AFRY POLITICAL

Target: AFRY AB (publ) Research date: 26 October 2026 Evidence period: 2019–2026, including examination of public communications from 7 October 2023 through 26 October 2026 Scope: Corporate communications, territorial operations, internal governance, institutional partnerships, political financing, ownership, and executive conduct.

Corporate Communications & Public Stance

Statements concerning Israel and Palestine

No public evidence identified of an AFRY corporate statement expressly endorsing Israeli military operations, condemning Israeli military operations in Gaza, supporting Palestinian statehood, or addressing Palestinian civilian casualties.

A targeted public-record search covering 7 October 2023 through 26 October 2026 examined indexed AFRY-controlled English- and Swedish-language communications, newsroom material, project descriptions, governance information, and searches for attributable statements by current and former leadership; no corporate statement specifically addressing Palestinian civilian harm was identified within that search scope.^{1, 2, 3, 4}

The search included English terms such as “Palestine,” “Palestinian,” “Gaza,” “Israel,” “civilians,” and “humanitarian,” together with Swedish-language variants including “Palestina,” “Palestinier,” “Gaza,” and “civila”; the retrieved AFRY material did not establish a publicly declared position concerning Palestinian civilian casualties.^{1, 2, 3, 4}

No public evidence identified of an official AFRY declaration adopting political neutrality concerning the Israel-Palestine conflict.

The documented search did not comprehensively examine deleted social-media posts, non-indexed employee communications, private correspondence, or historical versions of every corporate webpage; its negative result is therefore limited to the publicly discoverable records examined.^{2, 3, 4}

AFRY’s published description of the Manara pumped-storage project presents its Israeli engagement as an energy-infrastructure assignment supporting electricity-grid flexibility and renewable-energy integration. The project is described as providing reserve electricity capacity for Israel Electric Corporation, with AFRY serving as owner’s engineer for Ellomay Pumped Storage. The published project duration is 2021–2026.¹

In its announcement of 6 July 2021, AFRY characterised the Manara assignment as part of its international expertise in pumped-storage hydropower engineering. The announcement identified Israeli governmental electricity policy, the project’s state licensing arrangements, and its electricity-purchase relationship with Israel Electric Corporation.⁵

Comparative public posture - Russia and Ukraine

On 8 March 2022, AFRY publicly condemned Russia’s invasion of Ukraine and announced that it would stop accepting new Russian projects and initiate withdrawal from Russia. Then-CEO Jonas Gustavsson stated: “We condemn Russia’s aggression against Ukraine.” AFRY also disclosed a SEK 500,000 contribution to UNICEF and support measures for employees affected by the conflict.⁶

On 13 April 2022, AFRY again publicly discussed the invasion of Ukraine in its AFRY Insights announcement. The company described the destruction of families and homes, repeated Gustavsson’s condemnation of Russian aggression, and reiterated its decision to stop accepting new Russian projects and initiate its Russian-market exit.⁷

On 11 April 2023, AFRY announced that it had completed the divestment of its Russian subsidiary to local management. The company stated that the transaction had been registered with Russian authorities and that the divested business would operate under another brand. The divestment is confirmed as completed.⁸

AFRY also promoted its engineering and infrastructure services at ReBuild Ukraine 2024, describing its Ukrainian market experience and local presence. This provides a further documented example of public corporate engagement with reconstruction following the Russian invasion.⁹

The company’s current Ukraine office information identifies AFRY Ukraine LLC in Kyiv and describes consulting services relating to energy infrastructure, nuclear safety, transmission systems, renewables, and environmental engineering. The office listing indicates an ongoing Ukrainian business presence as of the October 2026 review.¹⁰

Defined comparison window and limitations

AFRY’s publicly documented condemnation of Russian aggression and humanitarian contribution occurred in March 2022, with a further corporate statement in April 2022 and confirmed Russian divestment in April 2023.^{6, 8, 7}

The Palestine-focused search examined publicly discoverable communications concerning Palestinian civilian harm between 7 October 2023 and 26 October 2026 and identified no corresponding AFRY corporate or attributable leadership statement specifically addressing that subject within the examined records.^{1, 2, 3, 4}

The principal Russia-related statements preceded 7 October 2023, while AFRY’s Ukraine reconstruction communications extended into 2024; the compared events therefore belong to different reporting periods and involved different corporate and operational circumstances.^{6, 8, 9, 7}

No public evidence identified establishing that AFRY formally adopted neutrality concerning Palestinian civilian harm, deliberately suppressed a statement, or publicly explained why it had not issued a comparable statement.

