Military Audit: HSBC Holdings PLC

Audit Phase: Military - Defence, Security & Military-Adjacent Supply Chain Target Company: HSBC Holdings PLC (including HSBC Bank Israel) Audit Date: 28 June 2026

Direct Defence Contracting & Procurement

HSBC Holdings PLC is a global banking and financial services group; it does not supply equipment, services, or maintenance to military bodies in the conventional procurement sense. No public evidence identified of HSBC holding contracts, tender awards, framework agreements, or memoranda of understanding with the Israeli Ministry of Defence (IMOD), Israel Defence Forces (IDF), Israel Prison Service, or Israel Border Police.

No public evidence identified of HSBC appearing in SIBAT export directories, international defence exhibition catalogues, or Israeli defence procurement registries.

HSBC’s corporate website for its Israel operation describes the branch providing “corporate and institutional banking products and services” to “international Israeli corporates, institutions and multinational companies or their local subsidiaries,” with a stated focus on the technology sector ¹. No defence-sector-specific services are disclosed on that page ¹. In January 2019, HSBC Chief Legal Officer Stuart Levey confirmed that “HSBC has a banking operation in Tel Aviv and provides banking services to numerous Israeli companies. We have every intention of continuing to do so” ²³. No defence-sector carve-out was stated in that communication ²⁴³.

No public evidence identified of any Foreign Military Sales notification naming HSBC as a prime contractor, sub-contractor, or service provider.

Dual-Use Products & Tactical Variants

HSBC is a banking and financial services institution and does not manufacture, develop, or market physical products of any kind. No public evidence identified of HSBC producing or commercialising dual-use technologies, militarised product variants, or civilian-to-military adaptation programmes.

HSBC’s sole avenue of relevance to dual-use supply chains is through its role as a financial intermediary - specifically as an equity holder, lender, and underwriter of companies that manufacture weapons and dual-use equipment, as documented under Supply Chain Integration with Defence Primes below ⁵⁶.

No public evidence identified of HSBC filing or receiving export licences, end-user certificates, or being subject to export control review in connection with Israeli defence or security end-users.

Heavy Machinery, Construction & Infrastructure

HSBC does not manufacture, lease, or distribute heavy machinery or construction equipment. No public evidence identified of HSBC-branded or HSBC-supplied heavy plant operating in the Occupied Palestinian Territory, the West Bank, East Jerusalem, Gaza, or the Golan Heights.

As a passive equity investor, HSBC held shares in Caterpillar Inc. valued at approximately £99–£99.5 million, as documented in War on Want’s “Deadly Investments” report of July 2017 ⁵⁷⁸. War on Want’s January 2019 campaign update further confirmed that HSBC “has shares in and participated in syndicated loans to Caterpillar” as of early 2019 ⁹. Caterpillar’s D9 bulldozer has been documented as having been modified and deployed by the IDF to demolish Palestinian structures in the West Bank and Gaza ⁵¹⁰. This constitutes an indirect financial relationship via equity holding; HSBC’s connection to those operations is as a passive shareholder, not as supplier, distributor, intermediary, or direct contractor ⁵⁹¹⁰.

No primary 13F filing data confirming HSBC’s Caterpillar position for the period 2023–2026 was available in this research session; the War on Want figure of approximately £99–£99.5 million applies to the pre-2020 period ⁵.

No public evidence identified of HSBC holding direct contracts for construction, demolition, or maintenance of checkpoints, detention facilities, the separation barrier, or settlement infrastructure in any Israeli-administered territory.

Supply Chain Integration with Defence Primes

Note: HSBC is a financial institution. Its integration with defence primes takes the form of equity holdings, syndicated loans, underwriting arrangements, and other financial services - not physical component supply or sub-tier manufacturing. The following documents those financial relationships.

Elbit Systems Ltd (NASDAQ: ESLT)

HSBC’s most extensively documented relationship with an Israeli defence prime is its recurrent equity holding in Elbit Systems, Israel’s largest private defence contractor and the principal supplier of unmanned aerial systems to the IDF ¹¹.

War on Want’s “Deadly Investments” report (July 2017) first publicly disclosed HSBC’s shareholding in Elbit Systems, then valued at approximately £3.1 million ⁵¹²¹³. HSBC’s initial response described the holding as being maintained “on behalf of clients” ¹¹.

On 20 December 2018, HSBC fully divested its Elbit shareholding ^141512161718. HSBC confirmed this divestment to the Palestine Solidarity Campaign and War on Want by email on 23 December 2018 and issued a public announcement on 27 December 2018 ¹⁴¹². In January 2019, HSBC Chief Legal Officer Stuart Levey stated: “HSBC’s decision to divest from Elbit Systems was not the result of campaigning by the Boycott, Divestment and Sanctions movement… HSBC’s decision was based on our long-standing defense policy whereby we do not invest in companies linked to the production or marketing of cluster munitions” ²⁴³. HSBC attributed the trigger to Elbit’s November 2018 acquisition of IMI Systems (Israel Military Industries), whose products included cluster munitions of types M85, M970, and M971 ²¹⁹³. Elbit Systems publicly disputed the stated rationale, issuing a denial that it produces cluster munitions ²⁰.

