Key Findings
- Economic: E.ON’s statutory disclosures document 100% group ownership of E.ON Israel Ltd., Herzliya, through the reviewed 2025 shareholding-list reproduction; available material characterises the affiliate’s nexus as innovation, technology scouting, and software-engineering support rather than utility operations.1, 2
- Economic: E.ON-linked Future Energy Ventures (FEV) participated in Buildots financing rounds, including the company’s 2025 Series D; the available record does not establish E.ON SE’s direct ownership, transaction approval, or control over individual fund investments.3, 4
- Political: E.ON has no identified corporate Israel-Palestine statement in reviewed press material; its minority shareholder RWE issued a 2023 solidarity statement, but the evidence does not establish E.ON adoption or attribution of that statement.5, 6
- Not found: No public evidence identified of E.ON military/security contracts, Israeli state-security technology deployment, settlement operations, or inclusion in the reviewed OHCHR settlement-business database.7, 8, 9
Target Profile
| Field | Detail |
|---|---|
| Company Name | E.ON SE |
| Jurisdiction | Germany; registered with Essen District Court under HRB 28196.10 |
| Headquarters | Brüsseler Platz 1, 45131 Essen, Germany.10 |
| Sector | Energy utility: Energy Networks, Energy Infrastructure Solutions, and Energy Retail.10 |
| Ownership | Listed in Frankfurt under ticker EOAN. RWE AG held disclosed voting rights of 15.00%; the reviewed record does not identify RWE as E.ON’s parent or controlling shareholder.10, 11 |
| Key Executives / Governance | Leonhard Birnbaum (CEO); Nadia Jakobi (CFO); Thomas König (COO Networks); Victoria Ossadnik (COO Digital); Marc Spieker (COO Commercial). Erich Clementi chaired the Supervisory Board at year-end 2025.10 |
| Israeli-Nexus Summary | Documented 100%-held E.ON Israel Ltd. affiliate in Herzliya and E.ON-linked venture/innovation activity in Israel; no verified Israeli utility-market, settlement, military, or state-security operation.1, 2, 7, 9 |
Key Facts:
- E.ON Israel Ltd. was listed as a 100%-held, non-consolidated affiliated company because of subordinate importance in E.ON’s reviewed statutory reporting.1
- The reviewed evidence does not establish E.ON Israel Ltd.’s current revenue, workforce, contracts, customer base, utility licence, tax payments, or day-to-day management by E.ON SE.2, 12
Executive Summary
E.ON SE is a German energy utility headquartered in Essen. Its disclosed core business is energy networks, infrastructure solutions, and retail energy. Israel is not identified as a stated E.ON energy-network or retail market in the reviewed group reporting. The material Israel nexus is instead a corporate-affiliate and innovation nexus: E.ON’s statutory schedules identify E.ON Israel Ltd., Herzliya, as a wholly group-owned, immaterial non-consolidated affiliate, while ecosystem material describes technology scouting, startup collaboration, potential strategic investment work, and software-engineering support.1, 2, 10
The strongest documented economic vector is the continuing ownership record for E.ON Israel Ltd. and E.ON’s relationship with Future Energy Ventures. E.ON’s 2024 reporting identifies FEV as an internationally active investment fund and E.ON as a strategic partner. A separately named Israeli vehicle, FEV Future Energy Ventures Israel Ltd., was listed as 100% group-owned in E.ON’s reviewed reporting. This establishes a documented E.ON-group ownership chain for that vehicle, but it does not establish that every FEV fund investment is a direct E.ON SE investment or that E.ON approved individual transactions.13, 14
FEV’s participation in Israeli-founded Buildots funding rounds is documented, including the company’s 2021 Series B, 2022 Series C, and 2025 Series D. The 2025 round occurred after the July 2024 ICJ advisory opinion and November 2024 ICC arrest warrants. However, the sources do not identify the particular FEV vehicle that made each investment, investment amounts, E.ON’s capital contribution, ownership interests, board rights, investment-committee authority, or E.ON control over Buildots. Buildots is documented as commercial construction-progress software; no public evidence identified of military, settlement, defence, or Israeli-security procurement of its product.3, 4, 15
