Caterpillar ECONOMIC

Audit Phase: Economic Audit
Subject Entity: Caterpillar Inc. (NYSE: CAT)
Jurisdiction Focus: Israel and Occupied Palestinian Territory Operations
Audit Date: 2026
Classification: Updated

Supply Chain & Sourcing Relationships

Direct Supplier Relationships

• No public evidence identified linking Caterpillar to Israeli agricultural exporters, including Mehadrin, Hadiklaim, Galilee Export, Agrexco successors, settlement-origin produce, or seasonal agricultural procurement; Caterpillar’s documented business concerns industrial equipment rather than agricultural commodity sourcing. ^{1, 2}
• No public evidence identified of Israeli-origin Caterpillar goods reaching non-Israeli markets through white-label arrangements or third-party onward distribution. ^{1, 3}

Importer and Dealer Structure

• Zoko states that Tractors and Equipment (I.T.E.) Ltd., a Zoko-group company, holds an exclusive Caterpillar franchise to import, market, and sell Caterpillar engineering equipment in Israel; Zoko lists its own address as 8 HaManor Street, Holon. ³
• I.T.E. states that it imports and exclusively markets Caterpillar equipment, engines, generators, parts, attachments, equipment-management technology, hydraulic services, and related equipment in Israel. ⁴
• I.T.E.’s predecessor received the Caterpillar distribution franchise in 1948, and the operating activity moved to Tractors and Equipment (I.T.E.) Ltd. in 2001. ⁵
• A 5 July 2012 Zoko Enterprises issuer disclosure identified Tractors & Equipment (I.T.E.) Ltd., Israeli company number 512994054, as a wholly owned Zoko subsidiary; this historical disclosure does not establish the current ownership percentage. ⁶
• Current I.T.E. and Zoko materials represent I.T.E. as part of the Zoko group, but no current Israeli Companies Registrar extract or current Zoko ownership filing was retrieved; current legal ownership remains unverified. ^{3, 4}
• Israeli Ministry of Economy notices from 2015 identify I.T.E., company number 512994054, for machinery-maintenance training procurement; they establish historical government contracting under that corporate identity, not current ownership or a settlement location. ^{7, 8}
• The reviewed corporate disclosures do not identify I.T.E. or Zoko as a Caterpillar subsidiary, majority-owned entity, or listed affiliate. ^{9, 3}
• The available first-party dealer material does not establish that I.T.E. is the customs importer of record for every Caterpillar shipment, and no underlying franchise agreement or shipment-specific customs record was identified. ^{3, 4}
• No dealer agreement was retrieved establishing Caterpillar’s authority to approve, restrict, audit, or terminate I.T.E./Zoko activity by territory, end customer, or military use. ^{3, 4}

Military-Related Dealer Activity

• Who Profits describes Zoko Enterprises and I.T.E. as supplying Caterpillar heavy machinery to the Israeli military and performing equipment retrofits including armour plating, gunner positions, bulletproof cabins, and autonomous-systems integration; this NGO-sourced assertion was not independently resolved through procurement, contract, or military records in the updated research. ¹⁰
• I.T.E.’s training centre states that it uses Caterpillar-certified instructors and provides training and certification to IDF bodies and commercial customers, including named Air Force, Engineering Corps, Technology and Maintenance Corps, and Navy customers; this evidences I.T.E. training relationships rather than disclosed direct Caterpillar contracts with each body. ¹¹

Product Origin, Labeling & Regulatory Compliance

• Caterpillar’s documented Israeli offering concerns industrial machinery, parts, generators, and services rather than food or ordinary consumer goods. ⁴
• No public evidence identified of settlement-origin consumer-product labeling disputes, country-of-origin enforcement actions, customs enforcement, or product-labeling regulatory actions involving Caterpillar equipment. ^{1, 4}
• No public evidence identified of a Caterpillar policy specifically addressing sourcing or labeling of goods from occupied or contested territories. ^{1, 12}
• The absence of identified enforcement or policy evidence does not establish that product-origin requirements can never apply to machinery. ⁴