No public evidence identified of a specific AFRY corporate decision directing employees or executives to avoid commenting on Palestinian civilian harm.

Market framing

AFRY’s 2021 Manara announcement identifies the project as an Israeli electricity infrastructure development involving Ellomay Pumped Storage, the Israeli Electricity Authority, and Israel Electric Corporation. The company presents the assignment through engineering, energy storage, and electricity-generation terminology.⁵

AFRY’s project description states that Israel Electric Corporation determines the plant’s daily generation schedule and dispatches electricity according to grid requirements. The description identifies a 156 MW pumped-storage facility and AFRY’s work reviewing designs, monitoring implementation, and supporting commissioning.¹

AFRY’s April 2025 corporate reorganisation announcement describes its operating model through three divisions: Energy, Industry, and Transportation & Places. The stated strategic focus is energy transition, industrial transformation, and infrastructure consulting.¹¹

Operations in Occupied or Contested Territories

Documented Israeli infrastructure engagement

On 6 July 2021, AFRY announced that Ellomay Pumped Storage had awarded it owner’s engineering services for the Manara pumped-storage power station in northern Israel. The project was intended to provide electricity-storage and reserve-generation capacity for Israel Electric Corporation.⁵

AFRY’s project description places the facility in the Upper Galilee, adjacent to the Lebanese border and overlooking the Hula Valley. The project is associated with Kibbutz Manara and the Upper Galilee Regional Council.¹

The published installation comprises one 156 MW pump-turbine unit, an upper reservoir, a lower reservoir, an approximately 1,100-metre waterway, and an underground powerhouse. AFRY’s specified responsibilities include engineering design review, cooperation with the EPC contractor, and commissioning support.¹

The project description names Ellomay Pumped Storage as AFRY’s client and Electra Infrastructure as the engineering, procurement, and construction contractor. AFRY lists the engagement duration as 2021–2026.¹

Governmental licensing and electricity-market integration

AFRY states that the project company received a provisional licence from the State of Israel and entered into a power-purchase agreement with Israel Electric Corporation. The project is consequently linked to Israel’s regulated civilian electricity-generation market.⁵

Ellomay Capital’s financial-statement disclosure for 2025 identifies Ellomay Pumped Storage (2014) Ltd. as the project company, with Ellomay holding 83.333% and Ampa Ltd. holding 16.667%. The disclosure also identifies a conditional licence issued by the Israeli Minister of Energy and Infrastructures for construction of the 156 MW plant.¹²

AFRY’s published assignment is an engineering-services engagement. Its project description does not identify AFRY as the owner of the power station, the holder of its generation licence, or the purchaser of its electricity output.¹

2026 project-status update

On 18 August 2026, Ellomay Capital reported that construction activity at the Manara pumped-storage project was progressing across the project site. This establishes that the underlying Israeli electricity project remained active after the 19 July 2024 ICJ advisory opinion and the November 2024 ICC arrest warrants.¹³

Ellomay also reported negotiations with the Israeli Electricity Authority concerning compensation for construction delays and war-related damage, together with discussions concerning amendments to the project’s financing agreement.¹³

Ellomay’s August 2026 disclosure identifies the developer’s ongoing project activity but does not identify AFRY as the contractor performing those continuing works.¹³

AFRY’s own project description continues to identify an owner’s engineering assignment scheduled for 2021–2026, without providing independently dated evidence of individual engineering services performed during August 2026.¹

The available corporate disclosures consequently establish continuing activity at the project in August 2026 and a previously documented AFRY consultancy assignment, while leaving the precise dates of AFRY’s post-November 2024 service delivery unconfirmed.^{1, 13}

Occupied-territory location

The identified AFRY project is described by the company as located in the Upper Galilee of northern Israel. The reviewed project records do not establish that its physical site is situated in the occupied West Bank, occupied East Jerusalem, or occupied Syrian Golan.¹

No public evidence identified of a separately verified AFRY project situated inside an Israeli settlement in those territories.