The audits do not support a direct military or digital-security nexus. No public evidence identified of E.ON contracts or services for the Israeli Ministry of Defence, IDF, police, prison service, intelligence agencies, settlement authorities, or settler-security bodies. Nor was public evidence identified that E.ON deployed Israeli-origin surveillance, biometric, cloud, AI, cyber, or military technology for Israeli state-security functions. E.ON does not appear in the reviewed OHCHR settlement-business database, Who Profits database, AFSC Investigate database, or the specified civil-society reports; these are source-specific and document-scoped findings, not guarantees that no relationship exists.7, 8, 9
The political record is similarly limited. No E.ON corporate communication specifically addressing Israel-Palestine, 7 October 2023, or the Gaza war was identified in the reviewed press material. RWE, a documented material minority shareholder rather than E.ON’s parent or operating controller, issued an October 2023 statement expressing solidarity with Israel. The reviewed evidence does not establish that E.ON adopted, republished, directed, or was otherwise responsible for that RWE statement. On the fixed, human-vetted V6.5 assessment, E.ON receives BRS 409 and Tier C (Substantial Complicity), driven by the economic and political-domain scores while military and digital scores remain zero.5, 6, 11
Timeline of Relevant Events
| Date | Event |
|---|---|
| December 2018 | E.ON representatives reported plans to invest in Israeli startups through its Agile Accelerator, described an Israeli scouting representative and SOSA participation, and identified Indegy as winner of an E.ON startup competition and critical-infrastructure cyber-defence pilot partner.16 |
| 2019–2020 | The E.ON–RWE asset exchange was implemented: E.ON acquired innogy’s grid and retail business; RWE received a minority E.ON interest and E.ON transferred renewables activities to RWE.11 |
| August 2021 | Rekor’s SEC filing identified FEV Future Energy Ventures Israel Ltd. as a former Waycare equity holder receiving Rekor shares in connection with Rekor’s Waycare acquisition; the filing does not identify the original investment terms or a security, settlement, or state-contract nexus.17 |
| 4 August 2021 | FEV was identified as a participant in Buildots’ $30 million Series B.3 |
| 17 December 2021 | RWE Renewables announced the sale of Belectric’s European and Israeli businesses, including Belectric Israel, to Elevion Group; the divested activity was described as third-party solar EPC and operations-and-maintenance work.18 |
| 17 May 2022 | FEV reported participation in Buildots’ $60 million Series C.3 |
| 2022–2023 reporting dates | E.ON statutory schedules listed E.ON Israel Ltd., Herzliya, at 100% group ownership and as non-consolidated due to subordinate importance.1 |
| January 2024 | FEV stated that E.ON and the European Investment Fund had anchored a new Article 9 fund, then targeted at €250 million.14 |
| 29 May 2025 | Buildots announced a $45 million Series D with FEV participation; the record identifies this as a fund-level investment rather than a confirmed direct E.ON acquisition.4 |
| 16 December 2025 | FEV announced Fund II’s €205 million close and named E.ON SE and EIF as initial anchor investors.19 |
| 31 December 2025 | A commercial reproduction of E.ON’s statutory shareholding disclosure continued to list E.ON Israel Ltd., Herzliya, with a 100% interest; this corroborates ownership but does not independently establish active operations.2 |
Corporate Overview
E.ON SE is the audited parent company of an energy group operating through Energy Networks, Energy Infrastructure Solutions, and Energy Retail. Its reported network markets are European and Turkish markets; Israel is not identified as a stated E.ON energy-network, retail, or energy-infrastructure operating market. The absence of an “Israel” text match in the 2024 report is document-scoped and does not itself establish the absence of an affiliate, vendor, investment, or activity.10, 20
The documented Israel-facing entity is E.ON Israel Ltd., located in Herzliya in E.ON’s 2022 and 2023 statutory schedules. It was listed at 100% group ownership and non-consolidated because of subordinate importance. A 2025-labelled commercial reproduction of the statutory list supports continued 100% ownership, but no issuer-hosted complete 2025 statutory filing or official dated Israeli Registrar extract was retrieved. The audits therefore support a legal-ownership finding, not a conclusion about active operational scale, local revenue, staffing, or current legal status on the audit date.1, 2, 12