Notwithstanding the 2018 divestment, HSBC re-established a position in Elbit Systems by approximately September 2020, as reflected in subsequent third-party reporting and regulatory filings ²¹²². By Q1 2024, HSBC had grown its Elbit stake by 40.4% to approximately 11,169 shares ²¹. In the Q2 2024 13F filing (filed approximately August 2024), HSBC held 12,826 shares of Elbit Systems - representing a further increase of 1,657 shares (+14.8%) - with that position valued at approximately $5,707,000 ²¹²³. As of the Q2 2025 13F filing (August 2025), HSBC still held 12,826 shares of Elbit Systems ²³²⁴²⁵. In August 2025, an SEC filing disclosed that HSBC Holdings PLC purchased 3,213 additional Elbit shares in a single transaction ²⁶. Between August and November 2025, HSBC increased its Elbit holding by a further 27.22%, from 12,826 shares to 16,317 shares ²³²⁴²⁵. At the November 2025 valuation date, those 16,317 shares were worth approximately $8,318,407 ²³²⁴²⁵.

Following sustained direct-action protests beginning December 2025, HSBC reduced its Elbit position to 651 shares by March 2026 ²⁴²⁵. HSBC completed full divestment of the remaining 651 Elbit shares on 30 April 2026 ²⁴²⁵. No public statement by HSBC explaining the April 2026 divestment has been identified ²⁴²⁵.

The 2024 Don’t Buy Into Occupation report (DBIO IV) listed HSBC as providing “financial services” to Elbit Systems, covering the period January 2021 to September 2024 for loans and underwriting and the latest available filing (September 2024) for shares and bonds ²²²¹. Elbit Systems products documented as used by the IDF include Hermes 900 and Hermes 450 aerial drones - reported to account for approximately 85% of IDF drone capacity used to monitor and conduct operations in Gaza and the West Bank - Skylark mini-drones, the Iron Vision smart helmet system for Merkava tank crews, armed Canopy ground robots, and C4ISR and artillery systems ¹¹. Elbit’s subsidiary IMI Systems produced cluster munitions including the M85, M970, M971, and RAM types prior to its 2018 acquisition by Elbit ¹⁹.

BAE Systems PLC

War on Want’s “Deadly Investments” (July 2017) documented HSBC holding approximately £180 million (equivalent to approximately $232 million) in BAE Systems shares ⁵⁷⁸. BAE Systems manufactures target selection display systems for F-16 fighter jets supplied to Israel ⁵⁸. War on Want’s January 2019 update confirmed that HSBC maintained its BAE Systems relationship following the December 2018 Elbit divestment and announced intentions to campaign further on that holding ⁹. Campaign Against Arms Trade action days in August 2020 specifically cited HSBC’s BAE Systems shareholding as a target ¹⁰. No primary 13F filing data confirming HSBC’s BAE Systems position for 2023–2026 was identified in this research session; the figure of approximately £180 million applies to the pre-2020 period ⁵.

Boeing Company

War on Want’s “Deadly Investments” (July 2017) documented HSBC holding approximately £102 million (approximately $131.4 million) in Boeing shares ⁵⁷⁸. Boeing supplies Israel with AH-64 Apache attack helicopters and Hellfire air-to-surface missiles ⁸. The PAX report “Companies Arming Israel and Their Financiers” (June 2024), published by 19 civil society organisations, identified Boeing as one of six major arms producers whose European financiers - including HSBC - are documented ⁶. Ethical Consumer (2024) also lists Boeing among the arms companies that HSBC has recently financed ²¹. No specific 2024–2025 loan amounts or underwriting values for HSBC’s Boeing relationship were confirmed from primary filings during this research session.

Raytheon / RTX Corporation

War on Want’s “Deadly Investments” (July 2017) documented HSBC as a Raytheon shareholder, with Raytheon identified as a producer of “bunker-buster” bombs used in Israel’s 2014 military operations against Gaza ⁵⁸. The PAX report (June 2024) names RTX (formerly Raytheon Technologies) as one of the six arms producers whose European financiers - including HSBC - are documented ⁶. Ethical Consumer (2024) lists RTX Corporation among the arms companies that HSBC has recently financed ²¹.

