THE COURT OF THE CITIZENS OF THE WORLD

File Number TCCW-1

The PROSECUTOR AGAINST The ACCUSED, VLADIMIR VLADIMIROVICH PUTIN (“VLADIMIR PUTIN”)

I N D I C T M E N T

The Office of the Prosecutor, pursuant to the Statute of the International Criminal Court, particularly Article 8 bis, and the authority of the Rule of Law, charges:

VLADIMIR PUTIN

with the Crime of Aggression, as follows:

1. By actions taken commencing 7 April 2021 and continuing thereafter, VLADIMIR PUTIN, through his de jure and de facto power and authority a person in a position to effectively exercise control over or to direct the political or military action of the Russian Federation, planned, prepared, initiated or executed the Russian Federation’s acts of aggression in Ukraine.

( I ) THE ACCUSED

De Jure Power and Authority

2. VLADIMIR PUTIN is serving his fourth term as the President of the Russian Federation (hereinafter, “Russia”). He was previously President from 1999 to 2008, and has served as President again since 2012. As President, he is the constitutionally designated Head of State, with the de jure authority as guarantor of the Constitution to take measures to protect the sovereignty of Russia, its independence and state integrity; maintain civil peace and harmony in the country; and ensure the coordinated functioning and interaction of public authorities. As President, VLADIMIR PUTIN is constitutionally tasked with determining the main direction of Russia’s domestic and foreign policy, and with representing Russia within the country and in its international relations. As President, VLADIMIR PUTIN is the Supreme Commander-in-Chief of the Armed Forces of Russia. The Federal Law on Security stipulates that state security policy forms part of Russia’s domestic and foreign policy, which the President is required to direct. Under this Law, as President, VLADIMIR PUTIN is also granted the power to determine the main direction of state security and to approve the national security strategy.

3. As the President of Russia, VLADIMIR PUTIN is constitutionally mandated to form the Security Council to assist him as Head of State in exercising his powers on issues of ensuring the national interests and security of the individual, society 3 and the state; maintaining civil peace and harmony in the country; protecting Russia’s sovereignty, independence and state integrity; and preventing internal and external threats. The Federal Law on Security assigns the Security Council several main functions, including:

(1) considering issues of security, organization of defense and other issues related to protecting Russia’s constitutional order, sovereignty, independence and territorial integrity;

(2) developing and refining the national security strategy;

(3) implementing strategic planning on security; and

(4) preparing the President’s draft regulatory legal acts on issues of ensuring security.

The Security Council’s main tasks, as stipulated by the Federal Law on Security, include: (1) providing conditions for the President’s exercise of powers relating to security; (2) forming state security policy and controlling its implementation; (3) developing measures to neutralize security or military threats; (4) preparing proposals for the President on measures to prevent and eliminate emergency situations and overcome their consequences. The Federal Law on Security further provides that the Security Council is chaired by the President and is required to coordinate security activities with him. Regulations of the Security Council are to be approved by the President. De Facto Power and Authority

4. In addition to VLADIMIR PUTIN’s constitutionally-derived authority, his de facto authoritarian power greatly exceeds his constitutional power. 5. VLADIMIR PUTIN exercises absolute power over Russian political and military action in concert with a close circle of trusted advisors, who also have influence over such decisions. These advisors include the other persons who might be accused, several of whom are Members of the Security Council, and trusted highlevel Russian officials with security service backgrounds, known as “siloviki”.

6. VLADIMIR PUTIN’s total authoritarian power is acknowledged by his close advisors. For example, the Accused announced the beginning of a “special military operation” in Ukraine in a speech on 24 February 2022. Kremlin spokesperson Dmitry Peskov stated on 24 February 2022 during a call with media that VLADIMIR PUTIN as the Supreme Commander-in-Chief of the Armed Forces would decide the duration of the military operation in Ukraine: “Deadlines are determined by effectiveness and expediency. These will, of course, be determined by the Supreme Commander”. On 4 March 2022, Dmitry Peskov stated that VLADIMIR PUTIN as the Supreme Commander-in-Chief “receives information” and “makes decisions about how, and by what means to carry out the assigned tasks during that operation”.

7. In practice the exercise of the Accused’s political and military power is very personalized, being characterized not as rule by collective leadership so much as the iron will of his particular personality. In part, the exercise of this de facto power is an expression of the Accused’s preference to prioritize his personal interests over the national interests.

8. By virtue of these roles, powers, and authorities, both de jure and de facto, as the Head of State and as the President of Russia, VLADIMIR PUTIN was and is in a position effectively to exercise control over Russia’s political and military action. ( II ) ACTS OF AGGRESSION BY THE RUSSIAN STATE 4

9. Russia has committed acts of aggression by using armed force against the sovereignty, territorial integrity and political independence of Ukraine. These acts of aggression constitute manifest violations of the United Nations Charter, including Article 2(4), which provides: All Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state, or in any other manner inconsistent with the Purposes of the United Nations.

10. Russia is both a current and an original founding member state of the United Nations and is bound by the conditions of membership, including the provisions of the UN Charter, resolutions of the Security Council, and various other treaties and instruments to which Russia is a signatory. Russia used armed force against the sovereignty, territorial integrity and political independence of Ukraine

11. Russia used armed force against the sovereignty, territorial integrity and political independence of Ukraine. Article 8 bis (2) of the Statute of the International Criminal Court states that any of the following acts, regardless of a declaration of war, qualifies as an act of aggression in accordance with United Nations (“UN”) General Assembly Resolution 3314 (XXIX) of 14 December 1974: a) The invasion or attack by the armed forces of a State of the territory of another State, or any military occupation, however temporary, resulting from such invasion or attack, or any annexation by the use of force of the territory of another State or part thereof; b) Bombardment by the armed forces of a State against the territory of another State or the use of any weapons by a State against the territory of another State; c) Blockade of ports or coasts of a State by the armed forces of another State; d) An attack by the armed forces of a State on the land, sea or air forces, or marine and air fleets of another State; e) The use of armed forces of one State which are within the territory of another State with the agreement of the receiving State, in contravention of the conditions provided for in the agreement or any extension of their presence in such territory beyond the termination of the agreement; f) The action of a State in allowing its territory, which it has placed at the disposal of another State, to be used by that other State for perpetrating an act of aggression against a third State; g) The sending by or on behalf of a State of armed bands, groups, irregulars or mercenaries, which carry out acts of armed force against another State of such gravity as to amount to the acts listed above, or its substantial involvement therein.