Investment, Capital & Financial Exposure

Israeli Corporate Investment

• Caterpillar Inc. is a Delaware corporation with its principal executive office in Irving, Texas, and reported global 2025 sales and revenues of $67.589 billion. ²
• Caterpillar’s Exhibit 21, covering reported subsidiaries and affiliated companies as of 31 December 2025, contains no Israel-organized entity; this is limited to entities reportable in that SEC exhibit and does not establish the absence of unaffiliated dealers, customers, registrations, or investments. ⁹
• No public evidence identified in the reviewed SEC materials of a Caterpillar-owned Israeli factory, R&D centre, data centre, logistics hub, real-estate holding, acquisition, or Preferred Technology Enterprise status. ^{2, 9}
• The I.T.E./Zoko relationship is documented as an exclusive distribution franchise, not as a Caterpillar-controlled subsidiary. ^{9, 3, 4}
• Caterpillar’s FY2024 and FY2025 SEC filings do not disclose Israeli-specific foreign direct investment. ^{12, 2}

Caterpillar Ventures and Magnus Metal

• Caterpillar Venture Capital Inc. is a wholly owned Caterpillar Inc. subsidiary; Caterpillar describes the unit as making strategic startup investments and states that it had invested in more than 40 companies since 2015. ¹³
• Magnus Metal announced on 18 April 2024 that it raised $74 million in a Series B round co-led by Entrée Capital and Target Global, with Caterpillar Ventures listed as an additional participant; Magnus Metal described itself as operating from Tel Aviv, Israel. ¹⁴
• The disclosed $74 million is the total Series B amount, not Caterpillar Ventures’ individual investment amount. ¹⁴
• No public evidence identified of Caterpillar Ventures’ cheque size, ownership percentage, voting rights, board seat, observer rights, valuation, investment instrument, liquidation preferences, or other governance rights in Magnus Metal. ^{13, 14}
• Caterpillar’s reviewed May 2026 Ventures material does not list Magnus Metal or disclose a disposal; Caterpillar Ventures’ current holding status is therefore unknown. ^{13, 15}
• The disclosed participation is a minority venture investment, not evidence that Caterpillar acquired or controls Magnus Metal or operates an Israeli manufacturing subsidiary. ^{9, 13, 14}

Financial and Investor Exposure

• Caterpillar is held by major European financial institutions as equity and debt; the 2024 Don’t Buy Into Occupation report describes financing and investment exposure to settlement-linked companies, including Caterpillar. ¹⁶
• The inherited record reports that ABP and PFZW sold Caterpillar shares in 2024, ING maintained loans, and Achmea and ASR held Caterpillar shares. ¹⁷
• KLP excluded Caterpillar from its portfolios in June 2024, citing what it characterized as an unacceptable risk of contributing to human-rights violations; KLP stated it had held shares and bonds valued at NOK 728 million until 17 June 2024. ^{18, 19}
• Norway’s Government Pension Fund Global excluded Caterpillar in August 2025; the reported holding was 1.2% and valued at approximately $2.1 billion at the time of exclusion. ^{20, 21}
• Alameda County sold $32 million in Caterpillar bonds in December 2024. ²²
• No public evidence identified that Caterpillar underwrote Israeli sovereign debt, Israel Bonds, settlement activity, or Israeli military operations. ²

