munitions. Thus, they were compelled to work in departments engaged in the construction of turrets for tanks and carriages for heavy Army and Navy guns; the assembling of marine gun turrets, 10.5 cm. marine guns, and 15 cm. torpedo-boat guns; the manufacture of crankshafts for S-boats and aeroplanes, etc. (Charts and affidavit relating to production in the workshops of Fried. Krupp Cast Steel Works by prisoners of war and foreign workers, not here reproduced.) Affidavits of workers in the Krupp workshops afford added proof that prisoners of war and foreign laborers were used by Krupp in the manufacture of arms and munitions (see D-253, D-265, D-279).

(2) The prisoners of war and foreign workers at the Krupp factories did not voluntarily engage in the manufacture of arms and munitions; they were forced to do so. This fact is clearly shown by the following:

(a) Workers were brought to Essen from Poland and Russia in grossly overcrowded, unheated, and unsanitary cattle cars and upon debarking, were beaten, kicked, and otherwise inhumanely treated. An employee of the Reich Railway at Essen has described these conditions as follows:

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* * In the middle of 1941 the first workers arrived from Poland, Galicia and Polish Ukraine. They came to Essen in goods wagons in which potatoes, building materials and also cattle have been transported; they were brought to perform work at Krupp. The cars were jammed full with people. The people were squashed closely together and they had no room for free movement. The Krupp overseers laid special value on the speed the slave workers got in and out of the train. the people were beaten and kicked and generally maltreated in a brutal manI could see with my own eyes that sick people who could scarcely walk * were taken to work. One could see that it was sometimes difficult for them to move themselves. The same can be said for the Eastern workers and PWs who came to Essen in the middle of 1942." (D-321; D-367).

ner.

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(b) Foreign workers were compelled to go to work under guard and were closely watched. In a memorandum dated 7 April 1942, entitled "employment of foreign workers", from the Ignitor workshop of the Krupp Essen plant, it is stated:

"In the course of last week, due to the fact that the foreign workers, especially Poles, could not be relied upon to appear

at work, there was an extraordinary decrease in production; loss of money and fines did not obtain the desired results. "Especially during short (bank) holidays we were not able to find a responsible person in the camp Seumannstrasse, to whom we could have referred. We ourselves are short of guards to fetch the Poles from their camp, and to guard them overnight." (D-270; re compulsion exerted by guards in marching foreign workers to work, see also D-253). (c) After working hours, foreign workers were confined in camps under barbed wire enclosures and were carefully guarded. Dr. Jaeger, senior camp doctor in Krupp's workers' camps, has stated in an affidavit:

"The eastern workers and Poles who laboured in the Krupp works at Essen were kept at camps at Seumannstrasse, Spenlestrasse, Grieperstrasse, Heegstrasse, Germaniastrasse, Kapitan-Lehmannstrasse, Dechenschule, and Kramerplatz. * All these camps were surrounded by barbed wire and were closely guarded." (D-288)

*

H. CONTRARY TO ARTICLES 4, 6, 7, AND 46 OF THE HAGUE REGULATIONS, 1907, ARTICLES 2 AND 3 OF THE PRISONERS OF WAR CONVENTION (GENEVA 1929), THE LAWS AND CUSTOMS OF WAR, AND ARTICLES 6(b) AND 6(c) OF THE CHARTER, KRUPP, AS HEAD OF THE KRUPP CONCERN, WAS RESPONSIBLE FOR DENYING ADEQUATE FOOD, SHELTER, CLOTHING, AND MEDICAL CARE AND ATTENTION TO PRISONERS OF WAR AND WORKERS FORCIBLY DEPORTED FROM OCCUPIED COUNTRIES, FOR FORCING THEM TO WORK UNDER INHUMANE CONDITIONS, AND FOR TORTURING THEM AND SUBJECTING THEM TO INDIGNITIES.

(1) The prisoners of war and foreign laborers at the Krupp works were undernourished and forced to work on a virtual starvation diet.

(a) In a memorandum upon Krupp stationery to Mr. Hupe, Director of the Krupp locomotive factory in Essen, dated 14 March 1942 and entitled "Employment of Russians", it was said:

"During the last few days we have established that the food for the Russians employed here is so miserable, that the people are getting weaker from day to day.

"Investigations showed that single Russians are not able

to place a piece of metal for turning into position for instance, because of lack of physical strength. The same conditions exist at all places of work where Russians are employed." (D-316)

(b) In a memorandum dated 18 March 1942, the following was reported from the Krupp armoured car repair shop:

"I got the food this evening after Mr. Balz telephoned, but I had quite a struggle with the people responsible in the camp before I got anything at all. They always told me that the people had already received the day's rations and there wasn't any more. What the gentlemen understand under a day's ration is a complete puzzle to me. The food as a whole was a puzzle too, because they ladled me out the thinnest of any already watery soup. It was literally water with a handful of turnips and it looked as if it were washing up water. "Please tell Mr. Balz again definitely so that the matter is finally cleared up, that it cannot continue having people perish here at work." (D-310)

