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| UK Criteria | EU Code of Conduct
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| Will take into account respect for human rights and fundamental freedoms in the recipient country.
| having assessed the recipient country's attitude towards relevant principles established by international human rights instruments.
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| will not issue an export licence if there is a clearly identifiable risk that the proposed export might be used for internal repression.
| not issue an export licence if there is a clear risk that the proposed export might be used for internal repression.
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| . . . equipment which might be used for internal repression will include: equipment where there is clear evidence of the recent use of similar equipment for internal repression by the . . . end-user . . .. Equipment which has obvious application for internal represion in cases where the recipient country has a significant and continuing record of such repression, unless the end use of the equipment is judged to be legitimate, such as protection of members of security forces from violence.
| equipment which might be used for internal repression will . . . include equipment where there is evidence of the use of this or similar equipment for internal repression by the . . . end-user.
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| In some cases the use of force by a government within its own borders does not constitute internal repression. The use of such force by government is legitimate in some cases eg to preserve law and order against terrorists or other criminals. However force may only be used in accordance with international human rights standards
| no equivalent |
| no equivalent | The internal situation in the country of final destination . . .. Member states will not allow exports which would provoke or prolong armed conflicts or aggravate existing tensions or conflicts in the country of final destination
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| . . . will not issue an export licence if there is a clearly identifiable risk that the intended recipient would use the proposed export aggressively against another country . . .. However, a purely theoretical possibility that the items concerned might be used in the future against another state will not of itself lead to a licence being refused.
| will not issue an export licence if there is a clear risk that the intended recipient would use the proposed export aggressively against another country . . .
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| The need not to affect adversely regional stability in any significant way will also be considered. The balance of forces between neighbouring states, their relative expenditure on defence, and the need not to introduce into the region new capabilities which would be likely to lead to increased tension, will all be taken into account.
| EU member states will take into account . . . the need not to affect regional stability in any significant way.
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| In assessing the impact of the proposed export on the importing country . . . the following will be considered . . . the technical capability of the recipient country; whether the purchase would seriously undermine the economy of the recipient country . . .
| The compatibility of the arms exports with the technical and economic capacity of the recipient country, taking into account the desirability that states should achieve their legitimate needs of security and defence with the least diversion for armaments of human and economic resources . . . whether the proposed export would seriously hamper the sustainable development of the recipient country.
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| The risk of the arms being re-exported or diverted to an undesirable end-user including terrorist organisations . . .
| The existence of a risk that the equipment will be diverted within the buyer country or re-exported under undesirable conditions [the following will be considered] . . . the capability of the recipient country to exert effective export controls; the risk of the arms being re-exported or diverted to terrorist organisations .
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