Galderma ECONOMIC

Target: Galderma Group AG Research cutoff: 25 October 2026 Geographic scope: Israel and occupied Palestinian territory, including East Jerusalem, the occupied West Bank and the occupied Golan Heights. Evidence scope: Corporate ownership, financial relationships, commercial licensing, sourcing, employment, operating activity and identifiable economic beneficiaries.

Supply Chain & Sourcing Relationships

Direct Israeli pharmaceutical relationships

Israeli pharmaceutical documentation establishes a relationship involving Galderma-manufactured medicines and AMI Technologies, an Israeli pharmaceutical registration holder based in Hod Hasharon. A June 2023 Israeli patient leaflet identifies AMI Technologies as the registration holder for Soolantra, registration number 167-59-36606-99, and Laboratoires Galderma in Alby-sur-Chéran, France, as manufacturer.¹

A separate June 2023 Israeli regulatory leaflet identifies AMI Technologies as the registration holder for Epiduo, registration number 156-10-34289, and Laboratoires Galderma, France, as manufacturer.²

An Aklief product document revised in May 2025 identifies A.M.I. Medical Technologies Limited, Hanagar 22, Hod Hasharon, Israel, as registration holder, with registration number 176-48-37123-99; Laboratoires Galderma in France is identified as manufacturer. This document establishes a regulatory relationship documented after 19 July 2024 and November 2024.³

Manufacturing and product supply

Galderma identifies four manufacturing countries: Canada, Sweden, France and Brazil. Its French manufacturing site produces dermatological medicines, including Soolantra, Aklief and Epiduo; the Swedish site produces injectable aesthetics products, including Restylane; and the Canadian site is a principal Cetaphil manufacturing facility.⁴

The regulatory documentation for Soolantra, Epiduo and Aklief independently identifies French manufacturing and an Israeli registration holder. The documentation does not identify AMI as a wholly owned Galderma subsidiary or specify the contractual importer of record.^{1, 2, 3}

Israeli agricultural suppliers

No public evidence identified of Galderma procuring agricultural produce from Mehadrin, Hadiklaim, Galilee Export, Agrexco successors or other identified Israeli agricultural exporters.

Dedicated importer-of-record structure

AMI Technologies is identified as an Israeli pharmaceutical registration holder for specific Galderma medicines. The documents do not establish the customs importer of record, Galderma’s ownership percentage in AMI, or a dedicated Galderma-owned Israeli importing company.^{1, 2, 3}

No public evidence identified of a Galderma-owned Israeli importer-of-record subsidiary or joint venture.

Seasonal sourcing

No public evidence identified of recurring seasonal procurement from Israeli agricultural suppliers, including December–April counter-seasonal procurement.

Third-party and indirect distribution

The named Israeli pharmaceutical registration holder provides evidence of an intermediary regulatory relationship for Galderma medicines. The examined registrations do not identify particular pharmacy chains, settlement wholesalers, white-label manufacturers or settlement-based distributors.^{1, 2, 3}

No public evidence identified of settlement-specific third-party distribution or white-label sourcing arrangements attributable to Galderma.

Group supply-chain structure

Galderma’s published corporate history identifies acquisitions of Q-Med in 2011 and Alastin in 2021, along with its international expansion in dermatology and aesthetics. These disclosures do not identify either acquisition as the purchase of an Israeli operating company.⁵

Israeli biotechnology licensing relationship

On 25 June 2021, Galderma Holding SA entered into two licensing agreements with Israeli-incorporated Sol-Gel Technologies Ltd. for US commercialisation of Twyneo and Epsolay. The agreements establish a direct pharmaceutical licensing relationship with an Israeli developer, distinct from agricultural procurement or ownership of an Israeli manufacturing subsidiary.^{6, 7}

The executed termination agreement identifies Galderma Holding SA as the Swiss contractual counterparty and Sol-Gel Technologies Ltd. as the Israeli counterparty. The original agreements were dated 25 June 2021, and their termination became effective on 17 April 2025.⁷

Subsequent commercial arrangements

Sol-Gel’s 2025 Form 20-F records that, on 17 April 2025, it entered into a product purchase and exclusive licence agreement with a subsidiary of Mayne Pharma Group Limited for the US rights to Epsolay and Twyneo, following termination of the Galderma agreements. The filing identifies USD 16 million received under the new arrangement during 2025.⁶

The Mayne agreement identifies a subsequent commercial counterparty and does not constitute evidence of continued Galderma licensing expenditure after termination.^{6, 7}

Settlement sourcing

No public evidence identified of Galderma sourcing medicines, ingredients, packaging materials, cosmetics or agricultural products from an identified Israeli settlement supplier.

