct a 400 kV transmission line between El Aaiún and Hagounia, a location just south of the border between Morocco and occupied Western Sahara. The contract was awarded to VINCI's subsidiary Cegelec. WSRW wrote the company on 30 April 2021. The company responded without commenting on the main WSRW concerns on 17 May 2021. See correspondence here. 
A subsidiary of Vinci, Entrepose, in 2015 carried out onshore oil drilling in Western Sahara on behalf of Irish oil company San Leon Energy. This is the only onshore oil drilling operation ever undertaken in the territory during the 45 years of occupation. In 2013, Vinci's subsidiary Cegelec, was involved in the construction of the Foum el Oued wind farm that supplies the Bou Craa phosphate plant with energy. 

Agence Française de Développement, France
AFD has a dual status, being both a French public undertaking as an EPIC (“Etablissement Public à Caractère Industriel et Commercial”) and a finance company (“Société de Financement”) regulated by the national banking authority (ACPR). It is thus possible to invest in bonds in AFD.
In 2012, AFD signed an agreement with OCP for the financing of a desalination plant dedicated for the basic processing of phosphate rock at the Phosboucraa installations.
WSRW wrote to AFD in November 2020, inquiring as to what policies it has in place to avoid its funding would be used on occupied land - particularly in view of AFD's strategic partnership with OCP SA - but has not received any reply.

Wartsila OYJ ABP, Finland
The company has on two occasions, in 2010 and 2017, struck agreements with the Moroccan government for the production of diesel generated power plants in Western Sahara. The company states it does not see the engagements as any problematic. WSRW wrote the company on 28.09.2010. The company responded on 22.10.2010.

BW Epic Kosan Ltd, Oslo/Singapore
Listed at Euronext Growth, Oslo. Out of all buthane that arrived Western Sahara during the years 2019-2021, approximately half was shipped onboard BWEK vessels. The majority owner is BW Group, with J.Lauritzen A/S holding a minor share. The Norwegian Support Committee for Western Sahara has written BW Group/BWEK on seven occasions from 2020 to 2023, without response. 

3. INVOLVEMENT OF CONCERN

ThyssenKrupp AG, Germany
The company was awarded a contract for the construction of a cement factory in El Aaiún, 2016. WSRW wrote the company in on 09.02.2021. An answer from the company on 22.02.2021 fails to address the questions sent. WSRW wrote again on 07.03.2021, no answer was received.

Booking Holdings Inc, United States
Booking Holdings is branding itself as “the world's leader in online travel”, markets travels to – and accommodation in – Western Sahara, branding it as destinations in “Morocco”. This is done on the sites booking.com, rentalcars.com, agoda.com, priceline.com. WSRW has not yet written to the company. 

Expedia Group Inc, United States
The Expedia group branding itself as “one of the world’s leading travel companies” markets travels to – and accommodation in – Western Sahara, branding it as destinations in “Morocco”. This is done on the sites Expedia.com, Vrbo.com, Hotels.com, Hotwire.com, Orbitz.com, Travelocity.com, Trivago.com and CarRentals.com. WSRW has not yet written to the company.

Kosmos Energy Ltd, USA
Kosmos Energy maintains its website www.westernsaharaoil.com on which it describes its approach to the Western Sahara conflict, even after it terminated its interest on the Boujdour Maritime licence.
Kosmos’s first engagement in Western Sahara began in 2004, on a license later to be called Boujdour Maritime. Its operatorship in that license was terminated, and the company withdrew from Western Sahara, on 21 December 2017. According to a statement by the Moroccan state oil company ONHYM in January 2018, it can be interpreted that Kosmos has left the door open to return to Western Sahara.
In 2016, one of Kosmos Energy’s biggest owners, the Norwegian Government Pension Fund Global, excluded Kosmos due to “particularly serious violation of fundamental ethical norms” due to the oil exploration in the territory.
Kosmos in 2014-2015 undertook the first ever oil drilling in Western Sahara waters since the occupation of the territory in 1975. Western Sahara Resource Watch in 2014 wrote a report about Kosmos Energy’s upcoming drilling operation. 

Vestas Wind Systems A/S, Denmark
Vestas has been consulted in relation to the Harmattan (formerly Soluna) bitcoin energy project near Dakhla in 2020, regarding a single turnkey engineering, procurement and installation assignment. WSRW wrote Vestas on 31.03.2020 regarding the matter. The company responded in a letter dated 26.10.2020 in vague terms that it “follows local and international law” without clarifying further. WSRW wrote Vestas again on 05.05.2020 to ask for clarifications, and has since not obtained a response.  
Vestas took part in a tender in 2013 for construction of two wind farms in the occupied territory. WSRW wrote Vestas on 02.07.2013 and got this response on 09.07.2013. 

