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National Threat Assessment 2008. Organised Crime - Politie

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special investigation services. There are a number of reasons why the recorded<br />

information is incomplete. For example, people do not have to report<br />

environmental crimes, crime involving soil is difficult to establish and the<br />

legislation is complex. In recent years hardly any criminal investigations have<br />

been conducted into soil remediation crime. However, a number of examples<br />

provide some insight into the scale:<br />

• The Netherlands Police Agency’s Department of International Police<br />

Information (IPOL) receives an average of two reports per month about<br />

possible malpractices in relation to soil remediation;<br />

• Within a couple of months, a campaign by <strong>Crime</strong>stoppers Netherlands<br />

resulted in 11 reports of illegal activities involving soil remediation;<br />

• An investigation by the Netherlands Court of Audit noted that it was unclear<br />

where the contaminated soil was transported to and where the clean soil<br />

came from in a quarter of the remediation cases that were investigated;<br />

• An investigation by the Inspectorate of the Ministry of Housing, Spatial<br />

Planning and the Environment showed that 15 out of the 21 remediation<br />

operations investigated did not meet the remediation objective, whilst the<br />

evaluation report stated that the objective had been achieved;<br />

• That same investigation revealed a significant deviation from the official<br />

remediation result in 75% of the cases investigated (i.e. the level of residual<br />

pollution was greater than stated in the evaluation report). In a few cases<br />

public health was even at risk;<br />

• An investigation carried out by the Amsterdam-Amstelland regional police<br />

force showed that 70% of the transports investigated were in breach of the<br />

Soil Protection Act. These transports mainly involved the illegal disposal of<br />

contaminated soil.<br />

The above examples may give the impression that the entire soil remediation<br />

sector is systematically involved in criminal behaviour. This is not the case, but<br />

supervisors, enforcers and representatives of investigating authorities do agree<br />

that malpractices occur regularly in the soil remediation sector.<br />

3.4.4 Criminal organisation<br />

Many of the companies simply carry out their activities according to the rules.<br />

Other companies operate ‘on the edge’ of what is permitted, some companies<br />

go ‘over the edge’ by violating the rules.<br />

There are two categories of offenders. On the one hand, there are the incidental<br />

offenders and, on the other hand, the systematic offenders (the so-called ‘free<br />

riders’). The former group consists of company employees who originally were<br />

116 <strong>National</strong> <strong>Threat</strong> <strong>Assessment</strong> 2008 – <strong>Organised</strong> crime

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