12. In summary set out below, the Prosecutor alleges that various acts of aggression were committed, or continue to be committed, in Ukraine, contrary to the Statute 5 of the International Criminal Court, Article 8 bis (2), items a), b), c), d) and g), from paragraph 8, above. 8 bis (2) a : Russia invaded, attacked and occupied the territory of Ukraine

13. First, the Russian Armed Forces invaded and attacked the territory of Ukraine and such invasion and attacks have resulted in military occupation of parts of the territory of Ukraine, according to the meaning of Article 8 bis (2)(a).

14. Russian Armed Forces initiated a major military invasion and attack on Ukraine on 24 February 2022. At approximately 5:00am Ukrainian time, shortly after President Putin declared in a televised speech the start of a “special military operation” seeking the “demilitarization and denazification” of Ukraine, Russian troops crossed the border from multiple directions. Russian strikes and assaults were documented in various cities, including the capital Kyiv, Kharkiv, Ukraine’s second-largest city, and cities ranging from Ivano-Frankivsk in the west to Odesa and Mariupol in the south on 24 February 2022. The Ukrainian government asserted that at least eight had been killed and nine injured by the Russian shelling on the first day of the invasion.

15. The assault and pattern of civilian casualties has continued since. The Office of the UN High Commissioner for Human Rights (OHCHR) reported 18,657 civilian casualties from 24 February 2022 to 29 January 2023, recording 7,110 killed and 11,547 injured.

16. The Russian invasion and attacks on the territory of Ukraine has resulted in the occupation by Russian troops of parts of the territory of Ukraine. For instance, the mayor of Melitopol, a city in Southeastern Ukraine, announced on 1 March 2022 that Russian forces were occupying the city. 8 bis (2) b : Russia bombarded and used weapons against the territory of Ukraine

17. Second, the Russian Armed Forces have bombarded and used weapons against the territory of Ukraine, according to the meaning of Article 8 bis (2)(b).

18. Russian Armed Forces launched an estimated 100 missiles, including a mix of short and medium-range ballistic missiles, cruise missiles, and sea-launched missiles, in the early hours of 24 February 2022.

19. The spokesperson of the UN High Commissioner for Human Rights, Liz Throssell, reiterated on 11 March 2022 grave concern for “the rising death toll and human suffering in Ukraine”. The statement notes the effect of “what appear to be indiscriminate attacks, with Russian forces using explosive weapons with wide area effects in or near populated areas”. Such explosive weapons included “missiles, heavy artillery shells and rockets, as well as airstrikes.” On 14 March 2002, the UN OHCHR, stressed that most of the civilian casualties were caused “by the use of explosive weapons with a wide impact area, including shelling from heavy artillery and multi-launch rocket systems, and missile and air strikes.”

20. Russian forces have conducted missile strikes against targets throughout Ukraine. Some of the Ukrainian cities that have come under heavy Russian bombardments include: Kharkiv, Kherson, Mariupol and Kyiv.

21. According to ongoing and necessarily incomplete tallys of air-related attacks, it is apparent that many dozens of Ukrainian towns and cities and their civilian 6 infrastructure and their civilian citizenry have been hit by aerial bombardment since the start of the invasion. 8 bis (2) c : Russia blockaded the ports and coasts of Ukraine

22. Third, the Russian Armed Forces have blockaded the ports and coasts of Ukraine, according to the meaning of Article 8 bis (2)(c).

23. Russian naval forces established a blockade of Ukraine’s Black Sea coast which effectively isolated Ukraine from international maritime trade. 8 bis (2) d : Russia attacked the land, sea or air forces, or marine and air fleets of Ukraine

24. Fourth, the Russian Armed Forces attacked the Ukrainian Armed Forces and military bases across Ukraine, according to the meaning of Article 8 bis (2)(d).

25. On 24 February 2022, the first day of the invasion, Russian Armed Forces targeted a Ukrainian garrison on the island of Zmiinyi also known as Snake Island situated in the Black Sea.

26. Russian Armed Forces have targeted Ukrainian military bases. For instance, on 14 March 2022, Russian Armed Forces hit Ukraine’s military base in Yavoriv, in western Ukraine, less than 15 miles from the border with Poland, killing 35 people and wounding 134. Russia’s acts of aggression constitute manifest violations of the UN Charter

27. Russia’s acts of aggression constitute a “manifest violation” of the UN Charter because of their “character, gravity and scale”, according to the meaning of Article 8 bis (1). Russia’s acts of aggression are manifest violations by their illegal character

28. The acts of aggression, by their character, must constitute an evident violation of the UN Charter. The criterion of “manifest violation” applies to uses of force which indisputably violate the prohibition on the threat or use of force in international law enshrined in Article 2(4) of the UN Charter.

29. Russia has sought to justify its use of armed force in Ukraine as an act of selfdefense. On 24 February 2022, the President of Russia, VLADIMIR PUTIN, announced Russia’s military action in Ukraine in a speech. At the same time, the Russian Permanent Representative to the UN, Vassily Nebenzia, notified the UN Secretary-General that the military action was “taken in accordance with Article 51 of the UN Charter in the exercise of the right of self-defence.” The transcript of the President’s speech was appended to the Article 51 letter as sole legal justification for Russia’s use of force. The transcript of President Putin’s speech was appended to Russia’s written submissions dated 7 March 2022 in the case before the ICJ on Allegations of Genocide under the Convention on the Prevention and Punishment of the Crime of Genocide (Ukraine v. Russian Federation). The written submissions quoted extensively from President Putin’s speech and asserted that Russia’s only justification for the use of force against Ukraine was self-defense under Article 51 of the UN Charter: “The special military operation conducted by Russia in the territory of Ukraine is based on the United Nations Charter, its Article 51 and customary 7 international law. The legal basis for the military operation was communicated on 24 February 2022 to the Secretary-General of the United Nations and the United Nations Security Council by the Permanent Representative of the Russian Federation to the United Nations in the form of a notification under Article 51 of the United Nations Charter. The relevant letter addressed to the UN Secretary-General with the request to circulate it as a document of the UN Security Council forwarded “the address of the President of the Russian Federation H.E. Mr. Vladimir Putin to the citizens of Russia informing them of the measures taken in accordance with Article 51 of the UN Charter in exercise of the right of self-defense” (emp original)

30. President Putin appears to make two legal arguments for Russia’s purported use of force in self-defense in his speech from 24 February 2022: an individual selfdefense argument according to which Russia is using force in individual selfdefense to protect itself and Russian nationals and a collective self-defense argument according to which Russia is using force in collective self-defense to protect the ‘Donetsk People’s Republic’ and the ‘Luhansk People’s Republic’. The factual circumstances do not support either self-defense argument.

