But the essential undertaking of the German labor offices was the deportation of foreign workers to the munition factories of the Reich. The most varied means were used to this end. They were built up into a recruiting policy which can be analyzed as follows:

In the beginning, this policy took on the cloak of legality. The use of labor took the form of requisition as under the terms of Article 52 of the appendix to the fourth Hague Convention; it was also effected by means of the voluntary recruitment of workers, to whom the German recruiting offices offered labor contracts.

I shall provide the Tribunal with proof that the requisitions of labor effected by the National Socialist authorities were a deliberate misinterpretation of the letter and spirit of the international convention by virtue of which they were carried out. I shall show that the voluntary character of the recruitment of certain foreign workers was entirely fictitious; in reality their work contracts were made under the pressure which the occupation authorities brought to bear on their will.

The defendants lost no time in flinging aside their mask of legality. They compelled prisoners of war to do work forbidden by international conventions. I shall show how the work of prisoners of war was incorporated in the general plan for the Allocation of Labor from the occupied areas.

After all, it is through force that the defendants brought their recruitment plans to fruition. They did not hesitate to resort to violent methods. Thus they established compulsory labor service in the areas which they occupied. Sometimes they directly promulgated orders bearing the signature of military commanders or Reich commissioners; this is the case with Belgium and Holland. Sometimes they forced the actual authorities to take legislative measures themselves; this is particularly the case with France and Norway. Sometimes they simply took direct action, that is, they transferred foreign workers to factories in Germany without issuing regulations providing for such action; this happened in Denmark. Finally in certain occupied areas where they had carried out Germanization, the defendants incorporated the inhabitants of those territories in the labor service of the Reich. It happened thus in the French provinces of Haut-Rhin, Bas-Rhin, Moselle, and in Luxembourg.

The policy of compulsory labor was asserted and systematized from the day when the Defendant Sauckel was appointed Plenipotentiary General for Allocation of Labor.

Member of the National Socialist Party since its formation, member of the Diet of Thuringia, and member of the Reichstag, Obergruppenführer of the criminal organizations SS and SA, the Defendant Sauckel was Gauleiter and Reichsstatthalter of Thuringia. On 21 March 1942 he was appointed Plenipotentiary General for Allocation of Labor by a decree of the Führer. This decree is countersigned by Lammers in his capacity as Reichsminister and Chief of the Chancellery and by the Defendant Keitel; the responsibility of these latter is confirmed by this countersigning. The Defendant Keitel has associated himself with the policy of compulsory labor through the appointment of Sauckel, the principles and methods of whom he approved.

I have already read this decree to the Tribunal. I would remind you that it placed Sauckel, in his capacity as Plenipotentiary General for Allocation of Labour, under the immediate orders of the Delegate for the Four Year Plan, the Defendant Göring. The latter bears a direct responsibility in pursuing the plan of recruitment of compulsory labor. I shall produce numerous proofs of this. I ask the Tribunal to authorize me to produce as first proof the decree signed by the Defendant Göring the day after the appointment of the Defendant Sauckel. This decree, dated 27 March 1942, was published in the Reichsgesetzblatt, 1942, Part I, Page 180. I submit it to the Tribunal under Exhibit Number RF-12 (Document Number 1902-PS). Göring by this decree did away with all the administrative offices of the Four Year Plan which had been charged with the recruitment of labor; he transmitted their powers to Sauckel’s department, thus confirming his appointment.

The powers of Sauckel between 1942 and 1944 were considerably strengthened by decrees of Hitler and Göring. These decrees gave full significance to the Defendant Sauckel’s title of Plenipotentiary. They gave him administrative autonomy and even legislative competency such as he could not have aspired to had he confined himself to executive tasks. The importance of the political part which he played during the last 2 years of the war increases to this extent the weight of the responsibility devolving upon him.

I draw the attention of the Tribunal very especially to the decrees of the Führer of 30 September 1942 and of 4 March 1943 and to the decree of the Defendant Göring of 25 May 1942. I will not read these decrees, which have been commented on by my American colleague, Mr. Dodd. I submit them in support of my argument.