Operational Presence & Market Activity

Israeli Dealer Footprint

• Caterpillar’s Israeli commercial presence is documented through I.T.E./Zoko’s independent dealer operation rather than a Caterpillar-controlled Israeli entity. ^{9, 3}
• I.T.E. reports more than 300 employees, seven Israeli branches, service centres, a logistics centre, garages, 24/7 service, approximately 20 delivery trucks, two nationwide daily distribution rounds, and 120 mobile service units; these figures concern I.T.E., not Caterpillar Inc.’s direct workforce. ⁴
• I.T.E. lists facilities in Holon, Kiryat Bialik, Be’er Sheva, Eilat, Ramla, Lod, and Kannot; its published directory does not list Mishor Adumim, Ma’ale Adumim, East Jerusalem, the West Bank, the Golan Heights, or another settlement location. ²³
• I.T.E. identifies Holon, Kiryat Bialik, and Be’er Sheva as training-centre locations, and no settlement-area training site is identified in its reviewed public material. ^{11, 23}
• No public evidence identified that Zoko Enterprises or I.T.E. currently operates, leases, staffs, or provides services from a Mishor Adumim facility. ^{4, 23, 24}
• I.T.E.’s current directory contains no “Mishor” match and identifies its contact address as 8 HaManor Street, Holon. ^{4, 23}
• The Israel Garage Association directory lists I.T.E. locations in Be’er Sheva, Kiryat Bialik, Holon, and Eilat, not Mishor Adumim; this directory is corroborative rather than a complete corporate-location registry. ²⁴
• A 2012 customer-list PDF places I.T.E. at 9 HaManor Street, Holon, while its separate Mishor Adumim entry at Ofira Street 5 identifies another entity; this dated commercial list is not a land record, registry extract, or conclusive evidence that I.T.E. had no other facility. ²⁵
• No public evidence identified of an I.T.E. or Zoko Mishor Adumim facility importing, selling, maintaining, training on, or providing parts or logistics for Caterpillar equipment during any identified period. ^{4, 23, 24, 25}
• The current first-party directory, industry directory, and dated 2012 commercial list do not independently verify a Mishor Adumim I.T.E./Zoko service or logistics hub asserted in specialist-source material; the status is not confirmed. ^{1, 10, 4, 23, 24, 25}
• These listings do not conclusively disprove an unlisted, historic, mobile, leased, or customer-site operation. ^{4, 23, 24, 25}
• No public evidence identified in targeted searches or reviewed first-party facility material that Zoko or I.T.E. operated during 2024–2026 a Caterpillar-authorized or Caterpillar-branded sales, service, logistics, parts, or training facility in Mishor Adumim or another Israeli settlement. ^{3, 11, 23}
• This facility finding is limited to reviewed public listings and does not establish that I.T.E. never serviced a customer or equipment at an unlisted location. ²³
• The Israel Airports Authority published a 10 June 2026 single-supplier notice identifying I.T.E. for Caterpillar diesel-generator repairs and spare parts over a stated 36-month engagement; the notice identifies no settlement location, Wall, checkpoint, settlement-security end use, or settlement-related project. ²⁶
• Because no current I.T.E./Zoko Mishor Adumim facility was independently confirmed, no public evidence identified that such a confirmed facility serves settlement construction, settlement infrastructure, the Wall, or settlement-security customers. ^{4, 11, 23, 24}
• I.T.E.’s IDF training representation does not identify Mishor Adumim, a settlement project, or an end-user location. ¹¹

Market and Employment

• No public evidence identified of Caterpillar Inc.’s direct Israeli workforce, Israeli tax registration, or Israel-specific revenue reporting. ^{1, 2}
• Caterpillar’s public geographic reporting does not separately characterize Israel as a strategic growth market or disclose Israel-specific sales. ^{12, 2}
• No public evidence identified that Caterpillar itself is designated as Israeli critical national infrastructure. ²⁶

Post-July-2024 Equipment, Services, and Defence Activity

• The Norwegian Council on Ethics records that, in a 19 November 2024 meeting, Caterpillar said D9 machinery was sold to U.S. authorities through the Foreign Military Sales programme rather than directly to the IDF, while knowing Israel was the recipient. ²⁷
• The Council records that, at a 28 May 2025 meeting, Caterpillar confirmed a new FMS D9 order, with deliveries anticipated in coming months; this account does not identify a settlement project, end-user unit, delivery quantity, or I.T.E./Zoko role. ²⁷
• The U.S. Defense Security Cooperation Agency notified Congress in February 2025 of a possible emergency Foreign Military Sale to Israel, estimated at $295 million, for Caterpillar D9R and D9T bulldozers and associated parts, documentation, inspections, technical and logistics support, and storage; estimated delivery was stated to begin in 2027. ²⁸
• The DSCA notification is an approval and proposed-sale record, not evidence that all notified equipment was delivered or that Caterpillar entered a completed direct contract. ²⁸
• Times of Israel reported on 9 July 2025, citing the Israeli Defence Ministry, that dozens of Caterpillar D9 bulldozers arrived at Haifa for IDF Ground Forces and were transferred to an IDF logistics centre for armour installation. ²⁹
• Reuters photograph metadata dated 30 July 2025 identifies a D9 bulldozer leaving Gaza at the Israel–Gaza border. ³⁰
• These July 2025 reports and the February 2025 DSCA notification post-date the July 2024 ICJ Advisory Opinion and the November 2024 ICC arrest warrants. ^{28, 29, 30}
• Who Profits reports post-2024 use of Caterpillar equipment in the occupied West Bank and describes equipment use in settlements, settlement infrastructure, and the Separation Wall; these are NGO assertions. ¹
• No public evidence identified of a post-19-July-2024 Caterpillar, I.T.E., or Zoko transaction, service order, delivery record, maintenance record, or contract specifically traceable to a named settlement, settlement road, Separation Wall project, checkpoint, or settlement police/security facility. ^{1, 26, 27}
• The identified 2025–2026 records therefore evidence potential or reported Israel-directed supply, defence-related deliveries, and non-settlement-specific generator servicing, rather than verified current supply or servicing for settlement construction, settlement roads, the Wall, or settlement security infrastructure. ^{28, 26, 29, 30, 27}