31. Russia’s use of armed force in individual or collective self-defense was neither legally nor factually supported. Russia lacks any legal justification for its use of force against the sovereignty, territorial integrity or political independence of Ukraine. The UN General Assembly overwhelmingly adopted on 2 March 2022 a resolution which notably “‘[d]eplores in the strongest terms the aggression by the Russian Federation against Ukraine in violation of Article 2 (4) of the Charter”. That the resolution was adopted by a vote of 141 in favor to 5 against illustrates the international consensus that Russia’s acts of aggression were manifestly unlawful. Russia’s acts of aggression are manifest violations by their gravity and scale

32. Criminal acts of aggression must be a manifest violation by their gravity and scale. The use of force must not only be obviously illegal, but also be of a certain intensity. Russia’s acts of aggression in Ukraine display the required gravity and scale.

33. The “gravity” component relates to the effects of the use of force, which could include number of human casualties on all sides, the scope of the disturbance of common life within the victim state, and the level of property destruction on all sides. The use of force by Russia has had particularly grave effects. a) First, there has been a high number of human casualties on all sides; b) Second, common daily life in Ukraine has been severely disturbed; c) Third, property destruction has been particularly severe in Ukraine. Several Ukrainian cities have come under heavy Russian bombardments (see above paras 15-19). Residential houses, hospitals and schools have been hit. The amount of infrastructure damage and destruction has an enormous monetary cost and an immeasureable cost in terms of cultural and historical value. The enormity of those losses and the costs to be incurred in eventual rebuilding and restitution will become an especially grave economic burden. 8

34. The “scale” component relates to the means used, including the intensity of the people and firepower used. The means used by Russia in Ukraine illustrate the scale of the use of force. Russian forces of hundreds of thousands of mobilized troops have employed explosive weapons ranging from missiles, heavy artillery shells and rockets, and airstrikes.

35. Thus, Russia’s acts of aggression in Ukraine constitute a manifest violation of the UN Charter because of their evident illegality and because of their scale and gravity. ( III ) ALLEGATIONS of ACCUSED’s CONDUCT 36. The Accused VLADIMIR PUTIN, planned, prepared, initiated or executed Russia’s acts of aggression. The Accused perpetrated these acts, either by taking steps personally or, by virtue of his privileged position in Russian political or military decision-making, directing the actions of the Russian state and its agents, including through such persons as NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO, SERGEI BESEDA, SERGEI LAVROV and VALERY GERASIMOV. Planning 37. Planning includes participating in high-level meetings during which plans for the acts of aggression are formulated, and enacting legislation, decrees and ordinances concerning the aggressive plans. The Accused attended high-level meetings to plan Russia’s acts of aggression

38. On 18 February 2022, the Russian Security Council held a meeting to discuss the situation in Ukraine and “growing tensions that are provoked by external forces.” The meeting was attended by VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO and SERGEI LAVROV.

39. On or about 21 February 2022, the Russian Security Council held an extraordinary meeting to discuss the situation in Donbas. At this meeting, members of the Security Council agreed on the recognition of the DPR and the LPR as independent states. The meeting was attended by VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO and SERGEI LAVROV.

40. A statement from the Kremlin confirmed that Russia’s military operation in Ukraine followed a previously laid out plan to demilitarize Ukraine and ensure its neutrality. Following a call between VLADIMIR PUTIN and the President of France, Emmanuel Macron, on 3 March 2022, the statement read that Russia’s operation was going “according to plan.” Further, it stated that Vladimir Putin outlined in detail the fundamental approaches and conditions in the context of negotiations with representatives of Kyiv. It was confirmed that, first of all, we are talking about the demilitarisation and neutral status of Ukraine, so that a threat to the Russian Federation will never emanate from its territory. The statement also noted that, “It was emphasised [by VLADIMIR PUTIN] that the tasks of the special military operation will be fulfilled in any event.” 9 The Accused enacted legislation & decrees concerning Russia’s aggression plans

41. Legislation and Presidential decrees or orders were enacted to plan Russia’s acts of aggression: a) On 24 April 2019, VLADIMIR PUTIN enacted a decree “On determining for humanitarian purposes categories of individuals who may apply for the citizenship of the Russian Federation via a simplified procedure.” The decree extends Russian citizenship to residents of the DPR and the LPR. b) On 2 July 2021, VLADIMIR PUTIN signed into law Russia’s updated National Security Strategy, which states that Russia considers it lawful to respond to unfriendly actions that pose a threat to Russia’s sovereignty and territorial integrity by taking symmetrical and asymmetrical measures to suppress these actions and prevent their recurrence. c) On 13 September 2021, the Russian Ministry of Industry and Trade adopted a national technical standard for urgent burial of corpses in wartime and peacetime, to take effect from 1 February 2022. The standard allows for designation as burial sites of areas as large as 40 hectares. d) On 15 February 2022, the State Duma approved a resolution to recognize the sovereignty of the DPR and the LPR, submitted by the CPRF faction. On the same day, the State Duma sent the resolution to VLADIMIR PUTIN for his signature. e) On 21 February 2022, VLADIMIR PUTIN issued an instruction to the Defense Ministry to deploy “peacekeeping” troops to Donbas. f) On 22 February 2022, VLADIMIR PUTIN signed the resolution to recognize the sovereignty of the DPR with the Head of the DPR, Denis Pushilin. The resolution passed into law on the same day and allowed for the deployment of Russian peacekeeping troops to the DPR. g) On 22 February 2022, VLADIMIR PUTIN signed the resolution to recognize the sovereignty of the LPR with the Head of the LPR, Leonid Pasechnik. The resolution passed into law on the same day, and allowed for the deployment of Russian peacekeeping troops to the LPR. h) On 22 February 2022, the Federation Council passed a resolution granting VLADIMIR PUTIN’s request to authorize deployment of Russian armed forces abroad. The Federation Council is chaired by VALENTINA MATVIYENKO. i) On 27 February 2022, VLADIMIR PUTIN ordered the Minister of Defense, SERGEI SHOIGU, and the Chief of the General Staff, VALERY GERASIMOV, to transfer the “deterrence forces” of the Russian army to a special mode of combat duty.

