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The Germans proceeded to make requisitions and wholesale purchases of agricultural produce and livestock. A final estimate of these levies, amounting to a minimum of 300,000,000 Guilders is as yet impossible.

To give an idea of their magnitude we point out that, at the end of the year 1943, the Germans had seized 600,000 hogs, 275,000 cows and 30,000 tons of preserved meats.

The data is given in the testimony of the representative of the Netherlands Government, which I submit as Exhibit RF 133.

In passing I point out - although this question will be taken up again by my colleague in his presentation of War Crimes against persons - that on 17th April 1944, without any apparent strategic reason, twenty hectares of cultivated lands were flooded at Wieringermeer.

Transports and Communications :

The Germans made enormous levies on material, transport and communication. It is not yet possible to draw up an exact inventory of them. Nevertheless, the information given by the Netherlands Government makes it possible to form an idea of the magnitude of these spoliations.

I submit, as Exhibit RF 134, information given by the representative of the Netherlands Government concerning transport and communication. This is a summary:

(a) Railways

Of 890 locomotives 490 were requisitioned.
Of 30,000 railway cars 28,950 were requisitioned
Of 1,750 passenger cars 1,466 were requisitioned.
Of 300 electric trains 215 were requisitioned.
Of 37 Diesel engined trains 36 were requisitioned.

In general, the little material left by the Germans was badly damaged by wear and tear, by military operations and by sabotage.

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In addition to rolling stock, the Germans sent to the Reich considerable quantities of rails, signals, cranes, turn-tables, repair cars, etc.

(b) The equipment was removed from the Hague and Rotterdam to German cities. Thus, for example, some 50 motor trams and 42 trailer cars were sent to Bremen and Hamburg.

A considerable amount of rails, cables and other accessories were removed and transported to Germany.

The motor buses of the street car companies were likewise taken by the occupying power.

(c) The Germans seized the greater part of the automobiles, motorcycles and about one million bicycles. They left the population only those machines which would not run.

(d) Navigation: The Germans seized a considerable number of barges and river boats, as well as a considerable part of the merchant fleet, totalling about 1,500,000 tons.

(e) Postal Equipment: The Germans seized a great number of telephone and telegraph apparatus, cables and other accessories, which has not yet been computed. 600,000 radio sets were confiscated.

Forced labour for the occupier: From information given by the Netherlands Government, which I submit as Exhibit RF 135, a great number of Dutch workers were obliged to work either in Holland or in Germany. About 550,000 were deported to the Reich, which represents a considerable number of man- hours lost to the national production of the Netherlands.

Plunder of the Royal Palaces:

The furniture, private archives, the stables and carriages and wine cellars of the royal house were plundered by the Germans. In particular, the Palace of Norrdeinde was completely looted of the movable contents, including furniture, linen, silverware, paintings, tapestries, art treasures and household utensils. A certain number of these were removed from the Palace of Het Loo and were to be used in a convalescent home for German generals.

The archives of the royal family likewise were stripped. This is manifest from a report given by the representative of the Netherlands Government, which I submit as Exhibit RF 136.

Pillage of the city of Arnhem.

Besides numerous cases of individual looting, which are not the matter of the present subject, there was systematically organised pillage of entire cities. In this manner the town of Arnhem was despoiled in October and November 1944.

The Germans brought miners in from Essen who, under military orders, proceeded, in specialised gangs, to dismantle all the removable furniture, and send it with goods of all kinds to Germany. This is manifest in the testimony given by the representative of the Netherlands Government, which I submit as Exhibit RF 137.

The consequences of economic plundering in the Netherlands are considerable. We shall just mention that the enormous decrease in the national capital will have, as corollary, a production inferior to the needs of the country, for many years yet to come.

But the gravest consequence is that affecting the public health, which is irreparable. The excessive rationing, over many years, of food, clothing, and fuel, ordered by the occupant to increase the amount of spoliation, had brought about a debilitation of the population.