Air France-KLM Group, France/Netherlands
Subsidiary Transavia, operates flight Paris-Dakhla. Complaint lodged by Polisario against the company with the State Prosecutor at the High Court in Paris on 18 October 2018. WSRW wrote to the company in December 2020, following the announcement by the EU Commission that Western Sahara was not part of any EU aviation agreement. The company did not respond.

Ryanair Holdings PLC, Ireland
The airline announced in November 2024 that it was to operate flights from Lanzarote/Madrid to Dakhla from January 2025. WSRW wrote the company on 18.11.2024. No answer is received.

Air Arabia PJSC, United Arab Emirates
As of 2020, the company operates a flight route between Casablanca and Dakhla. The route is also mentioned in this Moroccan government document. WSRW wrote the company on 19.11.2024. No answer is received. 

Orange S.A., France
In its website [or download], Orange SA’s Moroccan subsidiary Orange Maroc states having 7 offices in El Aaiún (or Laayoune, Western Sahara’s occupied capital), 1 office in Boujdour, 1 office in Smara (or Essmara on its website) and 2 offices in Dakhla.
Data of coverage quality in the aforementioned locations suggests that Orange Morocco has substantial infrastructure [or download] in Western Sahara. As recently as 2017, it promoted events and cultural activities that legitimize the military Moroccan occupation of Western Sahara, and uses Moroccan colonial maps that merged Western Sahara’s occupied territories with Morocco.
From July of 2015 French Orange S.A. has controlled 49% in the Moroccan company MédiTel [or download]. From then, MédiTel was rebranded as Orange Maroc (or Orange Morocco in English) to fully include it in the Orange S.A. brand. This acquisition was honouring an investor agreement made in December of 2010 between Orange, Moroccan state-owned Cassie de Depot et de Gestion (CDG) and FinanceCom. (FinanceCom, which later changed name to O Capital, is also the owner of the controversial Moroccan bank BMCE Bank, which has a business operation and extensive presence in the occupied territories of Western Sahara.)
WSRW wrote to the company on 22.05.2023, and has not yet received a response. 

Abengoa S.A., Spain
In 2018, Spanish company Abengoa, together with Saudi ACWA, jointly bid to build a desalination plant in Dakhla, occupied Western Sahara. According to Africa Intelligence, the duo was disqualified from the tender. Abengoa’s 2017 Annual Report (page 46), makes reference to a water project in Dakhla, without specifying whether it is the same as the tender they are supposed to have lost.
In its website, Abengoa lists itself as having a “Permanent Presence” in Western Sahara. Abengoa’s subsidiary INABENSA also lists Western Sahara as part of Morocco on maps on its website.
According to Abengoa’s 2017 Annual Report (page 46), the company is also involved – through framework contracts – in the development and maintenance of telecommunications infrastructure for Orange and INWI in both fibre optics and GSM, although it is not defined where these projects are. INWI and Orange are both present and operate in the occupied territories of Western Sahara.
Took part in the desalination tender that was awarded to Engie in 2022. 
WSRW has so far not confronted the company.

AXA S.A., France
French insurance company with subsidiary AXA Assurance Maroc operating in occupied territory. Complaint lodged by Polisario against the company with the State Prosecutor at the High Court in Paris on 18 October 2018. 
In 2023, the leadership group of Axa Maroc went on a party trip to the territory, calling it “Morocco”. WSRW contacted AXA in January 2022. The company never responded. 

ARTICLE CHANGE LOG

05.12.2024. Siemens Gamesa, GE Vernova and Larsen & Toubro. Added reference to reported interest in a 2024 tender, and added correspondence. 
19.11.2024. Air Arabia. Added correspondence. 
18.11.2024. Added Ryanair Holdings to the list. 
05.10.2024. Added TAQA Group to the list. 
26.09.2024. Abengoa, Veolia, Voltalia. Added reference to participation in a 2022 tender. 
06.05.2024. Repsol. Documentation added. 
03.05.2024. Nokia. Documentation added. 
30.04.2024. Alstom and Vestas. Old correspondence added. 
30.04.2024. Added the companies Ratio Petroleum and Navitas Petroleum to the list.
20.03.2024: Voltalia. Old, previously unpublished, correspondence added. 
20.03.2024: Vestas. Old, previously unpublished, correspondence added. 
06.03.2024: Siemens Energy. Added correspondence and AGM reference. 
14.02.2024: General Electric. Added correspondence.
05.02.2024: General Electric. Added reference to subsidiary GE Vernova and WSRW correspondence.
19.12.2023: Delek Group. Added reference to Norwegian government pension fund exclusion. 
02.11.2023: Nordex. Added correspondence.
28.10.2023: Added the companies Acciona and Nordex to the list. 
16.10.2023: Engie. Added correspondence. 
13.10.2023: Engie. Added correspondence. 

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