HSBC Economic Audit

Audit Phase: V-ECON
Target Entity: HSBC Holdings plc
Incorporated: England and Wales (Companies House No. 00617987) ⁷
Headquarters: 8 Canada Square, London E14 5HQ
Audit Date: 2026-05-01
Data Coverage: Training data through April 2026; live web search unavailable at time of drafting.

Scope Note: HSBC Holdings plc is a globally systemically important bank (G-SIB) and diversified financial services conglomerate. It is not a retailer, agricultural importer, product manufacturer, or logistics operator. Several standard V-ECON supply-chain and labeling sub-categories are structurally inapplicable to HSBC’s business model and are recorded as such below. The primary zones of material relevance are investment, capital markets activity, asset management exposure, and correspondent banking relationships.

Supply Chain & Sourcing Relationships

HSBC does not procure, source, import, distribute, or retail physical goods of any kind. The supply chain categories typically examined in a V-ECON audit — including agricultural aggregators, seasonal produce importers, Medjool date or citrus exporters, and cold-chain logistics operators — are structurally inapplicable to HSBC’s business model. ¹

• Direct supplier relationships with Israeli agricultural exporters: No public evidence identified. Named entities in the Israeli agricultural export sector — including Mehadrin, Hadiklaim, Galilee Export, and successor operations to Agrexco — have no documented commercial relationship with HSBC in any publicly available record, corporate filing, or NGO investigation reviewed. ¹
• Importer of record structure: No public evidence identified. HSBC has no known subsidiary or joint venture functioning as an importer of record for physical goods in any jurisdiction. ¹
• Seasonal sourcing patterns: No public evidence identified. Not applicable to HSBC’s sector or operating model. ¹
• Third-party and indirect sourcing: HSBC’s procurement activities, as disclosed in its Modern Slavery Statement, cover IT infrastructure, professional services, and facilities management. No Israeli agricultural supply chain linkage appears in HSBC’s supplier disclosures or Modern Slavery statements. ¹³ No NGO investigation reviewed — including those published by Who Profits ⁴ and Corporate Occupation ¹⁵ — cites HSBC in connection with settlement produce sourcing. The PAX June 2024 report “Companies Arming Israel and Their Financiers” likewise does not identify HSBC in any agricultural or physical goods supply chain capacity; HSBC’s appearance in that report is exclusively in the financier category relating to capital markets and asset management activity. ¹⁶

Product Origin, Labeling & Regulatory Compliance

As a financial services group, HSBC does not sell, label, package, or import physical goods. The labeling compliance categories in this section — including settlement-origin produce, country-of-origin marking obligations, and DEFRA Trading Standards compliance — are structurally inapplicable. ¹

• Settlement-origin products: No public evidence identified. HSBC is not cited in any NGO investigation or regulatory enforcement action in connection with the procurement or sale of goods originating in Israeli settlements in the occupied West Bank or Golan Heights. ⁴⁵¹⁵ The Don’t Buy Into Occupation 2024 (DBIO 2024) company list, produced by a coalition including Amnesty International, Stop the Wall, and CIDSE, does not identify HSBC among companies with direct settlement-economy operations or supply chain linkages to settlement activity. ¹⁷ No confirmed evidence from training data places HSBC on the DBIO 2025 company list; this constitutes an identified evidence gap requiring primary-source verification. ¹⁷
• UN OHCHR settlement database: HSBC is not identified in the UN OHCHR Database of Business Enterprises (established under HRC resolutions 31/36 and 53/25) in any confirmed public source or NGO reporting reviewed. ¹⁸ This is consistent with HSBC having no operational physical presence in settlements and no documented provision of retail banking, mortgage lending, or direct financial services to settlement entities. The database’s financial-sector entries have focused primarily on Israeli domestic banks providing mortgage and business lending within settlements; HSBC as a non-domiciled, non-branch-present foreign bank falls outside the typical profile of OHCHR-database listed entities. ¹⁸
• Labeling compliance (DEFRA / Trading Standards): Not applicable. HSBC is not subject to country-of-origin labeling regulations for produce under UK DEFRA frameworks. ¹¹
• Corporate labeling policy: No public evidence identified. Not applicable to HSBC’s sector. ¹
• Regulatory exposure — financial products and Israeli-linked assets: To the extent that HSBC’s asset management products hold Israeli-domiciled securities, those products are subject to standard fund prospectus disclosure requirements in relevant domicile jurisdictions (UK, Luxembourg, Ireland). No enforcement action or regulatory finding relating to inadequate disclosure of Israeli or settlement-related exposure in HSBC AM fund products has been identified in public records. ¹⁰