The average calory consumption by the inhabitants, which varied between 2,800 and 3,000 dropped in large proportions to about 1,800 calories, finally to fall in April 1945 as low as 400.

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Not until March 1945 was this inhuman measure lifted; but it was too late. The famine had already become general. The death rate in the cities of Amsterdam, The Hague, Leyden, Delft and Gouda increased considerably, rising from 19 to 60 per cent. Diseases which had almost been eliminated from these regions, reappeared. Such a situation will have irreparable consequences for the future of the population.

These facts are manifest in two reports which I submit as Exhibits RF139 and 140.

By ordering such severe rationing measures to get for themselves products indispensable to the existence of the Dutch, an act which was contrary to all principles of International Law, I may say that the German leaders committed one of their gravest crimes.

My explanations concerning Holland are concluded. My colleague, M. Delpech, will now state the case for Belgium.

M. DELPECH: Mr. President, gentlemen, I have the honour of presenting to the Tribunal a statement on the economic plundering of Belgium.

As early as 1940 the National Socialist leaders intended to invade Belgium, Holland and Northern France. They knew that they would find there raw materials, equipment, and the factories which would enable them to increase their war potential.

As soon as Belgium had been occupied, the German military administration did its best to reap the maximum benefit. To this end the German leaders took a series of measures to block all existing resources and to seize all means of payment. Important supplies built up during the years 1936 to 1938 were the object of enormous requisition. The machines and equipment of numerous factories were dismantled and sent to Germany, bringing about the closing down of many of them and in many sectors their forced consolidation.

Given the highly industrial character of this country, the occupying authorities imposed a very heavy tribute upon Belgian industries. Nor was agriculture spared.

The third part of the French economic expose deals with a study of all these measures. This will be the subject of four chapters. Chapter I deals with the German seizure of the means of payment. The second chapter will treat the clandestine purchases and an exposition of the black market. Chapter 3 will deal with the purchases of apparent regularity. The fourth chapter will concern impressment. In the fifth chapter the acquisition of Belgian investments in foreign concerns will be presented to the Tribunal, before concluding and emphasising the effect on the public health of the German intrusion. Finally, a few remarks will be presented concerning the conduct of the Germans after they had annexed the Grand Duchy of Luxembourg.

CHAPTER I: German seizure of means of payment. To enslave the country from an economic point of view, the most simple procedure was to secure the possession of the largest part of the means of payment and to make impossible the export of currency and valuables of all kinds.

There is an order of 17 June, 1940, which forbids the export of currency and valuables of all kinds. This order was published in the 'Verordnungsblatt' for Belgium, Northern France and Luxembourg and will hereafter be called by its usual abbreviated form 'V.O.B.E.L.' This order was published in 'V.O.B.E.L. No. 2' and is submitted as Exhibit RF 98. In the 'V.O.B.E.L.' of the same date appeared a notice dated 9 May, 1940, which regulated the

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By this means the Germans could buy, without furnishing any compensating consideration, all they desired in a country which had products of all kinds, without the inhabitants being able to protect their possessions against the invader.

The occupants used, in addition, three other methods for obtaining the largest part of the means of payment. These three methods were; the creation of a bank of issue; the imposition of war tribute under the pretext of maintaining occupation troops; and a system of clearing, functioning to their own profit. These measures will be treated in three sections to be hereafter developed.

Section I: Establishment of a Bank of Issue. As soon as they arrived in Belgium the Germans established an office for supervising banks, entrusted at the same time with the control of the National Bank of Belgium. This was ordered on 14 June, 1940, (V.O.B.E.L. No. 2) which is submitted as Exhibit RF 141.

At this time the directorate of the National Bank of Belgium was outside the occupied territories. On the other hand, the amount of notes on hand would be insufficient to insure normal circulation, as a great number of Belgians had fled before the invasion, taking with them an important quantity of paper money.

