En Danwatch-undersøgelse

Despite a Danish export ban, Denmark’s largest IT company is arming the UAE military

Charlotte Aagaard

Journalist / Mobile or Signal: +45 20840040

Emilie Ekeberg

Journalist / Mobil: +45 53771104 / Signal: +47 45033479

Charlotte Aagaard

Journalist / Mobile or Signal: +45 20840040

Emilie Ekeberg

Journalist / Mobil: +45 53771104 / Signal: +47 45033479

Illustration and graphics: Sarah Hartvigsen Juncker, Johan Seidenfaden / Video: Roselyn Min

Redaktør: Jesper Hyhne | Executive Editor: Jesper Nymark | Vil du vide mere om denne undersøgelse, kan du kontakte Danwatch her

Published in collaboration with TV2 and Lighthouse Reports
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20. September 2021
Systematic A/S, a software and systems company headquartered in Aarhus, Denmark, never ceased to supply military software to the UAE, even though Denmark has put a stop to all military exports to a country suspected of war crimes in Yemen. Experts estimate that the IT company actively circumvents a Danish export ban.

In Denmark, exporting military equipment to the United Arab Emirates is forbidden.

In late autumn 2018, the Danish government suspended all new arms export authorizations to the tiny Gulf state, due to a perceived risk that products could be used in the ongoing war in Yemen, in which UAE has played and continues to play a leading role.

At the time, 85,000 children had already starved to death as a result of a war that has prompted what the UN describes as “the world’s worst humanitarian crisis”.

Today, almost three years later, the UEA’s war in Yemen goes on. And so does business in the UAE for Denmark’s biggest IT company, Systematic A/S.

Despite the export ban, Systematic continues to supply and implement SitaWare, an advanced command and control system, to the Emirati military. 

Systematic’s continued rearmament of a warring country is exposed in accounts on social media, job advertisements, annual reports and freedom of information requests into Systematic’s activities, which Danwatch has investigated in collaboration with TV2 and the international research center Lighthouse Reports.

Human rights organizations consider it highly problematic for a Danish company to continue in supplying military software to the UAE, which stands accused of committing serious war crimes in Yemen.

“There is a very high risk that equipment exported to the UAE would be used in serious violations of human rights and International Humanitarian Law in Yemen”, says Patrick Wilcken, an expert in arms control at Amnesty International. 

A Yemen expert at Human Rights Watch, Afrah Nasser, agrees.

According to the UN, about 400,000 Yemeni children are so malnourished that they risk dying soon. One of those who has starved because of the food blockade imposed by the UAE is Fatima Ibrahim Hadi, who weighs only ten kilos. Photo: Khaled Abdullah/Reuters.


How Systematic continues its export to the UAE

In the autumn of 2018, only three weeks after the Danish authorities rejected Systematic's application for military export to the Emirates, Systematic applied for an export permit from a British subsidiary.


Systematic is granted three permits from the Danish authorities to export SitaWare to the Emirates.

November 22, 2018:

Denmark decided to suspend all future military exports to the Emirates with reference to the Yemen war.

February 12, 2019:

The UK authorities gave Systematic permission to export SitaWare to the Emirates.

How Systematic continues its exports to the UAE

As the Danish authorities put a stop to Systematic’s exports to the Emirates in the fall of 2018, Systematic’s British subsidiary applied for export permits in the UK. 


Systematic was granted three permits from the Danish authorities to export SitaWare to the Emirates.

November 22nd 2018

Denmark decided to suspend all future military exports to the Emirates with reference to the Yemen war.

November 22nd 2018
February 12th 2019

The UK authorities gave Systematic permission to export SitaWare to the Emirates.

February 12th 2019

According to the UN, the war in Yemen has already caused more than 230,000 deaths, and the UN expects that the country is now heading for the worst famine disaster the world has seen for decades.

The Emirates are accused of being co-responsible for the hunger in Yemen by keeping food and emergency aid from reaching the country.

A British loophole

A British subsidiary became an alternative channel when the Danish government put an end to Systematic’s exports to the Emirates.

In the years before the export ban, Systematic, which also delivers customised IT solutions such as electronic patient records and library lending systems to the public sector in Denmark, exported its military software products to the UAE directly from their head office in Aarhus. 

On 16 October 2018 however, the Danish Ministry of Foreign Affairs discontinued the company’s exports in order to eliminate any risk that it could be instrumental in serious human rights violations.