The available ecosystem material describes E.ON Israel as conducting technology scouting, pursuing startup collaborations and possible strategic investments, exploring academic research, and providing software-engineering services. That material is self-described directory information, not an audited E.ON disclosure or contract record. It names Doron Ariel Shpasser as managing director and estimates one to ten employees, but neither the described functions nor the personnel estimate establish contracts, funding, E.ON SE approval, state partnerships, or defence relationships.2
E.ON’s relation to FEV requires attribution discipline. E.ON identifies FEV as a strategic partner and innovation-access route. FEV was reportedly spun out in 2022 and has raised external capital; its individual acts therefore cannot automatically be treated as direct E.ON SE acts. The audits separately document full E.ON-group ownership of FEV Future Energy Ventures Israel Ltd., while leaving unresolved the ownership and authority applicable to every FEV fund investment.13, 14
RWE’s 15% E.ON voting-rights position is a material minority holding, not evidence that RWE owns or controls E.ON. Regulatory material recorded the parties’ position that the stake was financial, though the UK CMA considered that it might confer shareholder-level material influence. The evidence does not establish group consolidation, operational control, procurement authority, direction over E.ON investments, or attribution of RWE’s historical Israeli operations to E.ON.11, 21
Domain Summaries
Military: Military
Mechanism of Involvement
No public evidence identified of E.ON, its named subsidiaries, RWE, or RWE-controlled entities holding Israeli military, prison, police, border-police, or other state-security contracts. No public evidence identified of E.ON supplying weapons, munitions, military logistics, military-base services, security infrastructure, or defence-prime components to Israel.7
FEV investments create defence-adjacent ecosystem exposure but do not establish direct E.ON military supply. FEV participated in Prisma Photonics funding rounds. Prisma markets fibre-optic sensing with documented civilian critical-infrastructure uses and military-perimeter and installation-security uses. The audits found no public evidence that E.ON’s own networks use Prisma technology, or that Prisma supplied an Israeli military recipient through E.ON.22
FEV also invested in Buildots, whose co-founders are reported IDF Talpiot programme graduates. Buildots is described as commercial construction-progress software. No public evidence identified of military, settlement, defence, or Israeli-security procurement of Buildots’ product.15
Counter-Arguments and Evidence Limits
The strongest counter-argument is that E.ON is an energy-network and retail-energy company, not a hardware or weapons manufacturer. The documented FEV stakes are venture investments, not verified direct E.ON product sales, military contracts, or service provision. A dual-use capability of a portfolio company does not establish a military customer, use, or attributable E.ON involvement.7, 22
RWE’s former Belectric Israel business is not a basis for attributing military or settlement activity to E.ON. It was divested in December 2021, and the available record identifies neither projects nor Israeli military, settlement, or security end-users. The audits found no public evidence supporting attribution of this historical RWE activity to E.ON beyond shareholder proximity.18, 21
Named Entities and Evidence Map
- E.ON SE: No identified Israeli military or security contract, product supply, or logistics relationship.7
- Future Energy Ventures: E.ON strategic partner; documented investor in Prisma and Buildots, without verified E.ON-directed military use.13, 22
- Prisma Photonics: Fibre-optic sensing platform with civilian and military-security use cases; no verified E.ON network deployment or Israeli military supply through E.ON.22
- Buildots: Commercial construction software; no identified military or settlement procurement.15
- RWE / Belectric Israel: Historical RWE-controlled Israeli solar business sold in 2021; no verified E.ON attribution.18, 21
Digital: Digital
Mechanism of Involvement
No public evidence identified of an E.ON licensing, subscription, integration, or managed-service relationship with identified Israeli-origin cybersecurity suppliers, or of Israeli-origin biometric, facial-recognition, behavioural-analytics, predictive-policing, or surveillance technology used by E.ON.20