42. By the foregoing acts, conduct and practices, VLADIMIR PUTIN is responsible for the crime of aggression by planning Russia’s acts of aggression, as charged in Count 1. 10 Preparation

43. Preparation refers to concrete steps taken to realize the plan and can include acts to create the necessary military or economic capacities to commit acts of aggression and political and diplomatic maneuvers. Preparation includes: a) preparing official justification for acts of aggression; b) making false assurances of peaceful intentions; c) pressuring the other State by amassing troops; d) intervening in the internal affairs of the other State; e) engaging in diplomatic maneuvers to prevent third States from aiding the other State; and f) engineering incidents as pretexts for military action. A) The accused prepared official justifications for Russia’s acts of aggression

44. VLADIMIR PUTIN’s speech of 24 February 2022 seeks to justify Russia’s acts of aggression as being conducted in self-defense to protect its own territory or Russian nationals (individual self-defense), and to protect the DPR and the LPR (collective self-defense). In advance of Russia’s acts of aggression, preparations were made to establish these official justifications.

45. In preparation for the individual self-defense justification, a number of statements were made before and after the initiation of the invasion of Ukraine to establish a record of Russia’s alleged perception of a threat from Ukraine, or to otherwise insinuate that Russia believes that such a threat exists. These statements and insinuations refer to the alleged threat posed to Russia by the Ukrainian armed forces and by the NATO presence in Ukraine:

a) On 12 July 2021, VLADIMIR PUTIN published an article titled “On the Historical Unity of Russians and Ukrainians,” claiming that Ukraine is “aggressive towards Russia,” as evinced by supposed discrimination against Russian speakers in Ukraine, termed “Russophobia”. In this article, VLADIMIR PUTIN also purports that Ukraine is indulging in aggressive rhetoric and militarizing, and that Ukraine’s authorities, security services and armed forces are under direct external control.

b) On 18 November 2021, in a speech at an expanded meeting of Russia’s Foreign Ministry Board, VLADIMIR PUTIN identified “Ukraine’s internal crisis” as a pressing issue for Russia, with Ukraine’s failure to fulfil its obligations under the Minsk Agreements preventing resolution of the issue. He continued that the West is exacerbating the situation by “supplying Kiev with modern lethal weapons, conducting provocative military exercises in the Black Sea and other regions close to our borders,” and that NATO’s expansion to Russia’s borders could be used offensively against Russia.

c) On 7 December 2021, in a meeting with the President of the United States of America, Joseph Biden, VLADIMIR PUTIN expressed concern that NATO was “undertaking dangerous attempts to gain a foothold on Ukrainian territory, and building up its military capabilities along the Russian border.” 11

d) On 9 December 2021, VLADIMIR PUTIN declared, at a meeting of the Council for Civil Society and Human Rights, that “Russophobia” is the first step towards genocide.

e) On 21 December 2021, in an expanded meeting of the Russian Defense Ministry Board, SERGEI SHOIGU made a number of claims regarding alleged US and NATO military presence in Ukraine, particularly in Donetsk, and military drills targeting Russia. Among these claims, SERGEI SHOIGU stated that US private military companies were preparing a provocation with chemical components in eastern Ukraine and that about 120 representatives of US private military companies were already in Ukraine. At this meeting, VLADIMIR PUTIN also reportedly stated that what the US is doing in Ukraine is at Russia’s border, and that Russia simply has nowhere to retreat. He continued that the US would put “hypersonic” weapons in Ukraine and thereby arm and push extremists from Ukraine into Russia, perhaps by attacking Crimea. The meeting was attended by VLADIMIR PUTIN, SERGEI SHOIGU, VALERY GERASIMOV, VALENTINA MATVIYENKO and unnamed “representatives of bodies of state power and public organizations” and “command officials from military districts.”

f) On 15 February 2022, at a press conference, VLADIMIR PUTIN stated that the US and NATO responses to Russian proposals on security guarantees did not meet Russian requirements.

g) On 18 February 2022, the Russian Security Council held a meeting focusing on the “growing tensions that are provoked by external forces” in relation to Ukraine. The meeting was attended by VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO and SERGEI LAVROV.

h) On 18 February 2022, the President of Belarus, Alexander Lukashenko, explained in a joint press conference with VLADIMIR PUTIN that the “growing military threat” on Russian and Belarussian borders with Ukraine and the “pumping of Ukraine with weapons” had compelled Belarus and Russia to look for adequate means of repelling a potential attack on their borders.

i) On 27 February 2022, VLADIMIR PUTIN claimed that the West is taking unfriendly actions against Russia, not only economically through sanctions, but also in the form of top officials of NATO Member States making “aggressive statements” against Russia. In response to this alleged aggression, he ordered the Minister of Defense, SERGEI SHOIGU, and the Chief of the General Staff, VALERY GERASIMOV, to transfer the “deterrence forces” of the Russian army to a special mode of combat duty.

j) On 1 March 2022, SERGEI LAVROV appeared before the UN Human Rights Council on 1 March 2022, where he claimed that Ukraine had “made territorial claims against the Russian Federation, threatened to use force and acquire a military nuclear capability.” Further, he stated that Russia had decided to launch its “special military operation” to protect the rights of Russian speakers and citizens of Ukraine and demilitarize and de-nazify Ukraine. 12

k) On 16 March 2022, in a meeting on socio-economic support for the constituent entities of Russia, VLADIMIR PUTIN claimed that Russia had “no alternative for self-defence” and to ensure its security, and therefore was forced to begin the “special military operation” in Ukraine. He continued that Russia would “never allow Ukraine to be a bridgehead for aggressive actions against our country.”