Product Origin, Labeling & Regulatory Compliance

Documented country of manufacture

The Israeli Soolantra leaflet revised in June 2023 identifies Laboratoires Galderma, Alby-sur-Chéran, France, as manufacturer and AMI Technologies, Hod Hasharon, Israel, as registration holder.¹

The Israeli Epiduo leaflet revised in June 2023 identifies Laboratoires Galderma, France, as manufacturer and AMI Technologies as the Israeli registration holder.²

The Aklief product information revised in May 2025 identifies Laboratoires Galderma, France, as manufacturer and A.M.I. Medical Technologies Limited, Israel, as registration holder.³

Regulatory registration framework

The Israeli Ministry of Health describes the country’s cosmetics database as a public mechanism for checking cosmetic licences and marketing notifications. Its published guidance explains that the regulatory framework permits marketing records through licences or notifications submitted by manufacturers or importers; the guidance does not itself establish a particular Galderma cosmetic registration.⁸

Settlement-origin goods

No public evidence identified of Galderma medicines or cosmetics being manufactured in Israeli settlements or originating from settlement-based suppliers.

Country-of-origin labeling

No public evidence identified of a regulatory enforcement action against Galderma concerning settlement-origin labeling, a misleading “Produce of Israel” designation, or incorrect country-of-origin descriptions for products entering Israel.

Corporate settlement-labeling policy

No public evidence identified of a Galderma policy specifically addressing sourcing or labeling of goods from Israeli settlements or occupied Palestinian territory.

Product-specific origin distinction

The examined Israeli regulatory documents identify French manufacturing for three pharmaceutical products. These records establish their disclosed manufacturing origin but do not establish the origin of every ingredient, component, packaging material or other Galderma product.^{1, 2, 3}

Sol-Gel licensed products

Sol-Gel’s SEC filings identify Twyneo and Epsolay as the products covered by the June 2021 Galderma licences. The agreements concerned commercialisation in the United States and do not establish manufacturing or sales within Israel or occupied Palestinian territory.^{6, 7}

The executed termination agreement ended the original licensing arrangements on 17 April 2025. The subsequent Mayne transaction involved US commercialisation rights to the same products.^{6, 7}

Investment, Capital & Financial Exposure

Corporate ownership and investment history

Galderma was established in 1981 as a joint venture between L’Oréal and Nestlé. Nestlé acquired full control in 2014, and an institutional investment consortium acquired the business in 2019.^{5, 9}

EQT identifies its Galderma investment as entering its portfolio in 2019 and exiting in 2026.¹⁰

Galderma became publicly listed on the SIX Swiss Exchange in March 2024. Its 2025 financial statements identify Galderma Group AG as the parent of the consolidated group and record that the previously controlling EQT-led shareholder consortium lost control in March 2025.^{11, 12}

L’Oréal’s initial renewed investment

On 5 August 2024, L’Oréal announced that it had acquired a 10% stake in Galderma Group AG from an EQT-led shareholder consortium including Sunshine SwissCo AG, Abu Dhabi Investment Authority and Auba Investment Pte. Ltd. L’Oréal also announced plans to pursue a strategic scientific partnership with Galderma.¹³

The August 2024 acquisition occurred after the ICJ advisory opinion issued on 19 July 2024. It was an investment in Galderma Group AG shares held by existing institutional shareholders, rather than a documented acquisition of an Israeli operating company.¹³

L’Oréal’s additional 10% investment

On 8 December 2025, L’Oréal announced an agreement to acquire an additional 10% of Galderma from the EQT-led consortium, bringing its intended holding to 20%. The announced sellers included Sunshine SwissCo, Abu Dhabi Investment Authority and Auba Investment Pte. Ltd.^{14, 15}

Galderma confirmed the proposed transaction and disclosed that the increased investment could result in the nomination of two non-independent representatives to its board.¹⁶

L’Oréal’s 2025 financial reporting records completion of the transaction on 10 February 2026 for approximately EUR 4.2 billion, with the resulting holding accounted for using the equity method.¹⁷

Galderma’s annual financial reporting identifies the February 2026 acquisition as resulting in significant influence for L’Oréal. The transaction establishes a strategic minority holding rather than an acquisition of all Galderma equity.^{11, 17}

Capital-flow classification

L’Oréal’s February 2026 purchase involved existing Galderma shares transferred by institutional shareholders. The transaction therefore documents an equity ownership transfer and does not itself establish a direct capital contribution to an Israeli Galderma operation.^{14, 17, 15}

No public evidence identified that L’Oréal directly financed Galderma Holding SA’s payments under the historical Sol-Gel licensing agreements.