Investment, Capital & Financial Exposure

This is the principal domain of material relevance for HSBC in a V-ECON context. HSBC’s relationship with Israel and Israeli-linked economic activity is primarily expressed through capital markets intermediation, asset management index exposure, and historical direct presence rather than through physical investment or operational facilities.

Direct Operational Investment

HSBC opened a representative office in Tel Aviv in January 2011, intended to support trade finance, capital markets coverage, and corporate banking services for Israeli clients accessing international markets. ² This represented HSBC’s most substantive direct commercial presence within Israel.

Multiple sources in the financial press reporting from approximately 2015 indicate that HSBC closed or substantially wound down its Tel Aviv representative office as part of a wider global cost-reduction and footprint-rationalisation programme under then-CEO Stuart Gulliver. The closure reflected HSBC’s strategic withdrawal from markets deemed sub-scale relative to the operational cost of maintaining a physical presence. As of HSBC’s 2023 and 2024 Annual Reports, Israel is not listed as a standalone country operation, licensed banking subsidiary, or principal subsidiary in HSBC’s geographic footprint disclosures. HSBC operates across approximately 60 countries; Israel does not appear as a named jurisdiction with a licensed banking entity. ¹⁹ The precise date and formal closure instrument (such as regulatory deregistration) for the Tel Aviv office have not been confirmed from public filings and constitute an identified evidence gap.

No evidence has been identified of HSBC holding factories, data centres, logistics hubs, warehouses, or commercial real estate within Israel or the occupied Palestinian territories in any public filing or corporate disclosure. ¹

R&D and Technology Investment

No public evidence identified of HSBC operating a dedicated R&D facility, technology innovation lab, or accelerator programme within Israel. HSBC’s named global technology and innovation centres — located in the UK, India, Canada, Poland, and Hong Kong — do not include any Israeli facility. ¹

Following HSBC’s March 2023 acquisition of Silicon Valley Bank UK (subsequently rebranded HSBC Innovation Banking) ⁸, HSBC Innovation Banking expanded its mandate to serve technology and life sciences startups. The HSBC acquisition was limited to SVB’s UK legal entity specifically — it did not encompass SVB’s US parent, SVB’s Israeli operations, or any other component of SVB’s global network. SVB had historically maintained significant engagement with Israeli technology ecosystem companies as clients through its global network, including through a dedicated Israel office; those operations and client relationships were not part of the HSBC SVB UK acquisition. ⁸ Whether HSBC Innovation Banking UK has independently established relationships with Israeli-founded companies incorporated in the UK or with UK-based operations as clients is not confirmed in any public filing or press release as of the audit date. This constitutes a remaining identified evidence gap requiring primary-source verification.