E.ON’s verified cloud relationship is with Google Cloud for E.ON Optimum, a commercial energy-analytics product. The cited record does not disclose Israeli data storage, routing, processing, legal access, or Israeli-controlled infrastructure; no public evidence identified that this data pipeline touches Israeli jurisdiction.20
No public evidence identified that E.ON operates data-centre infrastructure in Israel, participates in Project Nimbus, provides cloud services to Israeli state bodies, or supplied AI, cyber, surveillance, autonomous, intelligence, policing, prison, occupation, or settlement-security systems to Israeli recipients.20
Counter-Arguments and Evidence Limits
The material does not support transforming E.ON’s innovation relationship with FEV or historical innogy activity into a verified digital-security relationship. FEV’s Israeli footprint and portfolio references are not evidence of E.ON’s procurement or operational use of each portfolio technology, and the current status, ownership, headcount, address, and authority of a reported Tel Aviv FEV operation remain unverified.13, 20
The audits also correct the premise that RWE controls E.ON. RWE’s minority shareholding and board presence do not make RWE operations or historical innogy arrangements automatically attributable to E.ON.11, 21
Named Entities and Evidence Map
- E.ON Optimum / Google Cloud: Documented commercial energy-analytics cloud use; no identified Israel nexus in the data pipeline.20
- E.ON Digital Technology GmbH: Digital, consulting, cybersecurity, and innovation responsibilities were disclosed under Victoria Ossadnik; no identified Israeli state-security deployment.10, 20
- Future Energy Ventures: Strategic partner relationship, not proof that E.ON controls all FEV investments or that FEV activity supplied Israeli security bodies.13
- EON IO LTD: A name-collision lead identified as an unrelated Israeli cloud-backup and AI-analytics startup, not evidence of an E.ON SE subsidiary.20
Economic: Economic
Mechanism of Involvement
The primary economic nexus is E.ON’s ownership of E.ON Israel Ltd. E.ON’s 2022 and 2023 statutory schedules list the Herzliya affiliate at 100% group ownership and non-consolidation due to subordinate importance. The 2025 shareholding-list reproduction corroborates ownership through that date, while not independently establishing active operations or financial scale.1, 2
The second economic vector is E.ON’s documented FEV relationship and the E.ON-group-owned FEV Future Energy Ventures Israel Ltd. FEV’s Israeli investment activity includes documented participation in Buildots rounds, and the Israeli FEV vehicle was identified as a former Waycare equity holder in a US SEC filing. The available evidence does not identify investment amounts, control rights, E.ON’s specific capital commitment, transaction approval, or direct E.ON ownership of every FEV portfolio stake.3, 13, 17
No public evidence identified of E.ON acquiring or controlling an Israeli utility, manufacturer, consumer business, infrastructure company, or defence prime; underwriting Israeli sovereign debt, Israel Bonds, or war bonds; holding a Leviathan gas-field stake; operating Israeli retail-energy services; or generating separately disclosed Israeli revenue or tax payments.12, 23
Counter-Arguments and Evidence Limits
E.ON’s strongest defence is that the confirmed Israeli affiliate is documented as immaterial and non-consolidated, while the available descriptions point to innovation scouting and engineering support rather than energy sales, infrastructure operation, or physical-goods procurement. No audited entity-level revenue, payroll, tax, contract, licence, office lease, customer, or project record was identified in the bounded review.1, 2, 12
FEV linkage should be stated carefully. E.ON is an anchor investor and strategic partner, but reports of FEV’s independent fundraising and its spinout do not establish that FEV is presently an E.ON subsidiary or that E.ON controls individual investments. The 2025 Buildots round is documented as FEV participation, not a confirmed direct E.ON acquisition.4, 13, 19
RWE’s historical Belectric Israel operation was divested in 2021. The reviewed disclosure provides no identified settlement project, customer, revenue, workforce, tax contribution, or evidence that E.ON directed or operated it.18, 21
Named Entities and Evidence Map
- E.ON Israel Ltd.: 100%-held Herzliya affiliate in reviewed statutory schedules; immaterial/non-consolidated status documented.1