Governance influence arising from the investment

Galderma’s 20 March 2026 AGM announcement identified Delphine Viguier-Hovasse, L’Oréal’s Chief Innovation & Prospective Officer, and Samuel du Retail, L’Oréal’s Managing Director of Artificial Intelligence, Data and Shared Services, as proposed non-independent board members. They were nominated to replace representatives of the EQT-led consortium.¹⁸

On 22 April 2026, Galderma announced shareholder approval of their election as non-independent board members. The election established formal L’Oréal representation on Galderma’s board during 2026.¹⁹

L’Oréal’s 20% equity interest, equity-method accounting and two board representatives establish significant influence over Galderma. These disclosed arrangements do not establish that L’Oréal directly employed Sol-Gel personnel or became the contractual counterparty under the Sol-Gel licences.^{17, 7, 19}

Israeli direct investment

No public evidence identified of Galderma acquiring or establishing an Israeli manufacturing plant, data centre, logistics centre, industrial property or directly controlled Israeli operating business.

Israeli acquired subsidiaries - controlling ownership

Galderma’s consolidated company list as of 31 December 2025 identifies controlled subsidiaries and their countries of incorporation. No Israeli-incorporated controlled operating subsidiary was identified in the prior examination of that list.¹¹

The consolidated disclosure states that the listed subsidiaries’ countries of incorporation or registration serve as their main places of business. No public evidence identified of an acquisition date, acquisition price, Israeli manufacturing location, employee count or ownership percentage for an Israeli operating subsidiary acquired by Galderma.¹¹

No public evidence identified of a Galderma acquisition of a controlling stake in Sol-Gel Technologies Ltd. or AMI Technologies.

Pending acquisition

On 14 October 2026, Galderma announced an agreement to acquire 100% of ZO Skin Health for an enterprise value of USD 1.5 billion. The target was described as headquartered in Irvine, California, with US manufacturing and approximately USD 330 million in trailing twelve-month sales to June 2026. Closing was expected in late 2026 or early 2027, subject to conditions.²⁰

The announcement did not identify ZO Skin Health as an Israeli-incorporated operating company or document an Israeli manufacturing facility.²⁰

Research and development investments

Galderma identifies Uppsala, Sweden, as its global centre of excellence for injectable aesthetics and a location for product research, development and manufacturing. Its published manufacturing disclosure does not identify an equivalent facility in Israel.⁴

In December 2025, Galderma and L’Oréal described plans to explore additional scientific research projects of mutual interest. The announcement did not identify an Israeli research institution, Israeli facility or Israel-specific collaboration.¹⁶

Pharmaceutical partnership structure

In January 2026, Galderma announced an arbitral decision concerning the termination of a neuromodulator research and development partnership with Ipsen dating from 2014. Galderma stated that the decision did not affect its commercialisation arrangements for specified neuromodulator products. No Israel-specific research facility or financial commitment was established by that announcement.²¹

Sol-Gel licensing exposure

Sol-Gel Technologies Ltd.’s audited financial statements establish a commercial licensing relationship with Galderma covering Twyneo and Epsolay, with royalties recognised in connection with the products’ US commercialisation. The 2025 financial statements report USD 1.482 million in 2024 royalty revenue and USD 711,000 in 2025 royalty revenue in respect of the agreements.⁶

These recognised revenues establish a contractual financial relationship with an Israeli biotechnology company. They do not establish an equity investment by Galderma in Sol-Gel, acquisition of the Israeli company, Israeli manufacturing expenditure or settlement-related capital investment.^{6, 7}

Distinction between Galderma and L’Oréal attribution

The executed termination agreement identifies Galderma Holding SA and Sol-Gel Technologies Ltd. as the contracting parties. It does not name L’Oréal as a party to the licensing arrangements.⁷

L’Oréal’s documented relationship during 2024–2026 was an equity investment in Galderma Group AG, subsequently accompanied by board representation. These disclosures do not establish that L’Oréal acquired Sol-Gel or directly assumed Galderma Holding SA’s historical contractual obligations.^{17, 7, 13, 19}

Shareholder and portfolio exposure

The documented 20% L’Oréal shareholding is a strategic minority investment in Galderma. It does not establish that Galderma controls L’Oréal’s other subsidiaries or investments.^{14, 17}

No public evidence identified establishing that Galderma itself owns Israeli sovereign bonds, Israel Bonds, Israeli-domiciled investment funds or material portfolios of Israeli securities.

Financing the Israeli state

No public evidence identified of Galderma underwriting Israeli sovereign debt, arranging Israeli war bonds, distributing Israel Bonds, underwriting Israeli state insurance or directly financing Israeli defence manufacturers or settlement enterprises.

Controlling principals’ investments

Galderma’s corporate governance disclosures identify Thomas Ebeling as board chair and Flemming Ørnskov as chief executive and board member. The April 2026 AGM results identify Sherilyn McCoy, Harry Kirsch, Daniel Browne, Maria Teresa Hilado, Karen Lee Ling, Roberto Marques, Samuel du Retail and Delphine Viguier-Hovasse among the other elected board members.^{22, 19}

Galderma’s biography of Flemming Ørnskov describes his earlier executive employment at Shire, Bayer, Novartis and Merck, and identifies a non-executive chairmanship at Waters Corporation. The biography does not document a personal Israeli investment.²³

No public evidence identified establishing material personal or family-office investment by Galderma’s named executives or directors into an Israeli defence company, settlement enterprise or Israeli operating company.

