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(This section is based on a brief originally prepared for submission by the United States Prosecution in support of the allegation, in Count One of the Indictment, of a plan or conspiracy to commit war crimes. The evidence relating to the plan or conspiracy, however, proved to be inseparable from that on the execution thereof, a subject assigned to the French Prosecution. The materials contained herein were accordingly made available to the French for such use as they might deem appropriate in connection with the proof of their case.)

A. The Nazi Conspirators Obtained Enormous Quantities of Foodstuffs, Raw Materials and Equipment From the Occupied Western Countries.

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(1) The Nazis planned in advance of the invasion to secure from the conquered territories the strategic materials which Germany lacked and without which Germany could not prevail in a war of long duration. In this war, as in the last, German resources were sufficient only for a conflict of short duration. As early as the winter of 1939-40, following the swift and crushing defeat of Poland, Germany suffered from a critical shortage of essential raw materials (EC- 615). The Nazi leaders were thus faced with the question whether to conserve their supplies for a long war or to commit their limited reserves in the hope of obtaining an early decision. Hitler decided on the latter course. As Goering told General Thomas:

"The Fuehrer is firmly convinced that he will succeed in reaching a decision *** in the year 1940 by a big attack in the West. He reckons that Belgium, Holland, and Northern France will get into our possession and *** had figured out that the industrial areas of Douai and Lens and those of Luxemburg, Longwy, and Briey could, from the point of view of raw material, replace the supplies from Sweden. Therefore, the Fuehrer had decided now to make use of our reserve of raw materials without regard to future times. ***" (EC-606)

Careful plans were made in advance of the invasion in 1940 to secure for Germany the raw material resources of the to- be occupied countries. A manual of directives and decrees issued by the Quartermaster, OKH, for the economic administration of the military government set forth an exhaustive list of important raw materials to be seized wherever found (EC-155). Directives were issued to the so- called economic squads (Wirtschafts Truppe) attached to the tactical units on the procedures to be followed in locating, seizing, and preparing such materials for shipment to Germany (EC-618). Also included in the manual mentioned were drafts of decrees to be promulgated by the German occupation authorities, for the establishment in the occupied countries of Goods Offices, modeled after the German rationing boards, to control production and distribution in the occupied countries in the German interest. (EC-155)

(2) The occupied Western countries were ruthlessly exploited according to plan. The occupied areas were systematically stripped of their economic resources to feed the German war machine. The extent of German exploitation is partially indicated by the staggering totals of the occupation levies and the "credit" balances of the local central banks under clearing arrangements imposed

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by the Nazis, the principal sources of the funds with which Germany financed the spoliation of Western Europe. (For a brief explanation of the clearing system, see infra under D, 2.)

The total occupation charges exacted from Franco alone were 31,600,000,000 RM from 25 June 1940, to 5 September 1944 (3615-PS). They averaged more than 7,000,000,000 RM annually, a sum more than four times the German annual payments under the Dawes and Young Plans. This sum is in addition to a "credit" of the Bank of France under the Franco-German clearing, which, as of September, 1943, amounted to 4,400,000,000 RM (3615-PS). For the period May 1942-43, the tribute exacted from Belgium (mainly from occupation' charges and clearing credits) amounted to more than two-thirds of the Belgium national income (ECR-149). These figures, large as they are, take no account of the substantial quantities of materials seized and removed to the Reich without compensation (see infra under B, (1)) nor do they reflect the windfall to the Reich resulting from the substantial over-valuation of the Reichsmark, particularly in the case of France and Belgium. (EC-86)

A few illustrative examples of specific items, taken from the report of the German Military Commander for France of 10 September 1942 (EC-267), will serve to show even more concretely than monetary figures, the extent to which materials and equipment were taken from the occupied countries for the benefit of the Reich. Since the Armistice, according to this report, the French contributed to the Germans 73 percent of the normal annual French consumption of iron, amounting to nearly 5 million tons. From the Armistice to July, 1942, 225,000 tons of copper and 5,700 tons of nickel were delivered by France to Germany, amounting to 80 percent and 86 percent of French supplies respectively; also 55 percent of the French aluminum and 80 percent of the magnesium production. For her own needs France retained only 30 percent of the normal production of the wool industry, 16 percent of the cotton production, and 13 percent of the linen production. The total French production of locomotives and the major part of the machine tool industry were put at the disposal of the Germans. (EC- 267)

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