Parent & Beneficial Ownership Structure

HSBC Holdings plc is incorporated in England and Wales (Companies House No. 00617987) and has been domiciled and headquartered in London since its 1993 relocation. ⁷ The largest disclosed shareholders as reflected in the 2023 and 2024 Annual Reports include Ping An Insurance Group of China (a stake that peaked at approximately 8–9% and was progressively reduced through 2022–2023 ¹⁴), BlackRock (~5%), and Vanguard (~4%). No Israeli state entity, Israeli sovereign wealth fund, or Israeli-domiciled institution is identified as a material beneficial owner of HSBC Holdings plc in any public filing. ¹ The Companies House persons of significant control register for HSBC Holdings plc does not record any Israeli-domiciled entity as a person or entity with significant control. ²⁴

Israeli-Nexus Floor assessment (I-ECON rubric — four factors):

• Founded or originally incorporated in Israel: Negative. HSBC was founded in Hong Kong (1865) and incorporated in England and Wales (1990). ⁷
• HQ or principal place of management in Israel: Negative. HQ at 8 Canada Square, London E14 5HQ; no Israeli management headquarters or principal management location. ¹
• Israeli tax residency or Preferred Technology Enterprise (PTE) status: Negative. No public evidence of HSBC or any HSBC group entity holding Israeli tax residency or PTE/R&D centre designation from the Israeli Innovation Authority. No Israeli regulatory registration as a licensed bank, branch, or PTE exists in public records. ¹
• Beneficially owned or controlled by Israeli capital: Negative. Major shareholders are Ping An (reduced stake), BlackRock, and Vanguard; no Israeli state, sovereign wealth, or institutional capital in the material ownership structure. ¹²⁴

All four I-ECON Israeli-Nexus Floor factors are negative. HSBC is a foreign financial institution with historical and ongoing commercial relationships with Israel, not an Israeli-nexus company.

Controlling Principals

Group CEO — Georges Elhedery (appointed September 2024, succeeding Noel Quinn): Georges Elhedery is a Lebanese-French national who built his career within HSBC, most recently as Group CFO before appointment as Group CEO. He previously led HSBC’s Global Banking & Markets division and its Middle East operations. ²⁸ No public evidence identified of personal or family-office investments by Elhedery in Israeli companies, Israeli-domiciled funds, Israeli real estate, or Israeli state instruments in any public disclosure, regulatory filing, or press report reviewed. Elhedery’s publicly discussed Middle East background pertains to Lebanon and the Gulf; no Israeli personal nexus has been reported. This constitutes an identified evidence gap given the partial visibility of personal investment disclosures. ²⁵

Former Group CEO — Noel Quinn (retired September 2024): No public evidence identified of personal or family-office investments by Quinn in Israeli companies or instruments in any public disclosure or press reporting reviewed. ¹

Group Chair — Mark Tucker (appointed 2017): Mark Tucker is a UK national and former CEO of AIA Group and Prudential plc. No public evidence identified of personal or family-office investments by Tucker in Israeli companies, Israeli sovereign bonds, or Israeli-domiciled entities in any public disclosure or press reporting reviewed. ²⁵

Group CFO — Pam Kaur (appointed 2024): No public evidence of Israeli personal investments or affiliations identified. ²⁵

Board-level: No shareholder holding ≥10% of HSBC Holdings plc has been identified as an Israeli-domiciled entity in any public filing. Personal investment disclosures at individual board-member level are only partially visible in public filings; undisclosed holdings cannot be confirmed or excluded, and this constitutes an acknowledged evidence gap across all principals.

Asset Management Portfolio Exposure (HSBC Asset Management)

HSBC Asset Management (HSBC AM), with assets under management exceeding $600 billion as of 2023, is among the world’s largest diversified asset managers. By virtue of running global index-tracking and active strategies, HSBC AM holds positions in Israeli-domiciled companies across multiple fund ranges:

• Index fund exposure: Israel has been classified as a developed market within the MSCI index framework since 2010. HSBC AM funds tracking the MSCI World, MSCI ACWI, and equivalent indices therefore hold Israeli equities — including Check Point Software Technologies, Teva Pharmaceutical Industries, Bank Hapoalim, and Elbit Systems — as a structural consequence of passive index replication rather than as a result of a discretionary investment decision. ¹⁰
• PAX June 2024 report — financier matrix: The PAX June 2024 report “Companies Arming Israel and Their Financiers” identifies HSBC as a financier of companies supplying materiel to the Israeli military, specifically through HSBC AM’s index-fund and discretionary holdings in aerospace and defence companies. ¹⁶ The PAX report distinguishes between primary suppliers directly providing weapons or equipment to the IDF and financiers whose exposure arises from portfolio holdings; HSBC is characterised in the financier category, not as a primary supplier. The report does not allege that HSBC made a discretionary decision to finance Israeli weapons procurement; it documents the structural consequence of HSBC AM’s scale and global index exposure. ¹⁶
• BDS and civil society documentation: The BDS Movement and affiliated civil society organisations have cited HSBC as a holder of Israeli government bonds and equities in Israeli defence companies, including Elbit Systems, on the basis of publicly available fund holdings data. ⁶ War on Want’s Palestine solidarity divestment campaign similarly identifies HSBC among its targets. ¹² The AFSC Investigate database maintains a profile of HSBC reflecting its asset management holdings in Israeli defence companies and its capital markets activity — categories consistent with the findings documented in this audit. ¹⁹
• BankTrack profile: BankTrack’s HSBC profile documents HSBC’s broader financing activities including capital markets intermediation and bond underwriting relevant to the Israeli economy, and has been referenced by civil society organisations monitoring HSBC’s Israeli-market relationships. ²⁰
• Elbit Systems: Elbit Systems is included in global aerospace, defence, and technology indices. HSBC AM’s index fund exposure to global defence sectors structurally includes Elbit. No confirmed evidence of HSBC AM holding a discretionary, non-index overweight position in Elbit Systems has been identified in publicly available stewardship or fund disclosure documents. ⁶¹⁰
• Israeli sovereign bonds (State of Israel / Makam): No confirmed public evidence of HSBC AM holding a named, disclosed position in Israeli sovereign bonds in its stewardship reports or product disclosures. The Israel Bonds (IGLD) programme functions primarily as a retail diaspora instrument; no HSBC institutional underwriting or distribution arrangement for Israel Bonds has been identified in public sources, and HSBC’s retail banking network has not been identified as a distributor of Israel Bonds to retail clients. ¹
• Proxy voting and stewardship: HSBC AM’s stewardship and proxy voting disclosures do not specifically identify Israeli companies as subject to escalation, engagement, or exclusion under its current responsible investment framework, beyond general sector-based policies. ¹⁰
• HSBC AM Responsible Investment Policy (2024): HSBC AM’s responsible investment policy includes ESG integration, engagement, and exclusion criteria. The policy does not include a sector-based exclusion of Israeli securities or an explicit settlement-economy screen. HSBC AM applies weapons-related exclusions (cluster munitions, anti-personnel mines, biological/chemical weapons per international convention) but these do not capture conventional arms manufacturers or settlement-economy companies as excluded categories. ²¹ HSBC AM is a signatory to the UN Principles for Responsible Investment (PRI); the PRI framework includes human rights due diligence expectations but does not mandate exclusion of Israeli securities. No confirmed evidence has been identified of HSBC AM updating its responsible investment policy specifically in response to the ICJ Advisory Opinion of 19 July 2024 or the ICC arrest warrants of 21 November 2024. ²¹
• ESG exclusion listings: Storebrand Asset Management’s published exclusion list has referenced HSBC, reflecting the broader civil society and SRI-sector concern about HSBC’s financial relationships with Israeli entities; the basis of Storebrand’s exclusion is understood to relate to HSBC AM’s holdings in Israeli defence sector companies including Elbit Systems. ¹ KLP (Norwegian pension fund) has not been identified as having excluded HSBC from its published exclusion list as of the training data coverage period. ²² The Norwegian Government Pension Fund Global (NBIM/Norges Bank) exclusion and observation list does not include HSBC in publicly available records from training data. ²³ No confirmed evidence has been identified that CDPQ or ISIF have specifically excluded HSBC from their portfolios on grounds related to Israeli market exposure. ²⁶²⁷
• Pension float and insurance subsidiary exposure: HSBC’s insurance subsidiaries (including HSBC Life) hold diversified bond and equity portfolios. The extent of any Israeli sovereign or corporate bond exposure within those portfolios is not separately disclosed in public filings and constitutes an identified evidence gap.