Operational Presence & Market Activity

Documented Israeli pharmaceutical-market presence

The Israeli Soolantra, Epiduo and Aklief regulatory records establish Galderma pharmaceutical products associated with an Israeli registration holder, AMI Technologies, whose registered address is in Hod Hasharon.^{1, 2, 3}

The May 2025 Aklief documentation provides evidence of a registration relationship documented after the ICJ advisory opinion of 19 July 2024 and the ICC arrest warrants issued in November 2024. The document does not establish the date of an individual sale, customer identity or shipment destination.³

Directly operated offices

No public evidence identified establishing a Galderma-owned or Galderma-operated office, factory, warehouse or research centre in Israel.

Regional operating structure

Galderma’s Middle East corporate webpage identifies Galderma International SAS as the regional contact entity and provides an office address in Dubai Healthcare City, United Arab Emirates. This regional office disclosure does not establish a physical Galderma office in Israel.²⁴

Manufacturing locations

Galderma’s manufacturing disclosure identifies production facilities in Baie-D’Urfé, Canada; Uppsala, Sweden; Alby-sur-Chéran, France; and Hortolândia, Brazil. Israel is not among the four manufacturing countries identified.⁴

Israeli regulatory counterparties

The pharmaceutical documents identify AMI Technologies or A.M.I. Medical Technologies Limited as the Israeli registration holder for individual medicines. They do not disclose the company’s ownership structure, workforce, import volumes or tax liabilities.^{1, 2, 3}

Sol-Gel - identifiable Israeli operating company

Sol-Gel Technologies Ltd.’s 2025 Form 20-F identifies Israel as its jurisdiction of incorporation and Ness Ziona as its principal executive-office location. Sol-Gel was the Israeli contracting party under the Galderma Holding SA licensing arrangements.^{6, 7}

Sol-Gel - employment

As of 31 December 2025, Sol-Gel reported 28 employees, all located in Israel, compared with 34 employees in 2024 and 36 in 2023. The 2025 workforce comprised five management employees and 23 employees in research, development and other functions.⁶

The reported workforce belongs to Sol-Gel Technologies Ltd. The disclosure does not allocate those employees to individual customer contracts or identify them as employees of Galderma Holding SA or L’Oréal.^{6, 7}

Sol-Gel - operating activity and results

Sol-Gel reported approximately USD 19.4 million in total revenue in 2025, compared with approximately USD 11.6 million in 2024. Its management attributed the increase principally to milestones under commercial agreements with Mayne and Searchlight.⁶

Sol-Gel reported net losses of approximately USD 27.2 million in 2023, USD 10.6 million in 2024 and USD 6.1 million in 2025. Its accumulated deficit was approximately USD 237.0 million at 31 December 2025.⁶

These financial figures describe Sol-Gel’s entire business and cannot be attributed exclusively to Galderma’s licensing arrangements. The agreement-specific royalty amounts are separately identified in the financial-statement notes.⁶

Sol-Gel - US subsidiary cessation

Sol-Gel’s 2025 financial statements identify Sol-Gel Technologies Inc. as a wholly owned US subsidiary that supported marketing, regulatory affairs and business development. The filing states that this subsidiary ceased operating in 2024.⁶

The cessation of the US subsidiary does not establish cessation of Sol-Gel Technologies Ltd.’s Israeli operations, which continued to report employees, revenue and expenditure during 2025.⁶

Galderma-attributable Israeli employment

No public evidence identified quantifying the number of Israeli employees directly or indirectly supported by the Galderma–Sol-Gel agreements.

No public evidence identified establishing the proportion of Sol-Gel’s Israeli payroll, R&D expenditure or administrative expenses financed by Galderma-related royalties.

Galderma employment and taxation

No public evidence identified quantifying Galderma-attributable employment in Israel, payroll expenditure, Israeli corporation tax payments or local tax residence.

Market positioning

Galderma described itself in December 2025 as operating in approximately 90 countries worldwide. The announcement did not identify Israeli revenue, Israeli market share or an Israeli regional headquarters.¹⁶

No public evidence identified of Galderma formally designating Israel as a strategic growth market, regional hub or principal market in its examined public disclosures.

Settlement market activity

No public evidence identified establishing Galderma-operated premises, named pharmaceutical customers, clinic distribution contracts or documented sales destinations in Israeli settlements in the West Bank, East Jerusalem or the Golan Heights.

Military and defence procurement

No public evidence identified of Galderma supplying medicines, aesthetics products, technology or services under a named Israeli Ministry of Defence or IDF procurement contract.

Employment policies

No public evidence identified of a Galderma-specific Israeli military reservist salary subsidy, military-leave programme or associated financial commitment.

Charitable programmes

No public evidence identified of Galderma matching employee donations to a named Israeli military-support organisation or settlement-linked charity.

