A/HRC/36/47 example, it is noted that those involved in private security activities have no public authority powers, must wear a uniform, cannot use the titles and insignia of the authorities and cannot prevent the authorities from carrying out their activities. 93 Similarly, the legislation of Central American States provides that to avoid confusion, uniforms, credentials, logos and vehicle colours similar to those used by the police or the armed forces cannot be used.94 30. In general, legislation typically prohibits all activities that private security companies are not entitled to carry out according to their licence. In addition, in France, in the States of francophone Africa, and also for example in Uruguay and in the Province of Buenos Aires, private security companies are not allowed to be involved in labour conflicts or in political or religious events, or to gather information on political, religious or trade union opinions. Furthermore, private military and security companies are in general prohibited from carrying out activities reserved for the armed forces and the police. Some States’ legislation further specifies this prohibition or provides similar provisions, including that of the Democratic Republic of the Congo, Morocco and Tunisia, as well as that of the Plurinational State of Bolivia, Colombia, Ecuador and Peru. In some of the reviewed countries of the Asian region, private security companies are prohibited from conducting criminal investigations95 or from exercising specific powers conferred on police, customs, immigration and prison officers. 96 In Central America, the list of prohibited activities is extended to the roles played by the administration or the judiciary 97 and to investigations that are the exclusive competence of the Public Prosecutor’s Office or the national police.98 Guatemalan law is the most detailed and provides that private security cannot assume functions that are the tasks of the Government. 99 31. The legislation of the United States limits the outsourcing to private military and security companies of “inherently governmental functions” and provides a detailed list of those activities that “are so intimately related to the public interest as to require performance by Federal Government employees”. 100 By excluding the “inherently State functions” from the ambit of the activities of private military and security companies, the United States appears to draw the line between permitted and prohibited activities for private military and security companies, with reference to combat and combat-related activities. However, this does not specifically address “high-risk activities”, which would include a number of functions even outside of combat. Additionally, there is no clear enforcement mechanism for ensuring that agencies comply with the exclusion of “inherently governmental functions”, which is particularly worrying considering the dramatic expansion of the government contractor industry and the massive increase in the role and involvement of contractors in intelligence analysis and targeting decisions. 32. With regard to direct participation of personnel of private military and security companies in hostilities, the study shows that with the exception of Switzerland, 101 States’ national legislation does not address this specific question, and in cases where legislation prohibits personnel of private military and security companies from carrying out certain activities of the police and the armed forces, it is not clear whether the related provisions apply only in times of peace or during armed conflicts as well. Regarding the involvement of law enforcement officers in the activities of private military and security companies, the 93 94 95 96 97 98 99 100 101 Act CXXXIII of 2005, art. 2. The laws of Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua and Panama. In Malaysia and the United Arab Emirates. In Malaysia and Pakistan. Costa Rica. El Salvador and Mexico. Guatemala. Federal Activities Inventory Reform Act of 1998, sect. 5.2, and Office of Management and Budget circular A-76, Inventory Process B.1.a. United Kingdom law does not define what military or security activity can be outsourced to private companies, but there is an understanding that military activity in situations of armed conflict can be delivered only by military personnel under the command of a commissioned officer. (See A/HRC/22/41, para. 53, and the response of the Government of the United Kingdom to the Working Group’s request for national legislation and regulations on private military and security companies.) 11