46. In preparation for the individual self-defense justification, steps were also taken to establish a record of Russia’s alleged perception of a threat to Russian citizens in Ukraine from Ukrainian authorities or armed forces:

a) On 24 April 2019, VLADIMIR PUTIN enacted a decree “On determining for humanitarian purposes categories of individuals who may apply for the citizenship of the Russian Federation via a simplified procedure.” The decree enabled residents of Donetsk and Luhansk to apply for Russian citizenship, thereby laying the foundation for claims that the situation in Donbas threatens “Russian citizens,” and therefore threatens Russia itself.

b) On 23 February 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, stated at a UN Security Council meeting that “[t]he goal of this special operation is protection of people who have been victimized and exposed to genocide by the Kiev regime. To ensure this, we will seek… criminal prosecution for those who committed numerous heinous crimes against civilians, including citizens of the Russian Federation.”

47. In preparation for the collective self-defense justification, VLADIMIR PUTIN enacted a decree on 24 April 2019 allowing residents of the DPR and the LPR to apply for Russian citizenship. Thereafter, a number of statements were made as to the alleged genocide and “Russophobia” in Donbas: a) On 9 December 2021, at a meeting of the Council for Civil Society and Human Rights, VLADIMIR PUTIN declared that the “current developments in Donbas… are very reminiscent of genocide.” b) On 15 February 2022, at a press conference, VLADIMIR PUTIN asserted that there was an ongoing genocide in Donbas, and that Ukraine is systematically violating human rights in Donbas and endorsing discrimination against Russian speakers at the legislative level. c) On 23 February 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, stated at a UN Security Council meeting that, Ukraine “has turned into ‘Anti-Russia’ and raised its fight against the Russian language and everything Russian to the level of state policy… All those who disagree with such policies were persecuted, subjected to repressions, legal prosecution and violence.” Nebenzia also referred to the situation in Donbas as a “flagrant genocide and violation of the main human right – the right to life.”

48. In preparation for the collective self-defense justification, allegations were also raised as to Ukraine’s intention to violate the Minsk Agreements, and the actual or threatened use of force in Donbas by the armed forces of Ukraine and/or NATO Members: 13

a) On 12 July 2021, VLADIMIR PUTIN published an article titled “On the Historical Unity of Russians and Ukrainians,” claiming that Ukraine regularly declares its “full adherence” to the Minsk Agreements, but does not intend to seriously implement the same, instead arranging “bloody provocations” in Donbas.

b) On 7 December 2021, in a meeting with the President of the United States of America, Joseph Biden, VLADIMIR PUTIN “shared specific examples to illustrate the destructive nature of Kyiv’s policy to dismantle” the Minsk Agreements and expressed serious concern about Kyiv’s “provocative actions against Donbas.”

c) On 21 December 2021, at an expanded meeting of the Russian Defense Ministry Board, SERGEI SHOIGU claimed that the Ukrainian military was shelling civilian neighborhoods in Donbas. At this meeting, SERGEI SHOIGU also made a number of claims regarding alleged US and NATO military presence in Ukraine, particularly in Donetsk, and military drills targeting Russia. The meeting was attended by VLADIMIR PUTIN, SERGEI SHOIGU, VALERY GERASIMOV, VALENTINA MATVIYENKO and unnamed “representatives of bodies of state power and public organizations” and “command officials from military districts.”

d) On 15 February 2022, at a press conference, VLADIMIR PUTIN stated that Ukraine is refusing to abide by the Minsk Agreements and 2015 arrangements.

e) On 20 February 2022, in a telephone conversation with the President of France, Emmanuel Macron, VLADIMIR PUTIN claimed that “provocations from Ukrainian militants were the reason for the escalation” along the contact line in Donbas, with the modern weapons and ammunition being sent to Ukraine by NATO Members allegedly “encouraging Kiev to pursue a military solution to the Donbas problem” and thereby forcing civilians in Donetsk and Luhansk to flee to Russia.

f) On or about 21 February 2022, the Russian Security Council held an extraordinary meeting on the situation in Donbas. At the meeting, the Head of the Russian Security Service (FSB), Alexander Bortnikov, alleged that earlier that day Ukrainian forces were crossing the border into Russian territory, while SERGEI SHOIGU claimed that there had been over 107 heavy weapons attacks by Ukraine in Donetsk and Luhansk, and that 59,000 Ukrainian troops were at the borders of Luhansk and Donetsk. SERGEI SHOIGU also drew the Security Council’s attention to the President of Ukraine, Volodymyr Zelensky’s statement that he would like to make Ukraine a nuclear country again, warning that Ukraine’s capabilities could exceed those of Iran and North Korea. NIKOLAI PATRUSHEV further remarked that the US is responsible for the events in Donbas, and that Russia is obliged to support the DPR and the LPR. The meeting was attended by VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO and SERGEI LAVROV.

g) On 23 February 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, made a statement at a UN Security 14 Council meeting claiming that instead of implementing the Minsk Agreements, Ukraine is “proceeding with bombardments of residential quarters and sabotage activities… Elderly people and children hide from shells in basements. Refugee count – I stress that people are seeking refuge in Russia, and not Ukraine – stands at dozens of thousands these past days, most specifically – 96 thousand people as of now.” Nebenzia also claimed that “[b]ombardments of residential quarters of the two republics [the DPR and the LPR] have not stopped.”

49. In preparation for the collective self-defense justification, steps were taken to ostensibly recognize the sovereignty of the DPR and the LPR, purportedly in response to the threat from Ukraine: a) On 22 February 2022, VLADIMIR PUTIN and the Head of the DPR, Denis Pushilin, signed a resolution on recognition of the sovereignty of the DPR, as described in Paragraph f). The resolution includes a provision on mutual military assistance, serving as an ostensible legal basis for the deployment of Russian armed forces in Donbas. b) On 22 February 2022, VLADIMIR PUTIN and the Head of the LPR, Leonid Pasechnik, signed the resolution on recognition of the sovereignty of the LPR, as described in Paragraph g). Like the resolution recognizing the DPR, this resolution also included a clause on mutual military assistance.