US commercialisation of Israeli-developed medicines

The executed 2025 Galderma–Sol-Gel termination agreement identifies the United States as the territory for the original Twyneo and Epsolay licensing arrangements. Sol-Gel’s financial statements recognise associated royalty revenues during 2024 and 2025, but these documents do not identify an Israeli retail customer or settlement destination for the products.^{6, 7}

Constructive-notice chronology

The Galderma–Sol-Gel licensing agreements originated on 25 June 2021 and terminated effective 17 April 2025. Their contractual existence therefore extended beyond 19 July 2024 and November 2024.⁷

Sol-Gel’s interim financial statements report USD 433,000 of Galderma-related royalty revenue for the six months ended 30 June 2025. Because the termination agreement was effective on 17 April 2025, the interim accounting recognition does not independently demonstrate that the original licences remained operative throughout the first half of 2025.^{7, 25}

Current status of the identified licensing arrangements

The executed agreement terminated the original Galderma licences effective 17 April 2025, while preserving specified consequences of termination and surviving contractual rights and obligations.⁷

Sol-Gel’s 2025 Form 20-F documents a replacement commercial agreement with a Mayne Pharma subsidiary on the same date. The filing does not identify the Mayne arrangement as a continuation of the Galderma licences.^{6, 7}

No public evidence identified of a replacement Galderma–Sol-Gel commercialisation agreement in force at the 25 October 2026 research cutoff.

Current status of the Israeli registration relationship

The May 2025 Aklief regulatory documentation identifies AMI as the Israeli registration holder after both specified constructive-notice dates.³

No public evidence identified establishing that the Galderma–AMI registration relationship had been formally terminated by the research cutoff.

No public evidence identified establishing the number or value of Galderma product shipments or transactions in Israel during 2026.

Corporate Structure & Foundational Ties

Founding history

Galderma traces its establishment to a 1981 joint venture between Nestlé and L’Oréal. The company’s documented corporate heritage is associated with those two groups rather than an Israeli founder or Israeli incorporation.^{5, 9}

In 2014, Nestlé assumed full ownership of the joint venture. A consortium of institutional investors subsequently acquired the business in 2019.^{9, 10}

Legal domicile

Galderma Group AG is a Swiss corporate entity listed on the SIX Swiss Exchange. Its 2025 annual reporting describes the Swiss parent structure and identifies Galderma Holding SA as a principal group entity.^{11, 12}

Headquarters

Galderma’s corporate announcements identify Zug, Switzerland, as its corporate location. The company also identifies Zug as its global headquarters in annual reporting.^{11, 16}

Israeli-Nexus Floor - founding

The documented corporate history identifies Galderma’s establishment as a Nestlé–L’Oréal joint venture in 1981 rather than incorporation as an Israeli-origin business.^{5, 9}

No public evidence identified of Galderma having been founded in Israel.

Israeli-Nexus Floor - headquarters

Galderma’s corporate and annual disclosures identify Switzerland as the headquarters location.^{11, 16}

No public evidence identified of Galderma maintaining its global headquarters or principal place of management in Israel.

Israeli-Nexus Floor - tax residence or PTE status

No public evidence identified of Israeli tax residency, Preferred Technology Enterprise status or an Israeli corporate tax incentive awarded to Galderma.

Israeli-Nexus Floor - beneficial ownership or control

The identified historical controlling consortium comprised institutional investors associated with EQT, Abu Dhabi Investment Authority and Singapore-linked Auba Investment. Galderma’s 2025 accounts state that the consortium lost control in March 2025.^{11, 15}

L’Oréal acquired 10% of Galderma in August 2024 and increased its holding to 20% on 10 February 2026. The available corporate disclosures identify a strategic minority investment rather than Israeli beneficial control of Galderma Group AG.^{17, 13}

No public evidence identified demonstrating Israeli beneficial control of Galderma Group AG.

Subsidiary ownership

The consolidated group listing in the 2025 financial statements does not identify an Israeli-incorporated controlled subsidiary. AMI Technologies appears instead as a named Israeli pharmaceutical registration holder in regulatory documentation.^{1, 2, 3, 11}

No public evidence identified that Sol-Gel Technologies Ltd. was a controlled subsidiary of Galderma or L’Oréal.