No public evidence identified of AFRY’s Manara assignment involving construction of Israeli settlements or their dedicated transport, housing, or security infrastructure.

Legal and regulatory scrutiny

The Ellomay project disclosure identifies Israeli governmental licensing requirements and a conditional construction licence for the Manara facility. This establishes project-specific energy regulation.¹²

Ellomay’s August 2026 disclosure identifies continuing discussions with the Israeli Electricity Authority concerning war-related delays and financing arrangements.¹³

No public evidence identified of an AFRY-specific settlement-related court judgment, regulatory enforcement action, or OECD National Contact Point determination.

No confirmed AFRY-specific entry was established in the reviewed material from the UN OHCHR settlement-business database or UN Special Rapporteur documentation.

The absence of an established entry in the available research does not constitute independently verified exclusion from every version of those databases.

Civil-society and boycott campaigns

No public evidence identified of an organised AFRY-specific boycott, divestment, or sanctions campaign concerning Israel or Palestine.

No public evidence identified of an AFRY corporate response to an Israel-Palestine boycott campaign.

Post-July 2024 and post-November 2024 continuity

AFRY’s published Manara project schedule extends from 2021 through 2026 and therefore encompasses both the 19 July 2024 ICJ advisory opinion and the November 2024 ICC arrest warrants.¹

Ellomay’s August 2026 disclosure confirms that the underlying project remained active after those dates.¹³

No independently dated record identified in the reviewed AFRY and Ellomay disclosures establishes the precise engineering services AFRY itself performed following either international legal development.^{1, 13}

Internal Governance, Content & Retail Policies

Employee relations and political expression

AFRY publishes a Group-wide Code of Conduct and related policies covering human rights, non-discrimination, employment practices, business ethics, and employee conduct. The company states that the Code applies to employees and the Board of Directors.²

The company’s published inclusion and diversity materials describe its workplace initiatives, employee inclusion programmes, and diversity-related activities.¹⁴

No public evidence identified of AFRY disciplining, dismissing, or otherwise sanctioning employees for expressing support for Palestine.

No public evidence identified of AFRY litigation against unions concerning Palestine-related statements, demonstrations, or industrial action.

No public evidence identified of an AFRY-specific dispute concerning Palestinian flags, keffiyehs, workplace symbols, or political speech.

Platform and editorial policies

AFRY’s April 2025 operating model identifies Energy, Industry, and Transportation & Places as its core divisions, describing engineering, advisory, design, and project-management services.¹¹

No public evidence identified of AFRY operating a consumer social-media platform with relevant political-content moderation responsibilities.

No public evidence identified of AFRY suppressing Palestinian content, restricting Palestine-related terminology, or implementing asymmetric editorial policies concerning Israel and Palestine.

No public evidence identified of regulatory or academic findings concerning AFRY’s moderation of Israel-Palestine content.

Retail and supply-chain practices

No public evidence identified of AFRY mislabelling products originating in Israeli settlements.

No public evidence identified of AFRY facing enforcement action over the country-of-origin designation of Israeli or Palestinian goods.

No public evidence identified of Palestine-related retail merchandising, product-removal, or supply-chain labelling controversies.

Formal governance policies

AFRY’s public policies page identifies its Code of Conduct, Supplier Code of Conduct, Human Rights Statement, Compliance and Ethics Policy, and related governance documents. The company describes these as the basis for its relationships with employees, clients, suppliers, and other stakeholders.²

No public evidence identified of an Israel-Palestine-specific amendment to these policies.

No public evidence identified of a Palestine-specific shareholder-resolution suppression controversy involving AFRY.