Only three weeks later, on November 8th 2018, Systematic’s British subsidiary applied for an export permit to the United Arab Emirates in the UK. On November 28th 2018 Systematic applied for yet another export license in the UK.

This comes into view in a number of documents from the British and Danish authorities, which Danwatch, TV2 and Lighthouse have been able to access.

To this day, Systematic continually supplies the UAE with military software, now simply exported from Denmark to the Emirates via its British subsidiary. 

Systematic insists, however, that they are not doing anything wrong when exporting Danish military software to the UAE via the United Kingdom.

“It goes without saying that we do not seek to bypass Danish rules”, the company’s press manager, Maia Lindstrøm Sejersen, stated in an email to Danwatch.

Job ads point to close collaboration 

The IT company’s ongoing deliveries of military software to the Emirates appear, among other things, from a number of job ads published on Emirati job portals in 2020 and 2021.

They show that several times since the Danish export ban came into force in 2018, Systematic has advertised for hiring professionals to supply and implement SitaWare within the Emirati military systems.

“Our engagement in the United Arab Emirates is growing, and we need an ambitious and experienced manager”, a job posting from the summer of 2020 reads.

It further states that Systematic’s office in Abu Dhabi is looking for a project manager for “the delivery, deployment and support” of the SitaWare and IRIS product packages for the Emirati Navy.

The job postings also show that the joint venture with the UAE Armed Forces takes place in close co-operation with the Danish head office. 

The job ad from Systematic specifies that the project manager, who is assigned to implement SitaWare for the Emirati Navy, must also be able to pay regular visits to Systematic’s headquater in Aarhus, and must possess “natural ability to build bridges between Systematic’s office UAE and our headquarters in Aarhus, Denmark”.


In a job ad with an application deadline of 1 August 2020, Systematic is looking for a project manager for the delivery and implementation of military software for the UAE Armed Forces, almost two years after the Danish authorities imposed a ban on all military exports to the UAE because of the war in Yemen

SitaWare, according to experts, is a crucial contribution to the armament of the UAE military. 

It is a command and control system that makes it possible to monitor and coordinate military operations as they unfold in real time. Experts describe this capacity as the heart of modern warfare, and therefore the very same system is also used by Denmark, the United States and a number of other NATO countries to create an overview during military operations, coordinate attacks and designate bomb targets.

The UAE and the rest of the Saudi-led coalition have bombed countless civilian targets, including residential areas, markets, mosques, schools and hospitals during the six-year war. The photo shows the Chamber of Commerce in Sana’a after a bomb raid. Photo: Belkis Wille/Human Rights Watch

Circumventing Danish rules 

Danwatch and TV2 spoke with several experts who all concur in the view that Systematic’s exports to the Emirates very much look like a deliberate circumvention of the Danish export ban.

“Certainly, it seems that they are applying for export licenses in the UK to circumvent the ban”, says Tom Kirchmaier, professor of economic crime at Copenhagen Business School and the London School of Economics.

SitaWare is a military software, developed by the Aarhus company Systematic.

Its primary use is to coordinate efforts on the battlefield and to enable all military units to follow military operations as they unfold in real time. 

“I do not necessarily think that they are breaking the letter of the law, but they are circumventing it. It is very clear that they are breaking the spirit of the law,” he says.

His assessment is backed up by William Hartung, an expert in international arms trade at the American think tank Center for International Policy:

“Using a subsidiary to export to the UAE is a way to undermine the spirit of the Danish government decision to stop arming the UAE”, William Hartung said.

“If this is legal, it is a huge loophole in the Danish export regulations”.

Systematic denies any allegation that their application in November 2018 for an export permit in the UK was a deliberate attempt to bypass Denmark’s export ban.

“It is our normal business practice for our office in the UK to handle customers outside the Nordic region and Northern Europe”, the company’s press manager Maia Lindstrøm Sejersen explains in an email to Danwatch.

Play Video

How Systematic are still delivering software to the  Emirates

See how Systematic still manages to deliver military software to the Emirates despite a Danish export ban.

The press manager refers to the fact that Systematic also applied for export permits to the Emirates from the United Kingdom in 2011 and 2013. 

However, these permissions only concerned a go-ahead to demonstrating SitaWare to potential customers. 

The next time Systematic was granted export licenses to the Emirates was in 2016 and 2017, and both authorizations came from the Danish authorities, with the UAE Armed Forces as the stated recipient.

