We say that it is plain that the program of the concentration camp, the anti-Jewish program, and the forced labor program are all parts of a larger pattern, and this will become even more plain as we examine the evidence regarding these programs, and then test their legality by applying the relevant principles of international law.
The evidence relating to the Nazi slave labor program has been assembled in a document book bearing the letter “R”; and in addition, there is an appendix to the document book consisting of certain photographs contained in a manila folder. Your Honors will observe that on some of the books we have placed some tabs, so that it would be easier for the Tribunal to locate the documents. Unfortunately, we did not have a sufficient number of tabs to do the work completely, and that would account for tabs which are missing on some of the document books.
It may illuminate the specific items of evidence which will be offered later if we first describe in rather general terms the elements of the Nazi foreign labor policy. It was a policy of mass deportation and mass enslavement, as I said a minute ago, and it was also carried out by force, by fraud, by terror, by arson, by means unrestrained by the laws of war and laws of humanity, or the considerations of mercy. This labor policy was a policy as well of underfeeding and overworking foreign laborers, of subjecting them to every form of degradation, brutality, and inhumanity. It was a policy which compelled foreign workers and prisoners of war to manufacture armaments and to engage in other operations of war directed against their own countries. It was a policy, as we propose to establish, which constituted a flagrant violation of the laws of war and of the laws of humanity.
We shall show that the Defendants Sauckel and Speer are principally responsible for the formulation of the policy and for its execution: that the Defendant Sauckel, the Nazis’ Plenipotentiary General for Manpower, directed the recruitment, deportation, and the allocation of foreign civilian labor, that he sanctioned and directed the use of force as the instrument of recruitment, and that he was responsible for the care and the treatment of the enslaved millions; that the Defendant Speer, as Reich Minister for Armament and Munitions, Director of the Organization Todt, and member of the Central Planning Board, bears responsibility for the determination of the numbers of foreign slaves required by the German war machine, was responsible for the decision to recruit by force and for the use under brutal, inhumane, and degrading conditions of foreign civilians and prisoners of war in the manufacture of armaments and munitions, the construction of fortifications, and in active military operations.
We shall also show in this presentation that the Defendant Göring, as Plenipotentiary General for the Four Year Plan, is responsible for all of the crimes involved in the Nazi slave labor program. Finally, we propose to show that the Defendant Rosenberg, as Reich Minister for the Occupied Eastern Territories, and the Defendant Frank, as Governor of the Government General of Poland, and the Defendant Seyss-Inquart, as Reich Commissar for the occupied Netherlands, and the Defendant Keitel, as Chief of the OKW, share responsibility for the recruitment by force and terror and for the deportation to Germany of the citizens of the areas overrun or subjugated by the Wehrmacht.
The use of vast numbers of foreign workers was planned before Germany went to war and was an integral part of the conspiracy for waging aggressive war. On May 23, 1939 a meeting was held in Hitler’s study at the Reich Chancellery. Present were the Defendants Göring, Raeder, and Keitel.
I now refer to Document L-79, which has already been entered in evidence as Exhibit USA-27. The document presents the minutes of this meeting at which Hitler stated, as Your Honors will recall, that he intended to attack Poland at the first suitable opportunity; but I wish to quote from Page 2 of the English text starting with the 13th paragraph as follows. In the German text, by the way, the passage appears at Page 4, Paragraphs 6 and 7. Quoting directly from the English text:
“If fate brings us into conflict with the West, the possession of extensive areas in the East will be advantageous. We shall be able to rely upon record harvests even less in time of war than in peace.
“The population of non-German areas will perform no military service and will be available as a source of labor.”