General Dynamics, Leonardo, Lockheed Martin, Rolls-Royce

Ethical Consumer (2024) states that HSBC has recently financed General Dynamics, Leonardo, Lockheed Martin, and Rolls-Royce in addition to Boeing and RTX ²¹. The PAX “Companies Arming Israel and Their Financiers” report (June 2024) lists the same six companies - Boeing, General Dynamics, Leonardo, Lockheed Martin, RTX, and Rolls-Royce - as arms producers supplying weapons or weapons systems to Israel whose European financiers, including HSBC, are documented ⁶. War on Want (July 2017) documented HSBC’s participation in 15 syndicated loans totalling £19.3 billion ($25 billion) to companies including Rolls-Royce ⁵. No transaction-level data (loan amounts, dates, facility types) for HSBC’s positions in General Dynamics, Leonardo, Lockheed Martin, or Rolls-Royce for the 2023–2026 period was confirmed from primary sources in this research session.

Israeli State-Owned Defence Companies

No public evidence identified of direct HSBC financing relationships with Israel Aerospace Industries (IAI) or Rafael Advanced Defense Systems, both of which remain state-owned enterprises with limited public equity exposure.

Logistical Sustainment & Base Services

No public evidence identified. HSBC does not provide catering, transport, fuel supply, waste management, facilities management, telecommunications, or any other base-support services to military installations.

No public evidence identified of HSBC holding service contracts connected to any military installation, including facilities in the West Bank, Golan Heights, East Jerusalem, or the Negev.

No public evidence identified of HSBC engaging in freight forwarding, port handling, or any logistics services to Israeli military or security bodies.

Munitions, Weapons Systems & Strategic Platforms

No public evidence identified. HSBC does not manufacture small arms, light weapons, armoured vehicles, unmanned aerial systems, naval vessels, or any other lethal platform or weapons system.

No public evidence identified of HSBC supplying ammunition, ordnance, propellants, explosive precursors, or any munitions-related material to any party.

No public evidence identified of HSBC involvement in the manufacture, systems integration, or maintenance of Israeli strategic defence platforms, including Iron Dome, David’s Sling, Arrow ballistic missile defence systems, F-35 or F-16 fighter aircraft, Merkava main battle tanks, or any naval or ballistic missile system.

HSBC’s financial relationship with Elbit Systems - as documented under Supply Chain Integration with Defence Primes - constitutes passive equity investment and financial services provision; it does not constitute sub-system supply or component integration into any weapons platform ²¹²²⁶.

Export Licensing, Regulatory & Legal History

Export Control

No public evidence identified of any government authority granting, denying, suspending, or revoking export licences specifically applicable to HSBC in connection with Israeli military or security end-users. HSBC’s financial services products are not goods or technologies subject to export licensing in the sense administered by authorities such as the UK Export Control Joint Unit or the US Bureau of Industry and Security.

HSBC Defence Equipment Policy

HSBC publicly maintains a Defence Equipment Sector Policy; the current version is the “Defence Equipment Policy Statement” dated 27 June 2024 ²⁷, with a predecessor version dated December 2022 ²⁸. The December 2018 Elbit Systems divestment was executed explicitly under HSBC’s long-standing cluster munitions prohibition within this policy framework, as confirmed by HSBC Chief Legal Officer Stuart Levey in January 2019 ²⁴³. The trigger cited was Elbit’s acquisition of IMI Systems, whose products included cluster munitions such as the M85 and related types ²¹⁹. Ethical Consumer (2024) has assessed that while HSBC “prohibits financing of clients which manufacture, trade, purchase, or sell weapons for military use” under its stated policy, its practices do not match this stated policy given the documented equity holdings in Elbit and the other defence primes identified in this audit ²¹.

Cluster Munitions Policy and Elbit Systems Dispute

Following HSBC’s January 2019 public statements attributing its Elbit divestment to its cluster munitions policy, Elbit Systems issued a public rebuttal stating that it does not produce cluster bombs ²⁰. The Stop Explosive Investments network documented that Elbit Systems had confirmed exiting cluster munitions production, but noted that the IMI Systems acquisition created policy complications for investors applying cluster munitions exclusions ¹⁹. HSBC’s stated position - that the policy test was triggered by IMI Systems’ prior production record, incorporated into Elbit through the acquisition - was not retracted ²³.

Regulatory and Legal Proceedings

No public evidence identified of court proceedings, judicial reviews, or legal challenges brought against HSBC specifically regarding its defence-related investment relationship with Israel. No ICC or ICJ filings naming HSBC were identified during this research session. No government enforcement action under arms embargo or sanctions regulations specifically targeting HSBC in connection with Israeli defence companies has been publicly identified.

HSBC is not listed in the OHCHR database of business enterprises involved in Israeli settlement activity, which comprised 158 businesses as of the September 2025 update ²⁹³⁰³¹. HSBC is also not identified as one of the seven banks that underwrote Israeli government bonds (“war bonds”) totalling $19.4 billion after October 7, 2023; those seven underwriters are Goldman Sachs, Bank of America, Deutsche Bank, BNP Paribas, Citi, Barclays, and JPMorgan Chase ³².