Galderma Holding SA as licensing counterparty

The executed agreement terminating Sol-Gel’s Twyneo and Epsolay licences identifies Galderma Holding SA as the Galderma contracting entity and gives its Swiss address as Avenue d’Ouchy 4, Lausanne. It identifies Sol-Gel Technologies Ltd. as an Israeli company with an address in Ness Ziona.⁷

Sol-Gel’s 2025 annual report identifies Israel as its jurisdiction of incorporation and Ness Ziona as the location of its principal executive offices. This establishes the domicile of the Israeli licensing counterparty without establishing Israeli corporate ownership or control of Galderma.⁶

L’Oréal’s ownership and operating relationship

L’Oréal’s August 2024 acquisition established a 10% equity holding in Galderma Group AG and plans for scientific cooperation. Its February 2026 additional investment raised the holding to 20%, accompanied by equity-method accounting.^{17, 13}

The March 2026 AGM materials nominated two L’Oréal representatives to replace EQT consortium representatives, and the April 2026 AGM results confirm their election.^{18, 19}

These disclosures establish an investment and governance relationship between L’Oréal and Galderma Group AG. The executed Sol-Gel agreement independently identifies Galderma Holding SA as the operating contractual counterparty.^{7, 13, 19}

Relevant employing entities

Sol-Gel Technologies Ltd. reported 28 employees in Israel at 31 December 2025. Its separate US subsidiary, Sol-Gel Technologies Inc., had ceased operating in 2024.⁶

The disclosed employment records identify Sol-Gel’s own workforce, rather than a workforce legally employed by Galderma Group AG, Galderma Holding SA or L’Oréal.^{6, 7}

Governance

Galderma’s April 2026 AGM results confirm the election of Thomas Ebeling as chair and the election or re-election of Harry Kirsch, Daniel Browne, Maria Teresa Hilado, Karen Lee Ling, Roberto Marques, Sherilyn McCoy, Flemming Ørnskov, Samuel du Retail and Delphine Viguier-Hovasse to its board.¹⁹

The AGM results identify Samuel du Retail and Delphine Viguier-Hovasse as non-independent representatives of L’Oréal.¹⁹

Galderma announced on 1 July 2025 that Thomas Dittrich would depart as chief financial officer, with transitional arrangements specified in its announcement. No Israel-specific corporate appointment or Israeli state nomination was identified in that disclosure.²⁶

State ownership and institutional linkages

No public evidence identified of an Israeli government ownership stake, Israeli government-appointed board member, designation of Galderma as Israeli critical infrastructure or a named Israeli government contract involving Galderma.

Structural governance mechanisms

No public evidence identified of Israeli state golden shares, Israeli state veto rights, founder-control arrangements linked to Israeli policy objectives or charter provisions establishing a formal governance obligation to the Israeli state.

Profit Repatriation & Economic Contribution

Global revenue

Galderma reported 2025 net sales of USD 5.207 billion, representing growth of 17.7% at constant currency, and Core EBITDA of USD 1.211 billion.²⁷

Israeli revenue

No public evidence identified disclosing Galderma’s Israeli revenue as a separate geographic reporting segment or identifying a specific annual Israeli turnover figure.

Documented commercial mechanism

Israeli pharmaceutical registrations identify Galderma-manufactured products and AMI Technologies as the Israeli registration holder. These documents establish an Israeli market regulatory relationship but do not disclose wholesale prices, royalties, licensing fees, transfer prices or net profit distribution.^{1, 2, 3}

Direction of international profits

Galderma’s 2025 financial statements describe a Swiss parent and a multinational subsidiary group. They do not separately quantify profit repatriation originating from Israel or paid to an Israeli owner.¹¹

Dividend distributions

Galderma’s 2025 financial disclosures record a shareholder distribution approved in April 2025 of CHF 0.15 per eligible share, totalling approximately CHF 36 million. This distribution is a group-level shareholder payment and does not identify an Israeli recipient or an Israeli source of profits.¹¹

Galderma’s April 2026 AGM results also confirm approval of a gross dividend of CHF 0.35 per dividend-bearing share. The announcement does not identify an Israel-specific source of distributed profits.¹⁹

Shareholder capital flows

L’Oréal’s February 2026 additional investment was an acquisition of existing Galderma shares from the former shareholder consortium. L’Oréal’s financial disclosure identifies the purchase consideration as approximately EUR 4.2 billion.^{14, 17}

The February 2026 transaction establishes a capital transfer associated with ownership of Galderma shares. It does not itself document additional capital invested in Israeli Galderma operations or a direct payment to Sol-Gel.^{14, 17, 7}

Research and manufacturing expenditure

Galderma identifies manufacturing facilities in France, Sweden, Canada and Brazil, including research and manufacturing operations in Uppsala. No corresponding Israeli manufacturing facility is identified in that disclosure.⁴

Economic ecosystem significance

No public evidence identified quantifying Galderma’s share of the Israeli dermatology market, its contribution to Israeli pharmaceutical employment or its significance as a nationally designated Israeli industry participant.

Settlement-linked economic contribution

No public evidence identified establishing settlement-specific Galderma revenue, Israeli settlement taxes, settlement-based rents, settlement supplier payments or Galderma-funded settlement infrastructure.