Capital Markets Intermediation

HSBC Global Banking & Markets has historically acted as bookrunner and lead manager on Israeli sovereign and corporate bond issuances in international capital markets. This activity — documented in bond prospectuses filed with relevant regulators — constitutes a fee-for-service investment banking relationship rather than a direct balance sheet exposure or equity investment by HSBC. ¹ HSBC’s Global Research function has maintained analyst coverage of Israeli corporates and macro coverage of the Israeli economy, supporting client activity in Israeli-linked securities. ¹ HSBC’s business trade corridor page targeting UK and international corporates seeking to transact with Israel reflects an active commercial orientation toward the Israeli market at the client-services level. ⁹

Post-October 2023 capital markets activity — critical evidence gaps:

• January–March 2024 Israeli sovereign bond issuance: Israel conducted a reported USD 8 billion sovereign Eurobond issuance in early 2024, described in financial press as one of the largest-ever Israeli international sovereign bond offerings. The syndicate for this issuance included multiple major international banks. HSBC’s specific participation or non-participation as bookrunner or co-manager in this syndicate is not confirmed from training data and constitutes a priority evidence gap. ¹
• Post-19 July 2024 (ICJ Advisory Opinion): The ICJ Advisory Opinion of 19 July 2024 placed third parties — including financial institutions — on constructive notice regarding obligations not to render aid or assistance that maintains the unlawful occupation. Whether HSBC participated in any Israeli sovereign bond syndication after this date is not confirmed in training data. This constitutes the single most material unconfirmed fact in this audit. ¹
• Public posture post-October 2023: No public statement by HSBC Holdings, HSBC AM, or any HSBC subsidiary specifically announcing a review, suspension, or continuation of Israeli capital markets activity post-October 2023 has been identified in training data. No public statement addressing the ICC arrest warrants of 21 November 2024 for Israeli Prime Minister Netanyahu and former Defence Minister Gallant in the context of HSBC’s Israeli market relationships has been identified. ¹

Group Attribution — Principal Subsidiaries

• The Hongkong and Shanghai Banking Corporation Limited (HBAP): The principal Asia-Pacific banking subsidiary. No Israeli operations, branches, or Israeli-market specific disclosures. HBAP’s trade finance operations may serve Asian companies trading with Israeli counterparties, but no specific Israeli documentation exists. ¹
• HSBC Bank plc (UK): The principal UK retail and commercial banking subsidiary. No Israeli branches or operations. HSBC Bank plc is the entity through which UK correspondent banking relationships with Israeli banks are most likely operated for UK trade finance purposes. ¹
• HSBC Continental Europe: European commercial banking subsidiary. No Israeli operations. EU-Israel Association Agreement trade flows would be facilitated through HSBC Continental Europe for European clients. ¹
• HSBC Innovation Banking (formerly SVB UK): As noted above, the HSBC acquisition was limited to SVB’s UK legal entity; SVB’s Israeli operations were not acquired. The remaining evidence gap is HSBC Innovation Banking UK’s own independent Israeli-originated client base. ⁸
• HSBC Asset Management: Structural index exposure to Israeli equities and potential sovereign bonds as documented above. ¹⁰¹⁶²¹
• HSBC Life / insurance subsidiaries: Israeli bond exposure within investment portfolios not separately disclosed. ¹
• HSBC Bank Middle East Limited (Dubai): HSBC’s primary MENA operating entity. No Israeli branch or operations; the Dubai entity is the focal point of HSBC’s Gulf commercial banking and does not extend into Israel. ¹