(c) In a memorandum dated 20 March 1942 to Mr. Ihn, one of the Krupp Directors, Dinkelacker, a Krupp official, wrote:

"The Deputy Works Manager Mr. Mustin, who also employs a number of such Russian workers and who is quite satisfied with their performance, went to the camp in Kramerplatz on my inducement and had a talk with Mr. Welberg, the Camp Commandant. Mr. Hassel from the Works Police who was present at the time, butted in and declared that one should not believe what the people said. Also that one was dealing with Bolsheviks and they ought to have beatings substituted for food." (D-318)

(d) In a memorandum dated 26 March 1942, to Mr. Hupe concerning the use of Russian prisoners of war and civilian workers, it was reported:

"The reason why the Russians are not capable of production is, in my opinion, that the food which they are given will never give them the strength for working which you hope for. The food one day, for instance, consisted of a watery soup with cabbage leaves and a few pieces of turnip. The punctual appearance of the food leaves a good deal to be desired too." (D-297)

(e) In a memorandum dated 8 December 1942, Haller, a Krupp official, wrote:

"The complaints from our foreign workers about insufficient. food have increased lately.

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"We experienced a very forcible confirmation of these complaints the other day when we drew the food for the Eastern workers from the kitchen in Kramerplatz. On 5.12.42 the midday meal contained unpeeled, whole potatoes which were not even properly cooked; on 7.12.42, there was soup on which cabbage leaves floated, the sight of which made me feel sick." (D-366)

(f) Dr. Jaeger, senior camp doctor in the Krupps' workers' camps, has stated under oath that not only did the plan for food distribution to foreign workers call for a very small quantity of meat every week, but also that they received only contaminated meats rejected by the health authorities, such as horse or tuberculin infested meat (D-288).

(2) The prisoners of war and foreign workers at the Krupp factories were forced to live in grossly overcrowded hutted camps and otherwise were denied adequate shelter.

(a) In a sworn statement, Dr. Jaeger, senior camp doctor of the Krupp workers' camps, has stated with respect to the Krupp camps at which the eastern workers and Poles were kept:

"Conditions in all these camps were extremely bad. The camps were greatly overcrowded. In some camps there were over twice as many people in a barrack as health conditions permitted."

"Sanitary conditions were exceedingly bad. At Kramerplatz, where approximately 1,200 eastern workers were crowded into the rooms of an old school, the sanitary conditions were atrocious in the extreme. Only 10 children's toilets were available for the 1,200 inhabitants. At Dechenschule, 15 children's toilets were available for the 400-500 eastern workers. Excretion contaminated the entire floors of these lavatories. There were also very few facilities for washing." (D-288)

(b) Statistics upon the Krupp camps compiled by Krupp officials in 1942 for the Essen health authorities show that in the Krupp Seumannstrasse camp 1784 beds were compressed into a surface area of 7844 square meters; in the Krupp Bottroperstrasse camp 874 beds were crowded into a surface area of 3585 square meters; and that in other Krupp camps the congestion was even greater (D-143).

(c) In a memorandum dated 12 June 1944, Dr. Stinnesbeck, a doctor retained by the Krupp works, reported, with respect to the Krupp prisoner of war camp at Noggerathstrasse that:

"315 prisoners are still accommodated in the camp. 170 of these are no longer in barracks but in the tunnel in Grunerstrasse under the Essen-Mulheim railway line. This tunnel is damp and is not suitable for continued accommodation of human beings. The rest of the prisoners are accommodated in 10 different factories in Krupps works." (D-335)

(d) In a special medical report marked "strictly confidential”, dated 2 September 1944, concerning the same prisoner of war camp, Dr. Jaeger wrote:

"The P. O. W. camp in the Noggerathstrasse is in a frightful condition. The people live in ash bins, dog kennels, old baking ovens and in self-made huts." (D-339).

(3) The prisoners of war and foreign workers at the Krupp factories were denied adequate clothing.

(a) Dr. Jaeger, senior camp doctor in Krupps' workers' camps, has stated under oath:

"The clothing of the eastern workers was likewise completely inadequate. They worked and slept in the same clothing in which they had arrived from the east. Virtually all of them had no overcoats and were compelled, therefore, to use their blankets as coats in cold and rainy weather. In view of the shortage of shoes, many workers were forced to go to work in their bare feet, even in the winter. Wooden shoes were given to some of the workers, but their quality was such as to give the workers sore feet. Many workers preferred to go to work in their bare feet rather than endure the suffering caused by the wooden shoes. Apart from the wooden shoes, no clothing of any kind was issued to the workers until the latter part of 1943, when a single blue work suit was issued to some of them. To my knowledge, this represented the sole issue of clothing to the workers from the time of their arrival until the American forces entered Essen." (D-288) (b) In a memorandum to Mr. Ihn, a Krupp director, dated 20 October 1942, Dr. Wiehle, head of the Krupp hospital in Essen, wrote:

"It has already been pointed out several times at conferences that the clothing for Eastern workers, men and women, is not sufficient. With regard to the cold weather, the camp