50. In preparation for the collective self-defense justification, the deployment of Russian armed forces abroad was authorized on the basis of the resolutions recognizing the DPR and the LPR: a) On 21 February 2022, VLADIMIR PUTIN issued an instruction to the Defense Ministry to deploy “peacekeeping” troops to Donbas; b) On 22 February 2022, on the basis of the agreements recognizing the sovereignty of the DPR and the LPR, VLADIMIR PUTIN requested authorization to deploy the use of Russian armed forces abroad. c) On 22 February 2022, the Federation Council passed a resolution granting VLADIMIR PUTIN’s request for authorization to deploy the use of Russian armed forces abroad, as described at Paragraph h). The Federation Council is chaired by VALENTINA MATVIYENKO.

51. In preparation for the collective self-defense justification, further statements were made before and after the initiation of the invasion of Ukraine to reflect Russia’s alleged perception that any use of armed force against Ukraine would be justifiable in light of Ukraine’s supposed acts of provocation in Donbas and noncompliance with international law: a) On 22 February 2022, as reported in a tweet by the Russian Ministry of Foreign Affairs, VLADIMIR PUTIN warned that those in power in Ukraine must immediately stop hostilities, otherwise “responsibility for the possible continuation of the bloodshed will lie entirely on the conscience of Ukraine’s ruling regime.” b) On 23 February 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, made a statement at a UN Security 15 Council meeting that “Ukraine did not heed our signals that we sent to Kiev about the need to stop provocations against LPR and DPR… Over past 24 hours, OSCE SMM made records of almost 2,000 ceasefire violations, including almost 1,500 explosions… In a word, the nature of provocations of Ukraine’s Armed Forces has not changed.” Nebenzia also stated that “the principle of sovereignty and territorial integrity of states, of which violation we are being accused with regard to Ukraine… must be strictly observed with regard to states that are ‘conducting themselves in compliance with the principle of equal rights and self-determination of peoples and thus possessed of a government representing the whole people belonging to the territory without distinction as to race, creed or colour.’ The current government of Ukraine is not like this.” Nebenzia further stated that “Ukraine’s provocations against Donbas not only failed to stop, but actually intensified, that is why the leadership of DPR and LPR turned to us with a request to grant military support under bilateral agreements on cooperation… This is a logical step that clearly follows from the acts of Ukrainian regime.” c) On 23 February 2022, in a televised speech, VLADIMIR PUTIN announced that Russia would begin a “specialized military operation” in Donbas, with the aim of demilitarizing Ukraine. d) On 23 February 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, made a statement at the same UN Security Council meeting that “what clearly follows from his message [VLADIMIR PUTIN’s 23 February 2022 speech] is that occupation of Ukraine is not part of our plan. The goal of this special operation is protection of people who have been victimized and exposed to genocide by the Kiev regime. To ensure this, we will seek demilitarization and denazification of Ukraine, and criminal prosecution for those who committed numerous heinous crimes against civilians… This decision was made as per Article 51 of the UN Charter and authorized by the Federation Council of the Federal Assembly of Russia in pursuance of the Treaty of Friendship, Cooperation and Mutual Assistance with DPR and LPR.” e) On 16 March 2022, in a meeting on socio-economic support for the constituent entities of Russia, VLADIMIR PUTIN claimed that the main goal of Russia’s use of force in Ukraine was “to help our people in Donbass, who have been subjected to real genocide for nearly eight years,” and that, since Russia’s diplomatic efforts to resolve the matter were unsuccessful, it had been “left with no peaceful alternative to settle the problems that developed through no fault of [Russia’s]” but to begin the “special military operation.” He continued that the Russian “special military operation” is not connected with any desire to occupy Ukraine, and that Russia had “no alternative for self-defence.” B) The Accused gave false assurances of Russia’s peaceful intentions in respect of Ukraine’s sovereignty and territorial integrity

52. False assurances of Russia’s peaceful intentions and respect for Ukraine’s sovereignty and territorial integrity were made in preparation for Russia’s acts of aggression: 16 a) On 27 November 2021, in a media interview, SERGEI NARYSHKIN claimed that rumors of Russia’s preparation to invade Ukraine were “nonsense,” and merely propaganda conducted by the US State Department. b) On 9 December 2021, in a briefing of foreign military diplomats, VALERY GERASIMOV reportedly stated that “hype” in the media about preparation for a Russian invasion of Ukraine is a lie, and that troop movements in the course of combat training constitute routine practice. c) On 30 January 2022, in a media interview, NIKOLAI PATRUSHEV stated that it is a “complete absurdity” to suggest that Russia is threatening Ukraine, and that Russia does not want war. d) On 31 January 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, made a statement to the UN decrying US claims of “the presence of Russian troops on Russian territory as a threat to international peace and security” as an interference in Russia’s internal affairs and an attempt to mislead the international community as to the reality of the situation in Donbas. e) On 15 February 2022, at a press conference, VLADIMIR PUTIN stated that opportunities to restore Ukraine’s territorial integrity via a direct dialogue with Donetsk and Luhansk continue to be ignored. f) On 23 February 2022, an agent of the Russian state, Permanent Representative of Russia to the UN Vassily Nebenzia, made a statement at a UN Security Council meeting claiming that “Russian military will be monitoring the ceasefire upon request of Donetsk and Lugansk.” C) The Accused amassed troops on the border with Ukraine

53. VLADIMIR PUTIN used large scale military exercises as a pretense to reposition its armed forces near Ukraine, and to prepare for an invasion. 54. From 7 April 2021 to 17 May 2021, the Russian Armed Forces built up significant force elements in eastern Ukraine regions. A central focal point for this build-up was an air and amphibious assault exercise held on the southern coast of the Crimean Peninsula. These exercises were assessed to have been intended as a public demonstration of Russian capability to launch an overwhelming offensive against south-eastern Ukraine. They also served as a basis for significant forces to position close to Ukraine.