- FEV Future Energy Ventures Israel Ltd.: Listed as 100% group-owned; commercial registry and ownership-chain material support the identified group relationship, but not direct E.ON approval of each fund transaction.13
- Buildots: FEV participant in Series B, C, and D rounds; no identified defence, settlement, or security procurement.3, 4
- Waycare: SEC filing identifies FEV Future Energy Ventures Israel Ltd. as a former holder; no documented military, settlement, or state-contract nexus.17
- Belectric Israel: Former RWE-controlled business, divested in December 2021; not attributed to E.ON.18
Political: Political
Mechanism of Involvement
No E.ON corporate press release or other official corporate communication specifically addressing Israel-Palestine, 7 October 2023, or the Gaza war was identified in the reviewed material. Birnbaum’s January 2024 reported comment concerned potential energy-price effects of escalation, not civilian protection, international law, settlements, military support, or Palestinian rights.5, 24
RWE published an official statement on 23 October 2023 expressing solidarity with Israel, condemning Hamas’s attack, acknowledging civilian suffering in Israel and Gaza, stating Israel must protect its citizens, and hoping for de-escalation. RWE was E.ON’s material minority shareholder, not its demonstrated parent or operating controller.6, 11
E.ON’s documented Israel activity concerns innovation and affiliate operations, not a verified state partnership. No public evidence identified of Israeli state honours, government-hosting, Brand Israel sponsorship, Israel-Palestine lobbying, anti-BDS advocacy, donations to Israeli military-welfare, settlement, or nationalist organisations, or conflict-period asset mobilisation for Israeli state or military bodies.2, 25
Counter-Arguments and Evidence Limits
The strongest defence is attributional: RWE’s statement is RWE’s corporate act. The record does not establish an E.ON decision, republication, endorsement, instruction, joint action, or contractual mechanism making the statement an E.ON act. RWE’s 15% holding and a documented RWE-linked supervisory-board presence establish shareholder proximity, not operational control or authority over E.ON’s political communications.6, 11, 21
Historical E.ON participation in SOSA’s general innovation activity should not be conflated with SOSA Innofense, a distinct defence-technology programme. The audits identify ecosystem adjacency but no evidence that E.ON participated in the Ministry of Defense/IDF-linked Innofense track.16, 26
Named Entities and Evidence Map
- E.ON SE: No identified Israel-Palestine corporate statement, conflict lobbying disclosure, or relevant financial contribution.5, 25
- Leonhard Birnbaum: Reported January 2024 market-risk comment on possible energy-price effects from escalation; not a documented political position on the conflict.24
- RWE AG: E.ON material minority shareholder; made the October 2023 solidarity statement, without verified E.ON adoption.6, 11
- SOSA: General innovation-platform connection documented; no verified E.ON participation in Innofense.16, 26
Complicity Index Score
Method: V6.5.
| Domain | I | M | P | V-Domain Score |
|---|---|---|---|---|
| Military | 0.00 | 0.00 | 0.00 | 0.00 |
| Digital | 0.00 | 0.00 | 0.00 | 0.00 |
| Economic | 6.10 | 7.00 | 5.50 | 4.79 |
| Political | 3.10 | 4.00 | 7.00 | 1.77 |
- V_MAX: 4.79 Avg_OTHERS: 0.59
- BRS Score: 409 Tier: C (Substantial Complicity)
V_MAX is driven by the documented economic nexus: the wholly group-owned Israeli affiliate, E.ON’s FEV relationship, and documented fund-linked Israeli investment activity, subject to the ownership, control, scale, and transaction-specific caveats above. The political score reflects the fixed human-vetted assessment, including the carefully bounded RWE minority-shareholder statement and E.ON’s Israel-facing innovation footprint; it does not convert RWE into E.ON control or attribute unverified acts to E.ON.
The method is scale-free, evidence-only, and human-vetted: scores assess documented activity type, scale, and directness rather than advocacy claims, assumed affiliations, or unverified allegations.
Methodology Note
- Evidence is limited to the four supplied domain audits and their cited source record; claims not supported there are excluded or qualified.
- Impact (I) assesses documented activity type; Magnitude (M) assesses documented scale; Proximity (P) assesses directness to the relevant nexus.