Brand Heritage & State Partnerships

Corporate heritage and positioning

AFRY’s January 2025 CEO announcement describes the 2019 merger of ÅF and Pöyry as the foundation of the combined engineering group, with an emphasis on energy transition and infrastructure consulting. The merger is historical [pre-2020] and remains part of the company’s documented corporate heritage.¹⁵

AFRY’s April 2025 reorganisation describes its principal business activities as engineering and consulting across energy, industry, transportation, and the built environment.¹¹

Defence-sector commercial positioning

On 4 March 2025, AFRY announced a framework agreement with the Swedish Armed Forces and the Swedish Defence Materiel Administration for IT consultancy services. The agreement covers IT systems, systems testing, and information security, with a total potential framework value of approximately SEK 1.5 billion across four suppliers. AFRY’s individual contract allocation was not disclosed.¹⁶

AFRY stated that it had collaborated with the Swedish Armed Forces and Swedish Defence Materiel Administration on projects across multiple disciplines for more than 60 years. This historical relationship began [pre-2020] and was confirmed as continuing through the 2025 framework agreement.¹⁶

On 19 February 2025, AFRY announced that Advansia, part of the AFRY group, had been awarded a seven-year construction-management framework agreement for Norwegian military infrastructure. AFRY disclosed an estimated contract value of SEK 170 million and stated that the agreement was partly NATO-funded.¹⁷

AFRY’s project description identifies the Norwegian assignment as supporting the Norwegian Defence Estates Agency and the broader Mime programme, which concerns modernisation of military information and communications infrastructure. The listed project period is 2025–2032.¹⁸

AFRY also describes project and construction-management services for Norway’s Ørland Main Air Station, including infrastructure supporting F-35 operations and subsequent runway improvements. The published assignment spans 2015–2024; its initial years are [pre-2020], and the project is documented as completed in 2024.¹⁹

These published military-sector assignments identify Swedish and Norwegian defence customers. The cited records do not establish equivalent AFRY contracts with the Israel Defence Forces or Israeli Ministry of Defence.^{16, 17, 19}

Israeli state institutions

AFRY’s Manara project is connected to Israeli electricity-sector institutions through governmental licensing, electricity regulation, and the project’s power-purchase relationship with Israel Electric Corporation. AFRY’s contractual customer is identified as Ellomay Pumped Storage.^{1, 5}

The SEC financial-statement note independently records the Israeli governmental licence associated with the Manara facility.¹²

Ellomay’s August 2026 disclosure establishes that the project developer remained engaged with Israel’s electricity regulator concerning war-related project delays and financing.¹³

Institutional sponsorship and cultural diplomacy

No public evidence identified of AFRY sponsoring an Israeli government cultural-diplomacy or public-relations initiative.

No public evidence identified of AFRY sponsoring settlement-related conferences or state-advocacy events.

No public evidence identified of AFRY receiving an Israeli state honour specifically for political advocacy.

No public evidence identified of AFRY holding a non-commercial institutional partnership intended to promote Israeli geopolitical policy.

On 17 December 2025, AFRY formally announced a cooperation agreement with the Academic Officers’ Society in Stockholm (AOS), a non-profit network bringing together students and alumni with military backgrounds from Stockholm universities, including KTH, the Stockholm School of Economics, the Swedish Defence University, and Karolinska Institutet. AFRY stated that the partnership aimed to strengthen connections between academia and the defence industry, facilitate knowledge exchange, promote security-policy discussions, and encourage young people to pursue careers in the defence sector.²⁰

The announcement described AOS as working to increase young people’s engagement with Sweden’s total-defence system through lectures, company visits, networking, and other activities. Pär Lundberg, AFRY’s Vice President and Head of Defence Technology, publicly endorsed the collaboration as an opportunity to engage future talent and strengthen total defence.²⁰

AFRY characterised the agreement as supporting its strategic position in defence technology and security, identifying more than 300 defence-technology experts worldwide and projects in over 12 countries. The announcement establishes a formal institutional partnership supporting Swedish defence-sector engagement, education, networking, and recruitment; it does not identify an Israel-specific political objective or partnership with Israeli defence institutions.²⁰

Lobbying, Advocacy, Financing & Logistics

Political lobbying

No public evidence identified of AFRY undertaking lobbying specifically concerning Israeli settlement policy, Palestinian statehood, Israeli military assistance, or anti-BDS legislation.

No public evidence identified of AFRY leadership holding an official position in AIPAC, Conservative Friends of Israel, or an equivalent Israel-focused political lobbying organisation.

No verified AFRY-specific political action committee expenditure concerning Israel-Palestine policy was identified.