Cessation, Restrictions, and Residual Infrastructure

• No public evidence identified of a binding Caterpillar restriction specifically barring Israel sales, settlement sales, dealer servicing, or provision of parts or training to settlement-linked customers. ^{3, 4, 11, 27}
• The Council on Ethics records Caterpillar’s November 2024 statement that it was not aware of a D9-sale moratorium, its May 2025 account of a new FMS order, and its July 2025 assessment that relevant deliveries were set to resume. ²⁷
• No public evidence identified of verified withdrawal from settlement-related business, removal of equipment, divestment from the Israeli dealer relationship, removal of dealer authorization, or closure of Israel operations. ^{9, 3, 4, 27}
• Current residual commercial infrastructure is evidenced by I.T.E.’s branches, logistics and distribution network, product-support personnel, spare-parts services, mobile service units, and training centres; this public Israeli network does not establish servicing within settlements or prove the absence of such servicing. ^{4, 11, 23}

Corporate Structure & Foundational Ties

Foundation, Domicile, and Governance

• Caterpillar was founded in 1925 in California and is not Israeli-founded. ¹²
• Caterpillar Inc. is incorporated in Delaware and maintains its principal executive office at 5205 N. O’Connor Boulevard, Suite 100, Irving, Texas 75039. ²
• Joseph E. Creed became CEO and a Caterpillar director on 1 May 2025; he became Chairman upon D. James Umpleby III’s retirement on 1 April 2026, while Debra L. Reed-Klages remains Lead Independent Director. ^{31, 32}
• The proxy identifies The Vanguard Group as the only disclosed holder above 10% at 31 December 2025, at 10.06%; State Street Corporation and subsidiaries held 7.4%, and BlackRock, Inc. held 6.6%. ³¹
• The proxy reports that each director and executive officer individually held less than 1%. ³¹
• No public evidence identified in the reviewed filings of Israeli beneficial control, an Israeli shareholder holding at least 10%, Israeli tax residency, Israeli state ownership, governmental board appointments, golden shares, founder shares, or constitutional restrictions tying Caterpillar governance to Israeli state policy. ^{2, 9, 31}
• No person-by-person primary-record review of private or family-office investments by every director, executive, or institutional holder was completed; the reviewed disclosure record does not support a broad personal-investment absence conclusion. ³¹