These are, at any rate, the reasons which the Germans put forward for establishing the Bank of Issue, as of the ordinance of the 27th of June, 1940, published in 'V.O.B.E.L. No. 4 and 5', which I submit as Exhibit RF 142.

By virtue of this last ordinance, 21 June 1940, the new Bank of Issue with a capital of 150,000,000 Belgian francs, 20 per cent of which had been issued in cash, received the monopoly for issuing paper money in Belgian francs. As a matter of fact, the National Bank of Belgium no longer had the right to issue money. The issue of this bank was not backed by gold but:

1. By credits from discount operations and loans granted in conformity with article 8 of the new statutes.

2. By claims of the National Bank of Belgium as well as coin which was in circulation for the account of the public treasury.

3. Finally, by the third device: by circulation in foreign currency and francs particularly, German money which comprised occupation marks as well as assets of the Reichsbank at the Office of Compensation for the Reich and the Reich Credit Bank.

After the return to Belgium of the directors of the National Bank on 10 July, 1940, an agreement between this bank and the new Bank of Issue was effected by the nomination of the head of the new issuing bank to the position of director of the National Bank of Belgium.

The Bank of Issue proceeded to put out a large amount of notes. On 8 May, 1940, the currency in circulation amounted to 29,800,000,000 Belgian francs. On 29 December, 1943, it amounted to 93,200,000,000 Belgian francs, and on 31 August, 1944, it was 100,200,000,000 Belgian francs, that is to say, an increase of 235 per cent.

The Bank of Issue worked, but not without certain difficulties, either with the military government, its own staff, or with the National Bank of Belgium. Actually, besides its function of issuing, the new bank had, as a principle function, the operations relating to postal checks and to currency; as well as

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The National Bank of Belgium lost its right to issue paper money, but resumed its traditional operations of private as well as State accounts, notably transactions on the open market.

These data, gentlemen, are corroborated by the final report of the German military administration in Belgium, 9th part, treating of currency and finances. This final report of the German military administration in Belgium was discovered by the U.S. Army, and it is a document to which we shall refer many times. It is No. E.C.H.5, and is submitted to the Tribunal as Exhibit RF 144.

The 9th part, which is of interest here, was written by three chiefs of the administration section of Brussels, Wetter, Hofrichter and Jost.

In spite of the establishment of the bank of issue, the occupation marks were valid in Belgium until August 1942, but it was the National Bank of Belgium that was obliged to absorb these notes in September 1944, and, owing to this, the Belgian economy underwent a loss of 3,567,000,000 Belgian francs. (This number is given by Wetter in the foregoing report, Page 112, excerpt of the report, which is submitted as Exhibit RF 145.)

Moreover, from information given by the Belgian Government, the issuing bank had in hand at the moment of liberation of the territory, a sum totalling 664,000,000 in occupation marks, drawn up in Reichsmark, and further, it had assets in a transfer account of 12 million Reichsmark on the books of the Reich Credit Bank, that is to say, a total loss of 656,000,000 Belgian francs. (This number is given in a report of the Belgian Government which is deposed in the archives of the Tribunal under Exhibit RF 146.)

Let us now treat the occupation costs. Article 49 of the Hague Convention stipulates that, if the occupant takes contributions in cash, it will only be for the needs of the army of occupation or for the administration of the territory. The occupant can, therefore, deduct a contribution for the maintenance of his army, but this must not exceed the sum strictly necessary. On the other hand, the words "needs of the army of occupation" do not mean the expenses of armament and equipment, but solely the normal costs of billeting, food, and pay, which exclude in all cases luxury expenses.

Moreover, Article 52 authorises the occupying authority to exact, for the use of its army, requisitions in kind and in service, on the express condition that they shall be proportionate to the resources of the country, and that they should not involve the population with the obligation to take part in military operations against their own country. The same Article 52 stipulates, moreover, that levies in kind will be, as far as possible, paid in cash.

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