Operational Presence & Market Activity

Physical Footprint

HSBC’s current physical footprint within Israel is nil based on available public disclosures. The Tel Aviv representative office, opened in January 2011 ² and closed circa 2015 as part of global restructuring, represents HSBC’s only documented direct physical presence in Israel. As of HSBC’s 2023 and 2024 Annual Reports and corporate location disclosures, no licensed banking subsidiary, branch, registered office, or representative office in Israel is listed. ¹⁹

No offices, warehouses, data centres, retail locations, or operational support centres in the occupied territories (West Bank, Gaza Strip, Golan Heights) have been identified in any public record, NGO profile, or corporate disclosure. ¹¹⁵

Correspondent Banking

HSBC maintains correspondent banking relationships with major Israeli banks — including Bank Hapoalim, Bank Leumi, and Mizrahi Tefahot — enabling cross-border payment processing, trade finance letters of credit, and foreign exchange services for HSBC clients with trade or investment relationships with Israel. This is standard international interbank infrastructure and does not constitute a physical presence or direct investment. ¹

Indirect settlement nexus via correspondent banking: Both Bank Hapoalim and Bank Leumi are identified in NGO and academic literature — including Who Profits’ reporting — as providing mortgage, business, and infrastructure lending within Israeli settlements. ⁴ HSBC’s correspondent banking relationship with these banks therefore constitutes a documented indirect financial nexus to settlement-economy financial activity — interbank facilities enabling Bank Hapoalim and Bank Leumi to access international clearing, foreign exchange, and trade finance infrastructure. This is distinct from HSBC directly providing settlement-economy financing, but constitutes an indirect relationship operating at the interbank infrastructure layer. ⁴²⁹

Whether HSBC’s correspondent relationships with Israeli banks were maintained, reduced, or terminated following October 2023 is not confirmed in any public source reviewed; this constitutes an identified evidence gap.

Employment and Tax Contribution

No public evidence identified of HSBC employees formally based in Israel, employed under Israeli labour law, or registered for Israeli payroll tax purposes as of 2022–2025. HSBC’s geographic employee disclosures in its Annual Reports do not list Israel as a staffed jurisdiction. HSBC employed approximately 220,000 people globally as of 2023 reporting; none are attributed to an Israeli operation. ¹

Market Positioning

Israel does not appear as a named strategic market, high-growth priority, or regional hub in any HSBC Annual Report, investor day presentation, or investor relations communication reviewed for the period 2020–2024. ¹ HSBC’s Middle East and North Africa regional operations are anchored in Dubai (UAE), which serves as the hub for Gulf and broader MENA commercial and institutional banking. Israel is not included in HSBC’s named MENA or European regional cluster in public investor communications. ¹ HSBC’s Israel-facing trade corridor service page ⁹ positions the bank as a facilitator of trade and investment between Israel and international markets — a client-service orientation consistent with HSBC’s correspondent and capital markets role rather than with domestic market participation. Whether this page remained live, was taken down, or was modified post-October 2023 is unconfirmed. ⁹

Corporate Structure & Foundational Ties

Founding and Incorporation History

HSBC Holdings plc traces its origin to The Hongkong and Shanghai Banking Corporation, founded in 1865 by Thomas Sutherland in Hong Kong and Shanghai to finance trade between Europe and Asia. ⁷¹ The entity has no Israeli founding, no Israeli-origin brand identity, and no acquired subsidiary with Israeli operational heritage. HSBC Holdings plc itself was incorporated in England and Wales in 1990 as the holding company vehicle for the acquisition of Midland Bank; operational headquarters relocated from Hong Kong to London in 1993. ⁷

State and Institutional Linkages

No public evidence identified of any Israeli state ownership stake in HSBC, Israeli government-appointed board representation, Israeli Ministry of Finance or central bank governance relationship, or any HSBC designation as critical national infrastructure within Israel. ¹ HSBC is regulated as a G-SIB under the oversight of the UK Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA), with additional oversight from the Hong Kong Monetary Authority for its Hongkong and Shanghai Banking Corporation subsidiary. Its G-SIB designation by the Financial Stability Board is anchored in the UK and global financial system architecture, not the Israeli system. ¹