Financial exposure through intermediaries

The identified AMI registration relationship does not establish AMI’s customer-level revenues or Galderma’s share of the Israeli intermediary’s profits. No public evidence identified establishing the amount of Galderma-related income retained by AMI Technologies.^{1, 2, 3}

Sol-Gel Technologies - quantified pharmaceutical royalties

Sol-Gel Technologies Ltd., an Israeli biotechnology company headquartered in Ness Ziona, disclosed a quantified royalty relationship with Galderma in its 2025 annual report, Form 20-F, filed with the US Securities and Exchange Commission in 2026. Note 9(a) records that Sol-Gel entered into two exclusive licensing agreements with Galderma in June 2021 for the US commercialisation of Twyneo and Epsolay.⁶

Sol-Gel recognised USD 1.482 million in royalty revenue attributable to these agreements in 2024 and USD 711,000 in 2025, equivalent to USD 2.193 million across the two years. These amounts represent revenue recognised by Sol-Gel rather than independently verified cash transfers or profits retained after expenses.⁶

The executed termination agreement identifies Galderma Holding SA as the contractual counterparty, specifies that the original licensing agreements were dated 25 June 2021, and establishes 17 April 2025 as the effective termination date. The agreements concerned commercialisation rights in the United States.⁷

Reconciliation of 2024 royalty disclosures

Sol-Gel’s 2025 Form 20-F, Item 5, describes Galderma-related royalty revenue of USD 1.2 million for 2023, USD 1.6 million for 2024 and USD 0.7 million for 2025. Note 9(a) provides the more precise agreement-specific amounts of USD 1.482 million for 2024 and USD 711,000 for 2025.⁶

The difference between Item 5’s USD 1.6 million and Note 9(a)‘s USD 1.482 million for 2024 is USD 118,000. The difference is not explained by conventional rounding to one decimal place in millions, which would ordinarily present USD 1.482 million as USD 1.5 million.⁶

The 2025 Form 20-F’s geographical revenue disclosure separately reports Switzerland-attributed revenue of USD 1.482 million for 2024 and USD 711,000 for 2025. These figures match the amounts reported for the Galderma licensing agreements in Note 9(a). The same geographical table identifies USD 1.027 million for Switzerland in 2023.⁶

Sol-Gel’s preceding 2024 Form 20-F also reports USD 1.482 million of royalty revenue from the Galderma agreements for 2024 and USD 1.027 million for 2023. Its geographical revenue disclosure independently reports Switzerland-attributed revenue of USD 1.482 million for 2024.²⁸

The examined annual reports do not provide an explicit reconciliation explaining the additional USD 118,000 in the 2025 Form 20-F’s Item 5 narrative. The agreement-specific USD 1.482 million and USD 711,000 amounts are retained because they are corroborated by the financial-statement notes and geographical revenue disclosures in the annual filings.^{6, 28}

No public evidence identified establishing whether the USD 118,000 difference arose from an additional revenue component, an editorial error or another accounting classification.

Interim revenue corroboration

Sol-Gel’s interim financial statements for the six months ended 30 June 2024 report USD 723,000 of Galderma-related royalty revenue for that period, compared with USD 466,000 in the equivalent period of 2023.²⁹

Sol-Gel’s interim financial statements for the six months ended 30 June 2025 report USD 433,000 of Galderma-related royalty revenue, compared with USD 723,000 in the corresponding period of 2024. The same financial statements confirm that the agreements were mutually terminated in April 2025.²⁵

The USD 433,000 recognised during the first six months of 2025 forms part of a reporting period extending beyond the 17 April 2025 termination date. Its recognition does not establish that the original commercialisation licences remained in force after termination.^{7, 25}

Geographic attribution of royalty revenue

The 2025 Form 20-F attributes USD 1.482 million in 2024 and USD 711,000 in 2025 to Switzerland in Sol-Gel’s geographical revenue table. The executed termination agreement identifies Galderma Holding SA, a Swiss company, as the contractual counterparty, while identifying the United States as the commercialisation territory.^{6, 7}

The geographical accounting attribution and US commercialisation territory do not establish that the products were sold in Israel, that royalty proceeds were deposited in Israeli bank accounts or that the income originated from settlement activity.^{6, 7}

Identifiable Israeli economic beneficiary

Sol-Gel Technologies Ltd. was the Israeli-incorporated recipient of the revenue recognised under the Galderma licensing agreements. It maintained its principal executive offices in Ness Ziona, Israel.^{6, 7}

The audited reporting identifies royalty revenue at company level but does not allocate the corresponding receipts to particular Israeli employees, research projects, facilities, tax payments or shareholders.⁶

Downstream employment

Sol-Gel reported 28 employees as of 31 December 2025, all located in Israel, compared with 34 employees in 2024 and 36 in 2023.⁶

The reported 2025 workforce comprised five management employees and 23 employees in research, development and other functions. These employees belonged to Sol-Gel’s business as a whole.⁶

No public evidence identified establishing the number of Israeli jobs specifically financed by the Galderma–Sol-Gel licensing arrangements.