Institutional and UN-Related Record

• Caterpillar equipment is described as modified by Israeli defence-industry entities, including Israel Aerospace Industries’ unmanned D9 variants; the underlying primary documentation for individual modification programmes remains an evidence gap. ^{1, 33}
• The retained record identifies Caterpillar Inc. in Annex I of the February 2020 UN Human Rights Council settlement-enterprise database, A/HRC/43/71, in connection with activity categories concerning: (a) supply of equipment or materials facilitating construction or expansion of settlements and the Wall or associated infrastructure; and (c) supply of demolition or bulldozing equipment used to destroy property and agricultural assets. ^{34, 35, 36, 37}
• The official 2020 annex could not be independently retrieved in the updated research to verify its exact entry ordering or wording; the retained 2020 record should therefore be consulted directly before quoting the Annex entry verbatim. ³⁷
• The official 30 June 2023 OHCHR update states that it reassessed the 112 entities in the 2020 report, removed 15, and retained 97; Caterpillar was not identified in the reviewed text of that update. ³⁸
• The 2023 document-scoped no-hit does not establish whether Caterpillar was retained, removed, renamed, or otherwise omitted, and no Caterpillar-specific activity status can be attributed from that document alone. ³⁸
• Caterpillar was likewise not named in the supplied full-text scan of the 2025 OHCHR update, A/HRC/60/19; no Caterpillar-specific official removal, retention, or addition notice was retrieved. ³⁹
• The document-scoped absences in the 2023 and 2025 update material do not establish database-wide absence, discontinuation of activity, cessation, or removal. ^{38, 39}
• UN Special Rapporteur report A/HRC/59/23, dated 2 July 2025, names Caterpillar in discussion of equipment used in demolitions, D9 bulldozers, and Israeli defence-industry adaptation; this is a UN Special Rapporteur report, not a judicial finding. ³³
• The report’s statement that Caterpillar secured a further multi-million-dollar Israeli contract in 2025 remains a report-based lead because its underlying procurement record was not independently retrieved. ³³

Profit Repatriation & Economic Contribution

Revenue and Profit Flows

• Caterpillar’s FY2024 and FY2025 SEC filings do not disclose Israel-specific revenue, dealer margin, tax payments, transfer-pricing arrangements, or profit repatriation. ^{12, 2}
• Caterpillar reported global 2025 sales and revenues of $67.589 billion. ²
• No public evidence identified of Caterpillar worldwide profits flowing to Israeli-domiciled owners. ^{2, 31}
• I.T.E. identifies itself as an Israeli importer, distributor, and service operator, but does not disclose Caterpillar’s Israel-derived revenue or the direction of Caterpillar-related profit flows. ⁴
• No public evidence identified of Caterpillar as a key direct employer, sector anchor, or infrastructure provider within the Israeli economy; I.T.E. is an independent dealer operation. ^{1, 9, 3}

Documented Use and Accountability

• Caterpillar D9 armored bulldozers have been documented in reports concerning home demolitions, settlement construction and expansion, Separation Wall construction, military operations in Gaza, crowd control during the Great March of Return, and the 2003 killing of Rachel Corrie. ^{1, 40}
• Corrie et al. v. Caterpillar was filed in U.S. federal court in 2005 under the Alien Tort Statute, and the Ninth Circuit dismissed the case in September 2007 on grounds relating to the court’s inability to question foreign-policy decisions. ⁴¹
• Jewish Voice for Peace and allied shareholders submitted Caterpillar resolutions between 2011 and 2016; the 2011 proposal received 21% support, and Caterpillar obtained SEC no-action relief in 2013 concerning a shareholder proposal. ⁴²
• The Norwegian Council on Ethics stated that it had “no doubt” Caterpillar products were being used for extensive and systematic violations of international humanitarian law and that Caterpillar had not implemented measures to prevent such use; this is the Council’s exclusion rationale rather than a court finding. ^{21, 27}
• Caterpillar states that it may make lawful U.S. corporate political contributions, publishes them twice yearly, does not make independent candidate expenditures, and does not contribute to presidential campaigns or Super PACs; the policy makes no Israel- or Palestine-specific statement. ⁴³
• Caterpillar’s published 2025 CATPAC schedule documents U.S. political contributions but does not identify Israeli entities, Israel-related political organizations, or stated Israel-related purposes. ⁴⁴
• Caterpillar’s Q2 2025 federal lobbying filing reported $1.237 million in expenses and marked foreign-entity-interest fields “None”; it did not identify lobbying on Israel, Palestine, Israeli military procurement, or settlement activity. ⁴⁵
• Caterpillar Foundation’s FY2025 filing record reports $56.92 million in charitable disbursements, compared with $44.86 million in FY2024; no itemized grant-recipient finding regarding Israel-, Palestine-, or advocacy-linked recipients was established in the reviewed record. ⁴⁶