Application withdrawn 

In the autumn of 2018, Systematic ran into problems with renewing their authorizations from the Danish authorities.

An access to information request at the Danish Ministry of Foreign Affairs shows that it had become an urgent matter for Systematic to obtain permission to continue exporting military software to the Emirates.

“It is important that we get the permit”, an employee of Systematic writes in mid-August 2018 to a special adviser in the Ministry of Foreign Affairs’ security policy department.

Systematic is Denmark’s largest IT company with more than 1,000 employees and a turnover of more than one billion Danish Kroner.

The company provides customised IT systems to the public sector, such as healthcare, libraries and the education sectors. Systematic also has a subdivision, Systematic Defense, which specializes in the development of advanced military software.

The most important military products are the SitaWare command and control system, and the IRIS communication system. Systematic is founded, owned and managed by director Michael Holm, who also holds board positions in, among others, Jyllands-Posten’s Foundation and Moesgaard Museum.

In June this year, the Danish government appointed Michael Holm as chairman of the climate partnership in the field of defense. Systematic is headquartered in Aarhus, but also has offices in ten other countries, including the UK and the UAE. 

Systematic’s Danish export permit to the Emirates had just expired, and it was imperative to get a new one. This emerges in a number of follow-up emails from Systematic.

“We are unable to understand why this cannot simply be arranged momentarily”, a Systematic- employee wrote a month later.

But to no avail.

16 October 2018, the Ministry of Foreign Affairs wrote in a consultation response to the Ministry of Justice that Systematic’s application could not be granted.

The Ministry of Foreign Affairs referred to criteria 2 and 4 of the EU Common Rules on Arms Exports, which state that member states may not export military equipment if this involves a serious risk that it could be used in gross human rights violations.

The day before, on October 15, 2018, Systematic sent a short email to the Ministry of Justice and withdrew its application.

“Please confirm receipt of the withdrawal,” Systematic’s employee wrote.

Systematic denies having withdrawn the application because of the Danish authorities’ export ban to the Emirates.

“We have not been aware of the consultation response you are referring to”, press manager Maia Lindstrøm Sejersen wrote with reference to the Ministry of Foreign Affairs’ rejection. 

“We withdrew our application because we did not receive an expected order. Systematic UK’s export applications from November 2018 have nothing to do with the missing order”, she further stated.

Freedom of information requests in Denmark and the United Kingdom confirm that in both cases the application concerned a license to export SitaWare to the UEA Armed Forces, but information about the specific software licenses and recipient addresses are crossed out in the documents at hand.

Systematic itself has refused to document that the Danish and British applications concern different products and recipients.

“We cannot share commercially confidential information and documents regarding our agreements, offers and orders with customers with the media”, Systematic’s press manager said.

On November 22, 2018, the Danish government suspended all military exports to Saudi Arabia and the Emirates, because of the war in Yemen. In February 2019 however, Systematic was given a green light by the British authorities to continue their exports to the Emirates.

Systematic’s export licenses in the UK are valid until spring 2024.


The UAE’S dirty war in Yemen

The United Arab Emirates and its local militias are accused by UN experts and human rights organizations of having committed countless atrocities and possible war crimes during the six-year war in Yemen.


Since the war’s inception, the Saudi-led coalition which The UAE is part of, has shown a blatant disregard for civilian casualties and carried out at least 65,000 airstrikes, including thousands against residential areas, hospitals, schools, health clinics and more. According to the Yemen Data Project, a third of the coalition's airstrikes have hit civilian targets.


The UAE has also set up, funded and trained more than 90,000 local militia forces with gross human rights violations on their conscience. The Southern Transitional Council, Security Belt Forces and Joint Forces in the Western Gulf are responsible for widespread attacks on civilian targets, civilian killings, extreme violence, disappearances, imprisonment and torture. 


Den saudisk-ledede koalition har løbende blokeret Yemens havne og lufthavne for at forhindre fødevarer i at nå frem frem til den tredjedel af landet, som kontrolleres af Houthi- oprørerne, der bekæmper Yemens  regering.

The Saudi-led coalition has continuously blocked Yemen's ports and airports to prevent food from reaching the third of the country which is controlled by Houthi rebels fighting the Yemeni government. According to the UN, the current level of hunger in Yemen is unprecedented. The UN currently feeds 20 million people. 


During the war, the Emirates and their loyal militias have set up at least 27 secret torture prisons in southern Yemen and at the Assab military base in neighboring Eritrea.