Corporate financial contributions

No public evidence identified of AFRY donating to the Israel Defence Forces, Friends of the IDF, or an Israeli military-welfare organisation.

No public evidence identified of AFRY donating to JNF/KKL, Regavim, Im Tirtzu, or another identified settlement-support organisation.

No public evidence identified of AFRY directly financing Israeli reservist-support organisations.

No public evidence identified of AFRY funding Israeli settlement organisations through an identified corporate-controlled charitable foundation.

Documented humanitarian contribution in another conflict

On 8 March 2022, AFRY announced a SEK 500,000 contribution to UNICEF in connection with the humanitarian consequences of the war in Ukraine. The company also described efforts to support affected employees.⁶

AFRY’s April 2022 Insights announcement repeated its condemnation of Russian aggression and described the humanitarian suffering resulting from the invasion.⁷

No public evidence identified of an equivalent AFRY corporate humanitarian contribution expressly designated for Palestinian civilians during the October 2023–October 2026 period examined.

Energy-project financing and commercial relationships

The Manara project is a commercial electricity-infrastructure development for Ellomay Pumped Storage. AFRY’s stated role consists of engineering services, including design review, coordination with the construction contractor, and commissioning support.¹

Ellomay’s financial-statement disclosure identifies the ownership of the project company and its relationship with Israeli energy-licensing authorities. These records establish the project’s corporate and regulatory structure without identifying AFRY as a project equity investor.¹²

Ellomay’s August 2026 results confirm continuing construction activity and negotiations with the Israeli Electricity Authority concerning compensation for war-related project delays and changes to financing arrangements.¹³

No public evidence identified of AFRY providing a political donation, charitable grant, or military-welfare contribution through the Manara project.

Crisis asset mobilisation

No public evidence identified of AFRY donating engineering resources, vehicles, equipment, logistics, or free professional services to the Israel Defence Forces during the Gaza conflict.

No public evidence identified of AFRY providing crisis-related free infrastructure or digital services to Israeli military operations.

No public evidence identified of AFRY undertaking crisis-related engineering work for Israeli military installations connected to the Gaza conflict.

Charitable matching and reservist policies

No public evidence identified of an AFRY charitable-matching programme specifically supporting FIDF, Israeli military charities, or settlement organisations.

No public evidence identified of an AFRY policy providing Israeli reservists with military-service salary supplements.

Settlement sponsorship

No public evidence identified of AFRY financing, sponsoring, or publicly endorsing settlement-expansion activities.

Corporate Structure & Primary Mission

Legal structure

AFRY AB is a Swedish public limited liability company with its registered office in Stockholm. Its class B shares are listed on Nasdaq Stockholm, and its corporate governance follows Swedish company law and the Swedish Corporate Governance Code.²¹

AFRY has two share classes. Class A shares carry ten votes per share, while class B shares carry one vote. AFRY identifies the ÅForsk Foundation as the principal holder of unlisted class A shares.²²

The disclosed share structure comprises 113,251,741 shares, including 4,290,336 class A shares and 108,961,405 class B shares.²²

Shareholder and governance control

AFRY’s published corporate-governance framework allocates responsibilities among shareholders, the Board of Directors, the CEO, and the executive management structure.²¹

At the Annual General Meeting on 28 April 2026, shareholders re-elected Tom Erixon as Board Chair and re-elected the nominated directors. The AGM also approved the financial statements and other governance proposals.²³

The ÅForsk Foundation’s class A shareholding provides enhanced voting influence under the company’s dual-class share structure.²²

No public evidence identified of a controlling shareholder formally directing AFRY to undertake Israel-Palestine political advocacy.

Foundational mission

AFRY’s 2025 reorganisation announcement identifies commercial engineering, industrial transformation, energy transition, and infrastructure services as its principal operating activities.¹¹

No public evidence identified in the reviewed governance disclosures of a formal corporate mandate to advance Israeli state geopolitical objectives.

No public evidence identified of an Israeli government golden share or an Israeli governmental controlling shareholding in AFRY.