- Divested, exited, or discontinued operations are mitigating facts. RWE’s Belectric Israel business was sold in December 2021 and is not treated as a current E.ON operation.18
- Entity attribution is not transitive: RWE’s minority holding, historical innogy activity, and separate corporate statement do not by themselves establish E.ON operational control or responsibility.11, 21
- Settlement operations, if documented, would be assessed in both Economic and Political; no public evidence identified of E.ON settlement operations in the reviewed record.8, 9
- “No public evidence identified” is used where the audits’ bounded and source-specific checks found no supporting public record; it is not a universal claim of absence.
Footnotes
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https://annualreport.eon.com/content/dam/eon-annualreport/documents/en/EON_GB23_engl_Anhang_online_final.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9
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https://de.marketscreener.com/boerse-nachrichten/eon-anteilsbesitzliste-gemaess-313-abs-2-hgb-ce7e5fd9d08afe2c ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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https://www.prnewswire.com/news-releases/buildots-announces-30-million-series-b-as-their-ai-for-construction-technology-reaches-12-countries-301348142.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://buildots.com/blog/buildots-raises-45m-in-series-d-funding/ ↩ ↩2 ↩3 ↩4 ↩5
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https://www.eon.com/en/about-us/media/press-release/2024.html ↩ ↩2 ↩3 ↩4
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https://www.rwe.com/en/press/rwe-ag/2023-10-23-against-hate-terror-and-anti-semitism-solidarity-with-israel/ ↩ ↩2 ↩3 ↩4 ↩5
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https://assets.publishing.service.gov.uk/media/5cb5a3d0ed915d3f51602d34/Non-Confidential_RWE_EON_Minority_Stake.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.ohchr.org/en/documents/thematic-reports/ahrc6019-database-all-business-enterprises-involved-activities-detailed ↩ ↩2 ↩3
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https://annualreport.eon.com/content/dam/eon-annualreport/documents/en/GB25-gesamt-EN_final.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://www.rwe.com/en/press/rwe-ag/2019-09-17-brussels-paves-the-way-for-one-of-the-biggest-transactions-the-new-rwe-can-get-started/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9
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https://www.checkid.co.il/company/%D7%90%D7%99.%D7%90%D7%95%D7%9F-%D7%99%D7%A9%D7%A8%D7%90%D7%9C-%D7%91%D7%A2~%D7%9E-516283298 ↩ ↩2 ↩3 ↩4
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https://annualreport.eon.com/content/dam/eon-annualreport/documents/en/GB24-gesamt-EN_final.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://fev.vc/110-million-euro-fund-for-the-digitalization-of-the-energy-transition-established/ ↩ ↩2 ↩3
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https://www.calcalistech.com/ctechnews/article/ryv7nabfge ↩ ↩2 ↩3
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https://en.globes.co.il/en/article-eon-looks-to-invest-in-israeli-startups-1001264489 ↩ ↩2 ↩3
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https://www.sec.gov/Archives/edgar/data/1697851/000119312521313484/d204494ds3.htm ↩ ↩2 ↩3
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https://www.rwe.com/en/press/rwe-renewables/2021-12-17-rwe-renewables-sells-belectrics-european-and-israeli-businesses-to-elevion-group/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://fev.vc/fev-closes-e235-million-fund-to-accelerate-the-independent-energy-future/ ↩ ↩2
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https://cloud.google.com/customers/e-on ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020M8870(02) ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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https://www.prnewswire.com/news-releases/deep-tech-company-prisma-photonics-raises-20-million-from-insight-partners-to-monitor-large-scale-critical-infrastructure-while-protecting-the-environment-301478483.html ↩ ↩2 ↩3 ↩4
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https://www.zeit.de/wirtschaft/2024-01/energiepreise-anstieg-eon-leonhard-birnbaum ↩ ↩2
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https://www.lobbyregister.bundestag.de/media/b0/21/425771/Lobbyregister-Registereintraege-Detailansicht-R002309-2024-09-11_09-54-24.pdf ↩ ↩2