Sol-Gel operating results

Sol-Gel reported total annual revenues of approximately USD 11.6 million in 2024 and USD 19.4 million in 2025. Management attributed the 2025 increase mainly to milestone payments from the Mayne and Searchlight commercial agreements.⁶

Sol-Gel reported net losses of USD 10.580 million in 2024 and USD 6.127 million in 2025, following a net loss of approximately USD 27.2 million in 2023.⁶

Its accumulated deficit was approximately USD 237.0 million at 31 December 2025. The company’s financial statements also contained disclosures concerning its ability to finance future operations.⁶

The overall revenue and loss figures describe Sol-Gel’s consolidated operations. The audited reports separately identify the smaller royalty amounts attributable to Galderma.⁶

Cessation of the original licensing arrangements

The executed termination agreement ended the Twyneo and Epsolay licensing arrangements effective 17 April 2025. The document also addresses accrued rights, payments and other contractual consequences of termination.⁷

The original licences were therefore active after 19 July 2024 and November 2024 but had terminated by the October 2026 research cutoff.⁷

Subsequent Mayne Pharma transaction

Sol-Gel’s 2025 Form 20-F reports that it entered into a product purchase and exclusive licence agreement with a Mayne Pharma subsidiary on 17 April 2025 for the US rights to Twyneo and Epsolay, following termination of the Galderma agreements.⁶

Sol-Gel received USD 16 million in 2025 under that separate transaction, consisting of USD 10 million in the second quarter and USD 6 million in the fourth quarter.⁶

The Mayne agreement identifies a distinct subsequent commercial counterparty. It does not establish continuation of the original Galderma licences or additional Galderma payments under the replacement agreement.^{6, 7}

Sol-Gel US subsidiary and residual operations

Sol-Gel’s 2025 financial statements identify a wholly owned US subsidiary, Sol-Gel Technologies Inc., which supported marketing, regulatory affairs and business development. The filing states that the subsidiary ceased operating in 2024.⁶

Sol-Gel Technologies Ltd., the Israeli parent, continued reporting revenue, expenditure and employees in 2025, including Galderma-related royalty revenue recognised during the year.⁶

Post-termination financial recognition

Sol-Gel recognised USD 711,000 of Galderma-related royalties during fiscal 2025, including USD 433,000 in the six months ended 30 June 2025. The executed termination agreement establishes that the original licensing rights ended on 17 April 2025.^{6, 7, 25}

The existence of 2025 accounting revenue does not independently establish that the licensing agreements continued after termination or that cash was received on the dates of revenue recognition.^{6, 7}

No public evidence identified of a new Galderma–Sol-Gel licensing agreement replacing the terminated US commercialisation licences.

L’Oréal’s relationship to the Israeli economic beneficiary

L’Oréal acquired 10% of Galderma Group AG in August 2024 and increased its stake to 20% in February 2026, with two representatives subsequently elected to Galderma’s board.^{17, 13, 19}

The Galderma–Sol-Gel executed agreement identifies Galderma Holding SA and Sol-Gel Technologies Ltd. as its legal parties. L’Oréal is not named as a contracting party.⁷

The available investment, contractual and employment records establish separate roles for L’Oréal, Galderma Holding SA and Sol-Gel Technologies Ltd. They do not document a direct L’Oréal employment relationship with Sol-Gel personnel or direct L’Oréal operation of Sol-Gel’s Israeli facilities.^{17, 6, 7, 19}

Post-July 2024 and post-November 2024 continuity

The executed termination agreement establishes that the Galderma–Sol-Gel licences remained contractually operative until 17 April 2025. The contractual relationship therefore continued after 19 July 2024 and November 2024, before being terminated in April 2025.⁷

Sol-Gel’s 2025 Form 20-F recognises USD 711,000 of royalty revenue associated with the agreements during the 2025 reporting year. This accounting recognition does not independently establish the timing of cash settlement or the continuation of licensing rights after 17 April 2025.^{6, 7}

Distinction between operating relationships and ownership

The Sol-Gel licensing agreements establish contractual pharmaceutical rights and related royalty revenue attributable to an Israeli-incorporated biotechnology company. The examined agreements do not establish that Galderma acquired a controlling stake in Sol-Gel or operated its Israeli facilities.^{6, 7}

The agreements concern US pharmaceutical commercialisation. No public evidence identified linking the royalties to Israeli settlement production, settlement customers, Israeli military procurement or sales within occupied Palestinian territory.^{6, 7}

Residual Israeli economic activity

The May 2025 Israeli Aklief registration documentation establishes a separate regulatory relationship involving Galderma-manufactured pharmaceutical products and AMI Technologies after termination of the Sol-Gel US licences.^{3, 7}

The Galderma–Sol-Gel termination therefore does not establish cessation of every separate Galderma commercial or regulatory relationship involving Israel.^{3, 7}

No public evidence identified quantifying subsequent Galderma-attributable Israeli revenue, employment, tax payments or settlement-related economic activity at the research cutoff.