Let $S_k(n)$ be the maximum number of orientations of an $n$-vertex graph $G$ in which no copy of $K_k$ is strongly connected. For all integers $n$, $k\geq 4$ where $n\geq 5$ or $k\geq 5$, we prove that $S_k(n) = 2^{t_{k-1}(n)}$, where $t_{k-1}(n)$ is the number of edges of the $n$-vertex $(k-1)$-partite Tur\'an graph $T_{k-1}(n)$, and that $T_{k-1}(n)$ is the only $n$-vertex graph with this number of orientations. Furthermore, $S_4(4) = 40$ and this maximality is achieved only by $K_4$.

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