Governance and Charter Structure

No public evidence identified of golden shares, founder shares, charter restrictions, special shareholder rights, or governance mechanisms tying HSBC to Israeli state interests or policy objectives. HSBC’s Articles of Association and corporate governance framework conform to standard UK public company structures under the Companies Act 2006, the UK Corporate Governance Code, and applicable PRA rules. ⁷¹

ESG and Responsible Business Framework

HSBC’s ESG Data Pack and Sustainability Report do not contain specific disclosures relating to Israeli operations, occupied territory exposure, or settlement-economy engagement, consistent with the absence of a material operational presence in those territories. ³ HSBC’s Modern Slavery Statement does not identify Israeli supply chains as a category of concern, reflecting the absence of any goods-sourcing relationship in that geography. ¹³ The UK Government’s Overseas Business Risk guidance for Israel and the Occupied Palestinian Territories notes legal and reputational risks for UK businesses with exposure to Israeli settlement activity ¹¹ — risks that would apply to HSBC principally through its capital markets and asset management activities rather than through any physical supply chain.

Profit Repatriation & Economic Contribution

Revenue Attribution

HSBC does not disclose standalone Israel revenue in its geographic segment reporting. Financial results are reported by business line (Wealth & Personal Banking, Commercial Banking, Global Banking & Markets) and by region (Asia-Pacific, Europe, North America, Middle East & North Africa, Latin America). Israel does not appear as a named sub-segment or country unit within any of these reporting clusters. ¹ Any revenue generated from Israeli clients, Israeli sovereign bond issuances, or Israeli-linked correspondent banking transactions is aggregated within HSBC’s Europe or MENA regional reporting buckets and is not separately identifiable in public filings. ¹

Profit Flows

Given the absence of a licensed Israeli subsidiary and the closure of the Tel Aviv representative office circa 2015, there is no documented profit repatriation flow between HSBC and Israel at the operational entity level in either direction. ¹ HSBC’s global profits consolidate into HSBC Holdings plc in London and are distributed as dividends to shareholders globally. No Israeli state entity, Israeli government institution, or Israeli-domiciled entity is a material shareholder in HSBC Holdings plc or receives a direct profit stream from HSBC group operations. ¹¹⁴

To the extent that HSBC AM’s funds hold Israeli-domiciled equities, dividends paid by those Israeli companies flow into the relevant HSBC AM fund vehicles and are distributed onwards to fund investors globally. This represents standard fund mechanics and constitutes neither a corporate-level profit repatriation to Israel nor a direct economic contribution to the Israeli state. ¹⁰

Capital markets intermediation fees earned by HSBC Global Banking & Markets from acting as bookrunner on Israeli sovereign or corporate bond issuances represent revenue to HSBC, not a transfer of value to Israel. The corresponding economic benefit to the Israeli issuer is access to international capital at the sovereign or corporate level — a standard capital markets function. The ongoing status of this capital markets relationship post-October 2023, and specifically post-19 July 2024 (ICJ Advisory Opinion), is unconfirmed and constitutes a priority evidence gap. ¹

Economic Ecosystem Role

No public evidence identified of any Israeli government report, Israeli industry body, central bank publication, or regulatory designation characterising HSBC as a significant employer, anchor institution, systemic liquidity provider, or critical infrastructure participant within the Israeli domestic economy. ¹⁹¹⁵ HSBC’s most substantive economic relationship with Israel at the institutional level is as an international capital markets intermediary — specifically through its historical role as a bookrunner for sovereign and corporate Eurobond issuances in London and international capital markets — rather than as a domestic bank, employer, or operational investor. The indirect financial nexus via correspondent banking relationships with Israeli domestic banks (Bank Hapoalim, Bank Leumi) that themselves operate within the settlement economy represents a secondary and indirect channel of economic relationship. ⁴²⁰²⁹

End Notes