Human rights organizations have documented thousands of disappearances, incarcerations and cases of torture in these prisons.


The UAE has taken an active part in the Yemen war with thousands of soldiers on the ground. Its armed forces have shelled civilian targets with heavy artillery. Among the targets are hospitals, residential areas and markets.

In 2020 alone, human rights organizations documented 33 attacks on civilian targets. 


The UAE has also established death patrols consisting of i.a. American mercenaries, who themselves have testified how they executed religious leaders in the Aden area in 2015. Human rights organizations subsequently documented how executions of religious leaders continued in Aden in 2017-2018. 

CEO has ’no idea’ whether Sitaware was used in Yemen

The UAE is currently waging war in Yemen for the seventh year, and for almost as long, organizations such as the UN, Amnesty International, Human Right Watch and Médecins Sans Frontières have warned of war crimes and violations of the Geneva Conventions.

Military experts believe that there is a high risk that the UAE will use the Danish command and control system in their controversial warfare.

“It would hardly make sense if the system was not used in Yemen”, said Pieter Wezeman, a military researcher at the Stockholm Peace and Research Center, SIPRI, referring to the fact that the Emirates desperately need overview data in complex battlefield arenas such as Yemen – exactly the kind of data SitaWare can provide.

Today, Systematic’s director Michael Holm does not want to make himself available for an interview by Danwatch and TV2. But in an previons interview from February 2021, he said he did not know whether the UAE military had used Systematic’s products to wage its war in Yemen.

“I have no idea. But they have a number of licenses that they can use wherever they want”, he said. 

End user unknown

Systematic’s latest Danish license to export their military software SitaWare and IRIS from Aarhus to the subsidiary in the UK states that “the end user is unknown”.

Systematic applied for the permit in November 2020, several months after they posted local job advertisements for employees to implement SitaWare and IRIS at the Emirates military.

Systematic’s UK subsidiary has been in existence since 1992. According to account data, there are extensive exports form the subsidiary to the ’rest of the world’ – a category, which consists of undefined countries outside the UK and the EU.

In an email, Systematic’s press manager explains that the export via the UK takes place on a basis of Danish licenses to export a ’master version’ of each of Systematic’s standard products from Denmark to the subsidiary in the UK.

The UK subsidiary then copies the software licenses and exports them to their respective customers ’with possible modifications’, Systematic explains in an email.

“In that way, Systematic UK can deliver Systematic software to customers around the world based on the English export permits, issued on the basis of English rules”, Systematic’s press manager, Maia Lindstrøm Sejersen, explained.

Ignoring Danish policy makers

Systematic’s ongoing exports to the UAE contravene promises from both the previous Lars Løkke cabinet as well as the current Social Democratic government.

On numerous occasions, current Foreign Minister Jeppe Kofod has emphasized that Denmark should refrain completely from exporting military equipment to the UAE.

“My line is very clear: weapons and military equipment should not be exported to either Saudi Arabia or the United Arab Emirates from Denmark, as long as the products in question risk being used in the Yemen conflict”, Denmark’s foreign minister said in May 2020.

Still, Systematic’s CEO, Mr. Michael Holm does not think he is doing anything wrong by having his company continuing its exports to the UAE from the company’s subsidiary in the UK.

He also does not believe that the Danish authorities are entitled to know who the end user could be. 

“We do not always have to have an end-user certificate. For example, we can sell our products to our English company, which in turn can sell them on without us having to tell Denmark’s authorities where it’s going,” he told TV2 and Danwatch in February 2021.

Tom Kichmaier, a professor of governance at Copenhagen Business School, does not buy that explanation:

“There is a political agreement in Denmark to stop exports to the UAE. Are Danish policy makers happy to be so blatantly ignored?” he asks. 

en danwatch-undersøgelse
20. September 2021

Charlotte Aagaard

Journalist / Mobile or Signal: +45 20840040

Emilie Ekeberg

Journalist / Mobil: +45 53771104 / Signal: +47 45033479

Charlotte Aagaard

Journalist / Mobile or Signal: +45 20840040

Emilie Ekeberg

Journalist / Mobil: +45 53771104 / Signal: +47 45033479

Illustration and graphics: Sarah Hartvigsen Juncker, Johan Seidenfaden / Video: Roselyn Min

Editor: Jesper Hyhne | Executive Editor: Jesper Nymark | Need more information about this investigation? Please contact us here

Published in collaboration with TV2 and Lighthouse Reports

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