Group attribution

AFRY’s published corporate structure includes the historical ÅF/Pöyry combination and its continuing Energy, Industry, and Transportation & Places divisions.^{11, 15}

Advansia is identified by AFRY as part of its group and is named in the 2025 Norwegian military-infrastructure agreement.¹⁷

AFRY Ukraine LLC is identified as a local operating entity with an office in Kyiv.¹⁰

The reviewed official disclosures establish Advansia’s Norwegian military-infrastructure activity and AFRY Ukraine’s Ukrainian operations without identifying an Israel-Palestine-specific political relationship through those entities.^{10, 17}

No public evidence identified linking these named group entities to Israeli political donations, settlement sponsorships, or anti-Palestinian advocacy.

No public evidence identified of an Israel-specific political financing vehicle controlled by the ÅForsk Foundation.

Executive & Leadership Footprint

Current leadership

AFRY identifies Linda Pålsson as President and CEO. Its executive leadership includes Bo Sandström, Susan Gustafsson, Sara Klingenborg, Daniela Spetz, Henrik Tegnér, Elon Hägg, Nicholas Oksanen, and Richard Beard.³

Linda Pålsson was appointed President and CEO on 12 January 2025, succeeding Jonas Gustavsson. AFRY described her prior experience within its Energy Division and the wider energy sector.¹⁵

Board of Directors

AFRY’s current published Board includes Chair Tom Erixon and directors Viveka Beckeman, Jan Berntsson, Magnus Heimburg, Jenny Larsson, Neil McArthur, Åsa Pettersson, and Kristina Schauman.⁴

The 2026 AGM confirmed Tom Erixon’s re-election as Chair and the re-election of the other nominated Board members.²³

AFRY’s director biographies identify Tom Erixon’s leadership roles at Alfa Laval and Swedish industry organisations, as well as board members’ professional affiliations across engineering, energy, manufacturing, consulting, and corporate governance.⁴

Public advocacy and statements

Former CEO Jonas Gustavsson publicly condemned Russia’s invasion of Ukraine in March 2022 and explained AFRY’s decision to initiate withdrawal from Russia.⁶

AFRY’s April 2022 Insights publication repeated Gustavsson’s condemnation and referred to suffering caused by the invasion.⁷

For the period 7 October 2023 through 26 October 2026, searches for statements attributable to Linda Pålsson, Tom Erixon, and Jonas Gustavsson did not identify a verified public statement specifically addressing Palestinian civilian harm.^{15, 3, 4}

No public evidence identified of Linda Pålsson publicly endorsing Israeli military operations, settlement expansion, or anti-BDS legislation.

No public evidence identified of Tom Erixon publicly endorsing Israeli military operations or settlement expansion.

No public evidence identified of the other named AFRY executive officers or directors making corporate-branded statements advocating Israeli military or settlement policies.

No public evidence identified of a formal leadership decision prohibiting public discussion of Palestinian civilian casualties.

Personal philanthropy and financing

No public evidence identified of AFRY’s named executives or directors personally donating to Friends of the IDF, JNF/KKL, Israeli reservist funds, or settlement organisations.

No public evidence identified of an executive-controlled foundation making grants to those organisations.

No public evidence identified of an AFRY controlling principal holding a documented personal equity investment in an Israeli military or surveillance company specifically connected to the Israel-Palestine conflict.

Board memberships and advocacy affiliations

AFRY’s current Board biographies disclose professional directorships and institutional positions, including Tom Erixon’s Alfa Laval role and other directors’ positions in Swedish and international industry organisations.⁴

No public evidence identified of an AFRY founder, CEO, Chair, or listed director serving on the governing board of AIPAC, FIDF, JNF/KKL, Regavim, or Im Tirtzu.

No public evidence identified of a named AFRY controlling principal organising or sponsoring a political fundraising event for the Israeli military.

Conduct following the July and November 2024 international legal developments

The company’s Manara project description continues to list a 2021–2026 project period, while its January and April 2025 leadership announcements document the subsequent corporate leadership and organisational structure.^{1, 11, 15}

The August 2026 Ellomay disclosure independently confirms that the underlying Manara construction project continued after the July and November 2024 international legal developments, without establishing that AFRY itself carried out identifiable engineering work on the dates covered by that disclosure.¹³

No public evidence identified of a dated post-November 2024 political donation, settlement sponsorship, or Israel-Palestine advocacy statement attributable to the named AFRY executives.