55. On 10 February 2022, Russia and Belarus began 10 days of joint military drills. The military drills, called Allied Resolve-2022, began in Belarus and was reported to end on 20 February 2022, the Russian Ministry of Defense announced in a statement. VLADIMIR PUTIN stated that Russian military drills were “purely defensive” and “not a threat to any other country.” The statement from the Ministry of Defense stated that “[t]he purpose of the exercise is to work out the tasks of suppressing and repelling external aggression while conducting a defensive operation, countering terrorism and protecting the interests of the Union State.” Russia’s military exercises threatened Ukraine of an impending risk of invasion. Ukraine had decried the Zapad joint exercises as a form of psychological pressure. The President of Ukraine, Volodymyr Zelensky, said on 10 February 17 2022 that “the buildup of troops along the borders is psychological pressure from our neighbors.” D) The Accused engaged in diplomatic maneuvers to prevent third States from aiding Ukraine

56. In preparing for VLADIMIR PUTIN’s acts of aggression, several steps were taken to prevent third States, particularly the US and other NATO Members, from aiding Ukraine: a) On 9 February 2022, the Russian Ministry of Foreign Affairs set out conditions for the West to de-escalate the situation at the border with Ukraine. These conditions were for third States to “stop weapon deliveries to Ukraine, withdraw their military advisers and instructors, discontinue joint VSUNATO exercises, and pull out all earlier supplied foreign armaments to locations beyond the Ukrainian territory.” b) At the same 9 February 2022 meeting, the Russian Ministry of Foreign Affairs exerted diplomatic pressure on NATO to renounce its open-doors policy.

57. In addition, Russia engaged in diplomatic negotiations over the tension with Ukraine up to the invasion, maintaining the appearance that Russia intended to resolve any tensions through diplomatic negotiations while simultaneously conducting other preparations for aggression against Ukraine: a) On 14 February 2022, VLADIMIR PUTIN met with SERGEI LAVROV to discuss the US and NATO responses to Russia’s proposals regarding NATO’s expansion eastwards, projecting the appearance of an intention to resolve any tensions through diplomatic negotiations. b) On 15 February 2022, following talks with the Chancellor of Germany, Olaf Scholz, VLADIMIR PUTIN stated that the US and NATO responses to Russian proposals on security guarantees did not meet Russian requirements, and that Ukraine is refusing to abide by the Minsk Agreements and 2015 arrangements. E) The Accused engineered incidents as pretexts for military action in Ukraine

58. VLADIMIR PUTIN engineered pretexts for military action in Ukraine. For example, an incident of heavy shelling in eastern Ukraine on 17 February 2022. F) The Accused intervened in the internal affairs of Ukraine

59. VLADIMIR PUTIN intervened in Ukraine’s internal affairs in several ways, particularly in relation to the Donbas region. In summary: a) VLADIMIR PUTIN enacted a decree extending Russian citizenship to residents of Donetsk and Luhansk in Ukraine. b) Russia deployed “peacekeeping troops” to Donbas, Ukraine. c) Lawmakers in Russia, including at the State Duma, at the Federation Council and VLADIMIR PUTIN, passed a resolution recognizing the sovereignty of the “Donetsk People’s Republic” and “Lugansk People’s Republic,” both regions of Ukraine. In doing so, VLADIMIR PUTIN signed agreements on mutual military assistance with the heads of these supposed republics. The 18 UN General Assembly deemed this decision to recognize the DPR and the LPR as a violation of the territorial integrity and sovereignty of Ukraine, contrary to the principles of the UN Charter. d) VLADIMIR PUTIN requested authorization to deploy Russian armed forces abroad, and the Federation Council passed a resolution granting this request.

60. By the foregoing acts, conduct and practices, VLADIMIR PUTIN is responsible for the crime of aggression by preparing Russia’s acts of aggression, as charged in Count 1. Initiation

61. Initiation includes the decision taken immediately before the first use of force to commit the act of aggression, including by way of a declaration of hostilities, and the first actual use of force. VLADIMIR PUTIN made a declaration of hostilities

62. VLADIMIR PUTIN initiated Russia’s acts of aggression by making a declaration of hostilities in his speech of 24 February 2022. In that speech, he announced that he had decided to conduct a “special military operation,” which would involve unilateral military action by Russian armed forces on Ukrainian territory. Ukraine was clearly identified as the target State for the hostilities as the speech made 13 references to Ukraine; identified the operation’s objective as the “demilitarization and de-nazification of Ukraine”; exhorted members of the Ukrainian Armed Forces to lay down their weapons; and referenced events in the Donbas region of Ukraine. The accused initiated the first use of force in Ukraine

63. On 24 February 2022, the first use of force to execute VLADIMIR PUTIN’s “special military operation” by Russia in Ukraine was initiated by the Accused.

64. By his acts, conduct and practices, VLADIMIR PUTIN is responsible for the crime of aggression by initiating Russia’s acts of aggression, as charged in Count 1. Execution 65. Execution refers to “all substantive strategic acts undertaken after the initiation of an act of aggression to secure the continuation and success of the aggressive act.” Execution includes commanding armed forces conducing the acts of aggression, and governing territory occupied as a result of the acts of aggression. The accused secured the continuation of Russia’s acts of aggression

66. The beginning of Russia’s acts of aggression in Ukraine on 24 February 2022 demonstrates the execution of the act of aggression. Russia’s acts of aggression in Ukraine in 2022 and the ensuing conflict resulted in many thousands of civilian casualties, bombardments and indiscriminate attacks, including of populated areas, blockades of Ukrainian ports and coasts, and attacks against the Ukrainian Armed Forces.

67. VLADIMIR PUTIN secured the continuation of Russia’s acts of aggression by shoring up domestic support for, and suppressing dissent on, these acts: 19 a) On 4 March 2022, VLADIMIR PUTIN enacted a law ostensibly aimed at preventing the discrediting of the Russian armed forces in their operations to protect Russian interests and maintain international peace and security. This law was approved prior by the Federation Council, which is chaired by VALENTINA MATVIYENKO. This law criminalizes calls against the use of Russian troops to protect Russian interests, and calls for sanctions against Russia. Accordingly, individuals may face criminal penalties for referring to the “special military operation” as a “war” or “invasion.”

68. VLADIMIR PUTIN also secured the continuation of Russia’s acts of aggression by expressing or supporting Russia’s conditions for ceasing the use of force in Ukraine: a) On 17 February 2022, in a media interview, SERGEI LAVROV stated that the security of Europe depends on improving its position on stopping NATO expansion to the East and non-deployment of strike weapons. The accused secured the occupation of parts of Ukraine’s territory

69. The occupation of Ukrainian territory by Russia in 2022, and therefore the execution of Russia’s acts of aggression, was secured by the acts of the Accused and by the acts of those under his command, control or direction.

70. Finally, with regard to issues of the broader context of planning and preparation, Russia invaded and annexed the territory of Crimea eight years ago. Many of the tactics used during the 2014 ‘annexation’ form the playbook or pattern for the 2022 invasion.

71. By the foregoing acts, conduct and practices, VLADIMIR PUTIN is responsible for the crime of aggression by executing Russia’s acts of aggression, as charged in Count 1. ( IV ) CRIMINAL RESPONSIBILITY

72. The Accused VLADIMIR PUTIN is individually criminally responsible for the commission of the crime of aggression by planning, preparing, initiating or executing Russia’s acts of aggression, as charged in Count 1.

73. At all relevant times, VLADIMIR PUTIN was aware the factual circumstances that established that Russia’s use of armed force against the sovereignty, territorial integrity or political independence of another State was inconsistent with the UN Charter and that such acts of aggression constituted a manifest violation of the UN Charter.

74. The Accused VLADIMIR PUTIN and his collaborators made statements directly evincing their knowledge of the factual circumstances surrounding Russia’s use of armed force in Ukraine beginning 24 February 2022, or projecting that they are in a position to have acquired such knowledge: a) On 16 February 2022, in an interview published on the Federation Council’s website, VALENTINA MATVIYENKO stated that any Russian military action in Ukraine will be commensurate with the “scale of the aggression” by Ukraine in Donbas and the military-political situation that has arisen. 20 b) On 22 February 2022, in a media interview, SERGEI LAVROV opined that, under international law, the right to sovereignty need only be observed in relation to states that represent all the people living on their territory, and that Ukraine had ceased to do so since 2014. c) On 5 March 2022, at a meeting with Russian airline crew, VLADIMIR PUTIN stated that the Russian Ministry of Defense “has taken the path of destroying the military infrastructure of Ukraine, this part of the operation is almost completed.” d) On 10 March 2022, in a press conference following talks with Ukrainian Foreign Minister Dmitry Kuleba, SERGEI LAVROV made assertions as to Russia’s military conduct in Ukraine. In particular, he claimed that the Russian military is taking steps to alleviate the suffering of civilians used as human shields by Ukraine, and that Russia continues to open humanitarian corridors daily. e) On 11 March 2022, at a meeting of the Security Council, SERGEI SHOIGU proposed that Russian forces in Donbas be given air defense equipment, including portable anti-aircraft missile systems, and anti-tank and anti-aircraft systems. He further suggested that the Western weapons seized in Ukrainian territory be delivered to them. SERGEI SHOIGU also suggested that VLADIMIR PUTIN allow volunteers from the Middle East to join Russian forces in Ukraine, with VLADIMIR PUTIN accepting this suggestion. f) On 16 March 2022, in a meeting on socio-economic support for the constituent entities of Russia, VLADIMIR PUTIN stated that the combat tactics drafted by the Russian Ministry of Defense and the General Staff had “fully justified itself” in the Ukraine context, and that Russian soldiers and officers were doing all they could to avoid civilian losses in Ukrainian cities. g) On 28 March 2022, in a media interview, VALENTINA MATVIYENKO stated that Russia’s “special operation” in Ukraine is going “according to plan,” and that its assigned tasks will be completed in full. h) On 7 April 2022, in a media interview, SERGEI NARYSHKIN opined that Russia is creating a multipolar world by directly challenging the system, to create a new world order. i) On 11 April 2022, in a televised broadcast, SERGEI LAVROV reportedly announced an additional goal of the Russian “special operation” in Ukraine— to end US dominance worldwide. He continued that the operation is “designed to put an end to the reckless expansion and reckless course towards the complete dominance of the United States and under them the rest of the Western countries in the international arena.”

75. Additionally, the Accused participated in meetings regarding developments in Russia’s use of armed force in Ukraine beginning 24 February 2022, indicating knowledge of the conduct of hostilities: a) On 27 February 2022, VLADIMIR PUTIN met with SERGEI SHOIGU and VALERY GERASIMOV at the Kremlin, where he ordered that the Russian Army’s deterrence forces be put on high combat alert. 21 b) On 11 March 2022, the Permanent Members of the Security Council convened. At this meeting, SERGEI SHOIGU reported that Russian military action in Ukraine was proceeding as planned, and made suggestions on accepting volunteer fighters, delivery of seized weapons to Donbas, and reinforcing Russia’s western borders. VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN AND VALENTINA MATVIYENKO attended the meeting. c) On 18 March 2022, the Permanent Members of the Security Council convened to discuss progress in the “special military operation” in Ukraine. VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN AND SERGEI LAVROV attended the meeting. d) On 24 March 2022, the Permanent Members of the Security Council convened to discuss progress in the negotiations with Ukraine. SERGEI SHOIGU also reported on the ongoing “special military operation,” and efforts by the Russian military to “provide humanitarian aid, ensure security and restore vital infrastructure in the liberated territories.” VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO AND SERGEI LAVROV attended the meeting. e) On 7 April 2022, the Permanent Members of the Security Council convened to discuss progress in the “special military operation” in Ukraine, including the need to strongly counteract any “information attacks” or sabotage. VLADIMIR PUTIN, NIKOLAI PATRUSHEV, SERGEI SHOIGU, SERGEI NARYSHKIN, VALENTINA MATVIYENKO AND SERGEI LAVROV attended the meeting. COUNT 1

76. By the foregoing acts, conduct and practices, VLADIMIR PUTIN is responsible for the following crime: Count 1: Crime of Aggression, punishable under Article 8 bis of the Statute of the International Criminal Court Confirmed in The Hague on 24th February 2023 by the unanimous decision of the Judges, Zak Yacoob, Priya Pillai, and Stephen Rapp.