Civil Society Scrutiny & Documented Investigations

Major NGO and Research Reports

War on Want’s “Deadly Investments” report (July 2017) was the foundational public document identifying HSBC’s Israel-related defence exposure, disclosing aggregate holdings of over £831 million ($1.07 billion) in companies providing arms and technology to Israel ⁵⁷⁸. The report itemised BAE Systems shares at approximately £180 million ($232 million), linked to F-16 target selection displays; Boeing shares at approximately £102 million ($131.4 million), linked to AH-64 Apache helicopters and Hellfire missiles; and Caterpillar shares at approximately £99–£99.5 million, linked to IDF-modified D9 bulldozers ⁵⁸. War on Want described HSBC as “a crucial link in the chain of Palestinian oppression” ⁷. The same report documented HSBC as a participant in 15 syndicated loans totalling £19.3 billion ($25 billion) to arms-related companies, including Rolls-Royce ⁵. During 2017–2018, Ethical Consumer reported that HSBC was publicly questioned and challenged on its complicity in human rights abuses linked to its defence-related investment portfolio ³³.

The Don’t Buy Into Occupation III report (DBIO III, 2023), published by FIDH and multiple NGO partners, identified HSBC as the second-largest European creditor - by loan and underwriting volume - to companies involved in Israeli settlements, having provided $14.21 billion in loans and underwriting to businesses linked to Israeli settlements during January 2020 to August 2023 ³⁴. This placed HSBC behind only BNP Paribas ($22.19 billion) and ahead of Deutsche Bank ($13.23 billion), Société Générale ($12.4 billion), and Barclays ($10.63 billion) ³⁴.

The Don’t Buy Into Occupation IV report (DBIO IV, 2024) retained HSBC among the largest European creditors to companies involved in Israeli settlements and additionally listed HSBC as providing financial services to Elbit Systems, covering the period January 2021 to September 2024 for loans and underwriting and the latest available filing (September 2024) for shares and bonds ²²²¹.

The PAX report “Companies Arming Israel and Their Financiers” (June 2024), co-published by 19 civil society organisations, identified HSBC as a European financier of six major arms producers - Boeing, General Dynamics, Leonardo, Lockheed Martin, RTX, and Rolls-Royce - all of which sold weapons or weapons systems to Israel between 2019 and 2023 ⁶. Total documented European financial flows covered by that report amounted to €36.1 billion in loans and underwriting and €26 billion in shares and bonds ⁶.

Ethical Consumer’s ongoing analysis (2024–2025) ranked HSBC as the 13th-largest European investor and the 9th-largest European creditor among financial institutions assessed as complicit in Israeli arms supply, and as the second-largest European creditor to companies linked to Israeli settlements - consistent with the DBIO III ranking ²¹. Ethical Consumer additionally noted that HSBC’s stated prohibition on financing manufacturers of weapons for military use was assessed as inconsistent with HSBC’s documented practices ²¹. The New Arab (2024) reported that UK banks, including HSBC, were being accused of funding Israel’s military campaign in Gaza ³⁵.

HSBC is not named in the UN Special Rapporteur’s report A/HRC/59/23 (“From economy of occupation to economy of genocide,” Albanese, 2 July 2025), based on Al Jazeera’s published summary of companies and financial institutions named in that report; financial institutions named therein include BNP Paribas, Barclays, BlackRock, Vanguard, Allianz, and AXA ³⁶. HSBC is not listed in the OHCHR database of business enterprises involved in Israeli settlement activity, updated September 2025 and covering 158 businesses ²⁹³⁰. HSBC does not appear in the AFSC Investigate company database as checked in June 2026 ³⁷. The OpenSanctions dataset derived from OHCHR settlement database listings also does not include HSBC ³¹.

Boycott and Divestment Campaigns

The BDS Movement celebrated HSBC’s December 2018 Elbit divestment as a “BDS Victory” and later resumed campaigning when HSBC’s re-investment in Elbit became apparent post-2020 ⁸¹⁴. War on Want organised monthly pickets at 40 UK HSBC branches and an email campaign backed by more than 24,000 supporters during 2017–2018 ¹¹¹⁴. Following the 2018 divestment, War on Want announced intentions to “ramp up the pressure on HSBC to end its links with Caterpillar,” BAE Systems, Boeing, and Raytheon ⁹. The Palestine Solidarity Campaign ran a national day of action against HSBC, Twitter storm campaigns targeting HSBC’s AGM, and ongoing lobbying calling on the bank to stop arming Israel ³⁸. The Campaign Against Arms Trade organised a campaign action day against HSBC in August 2020, specifically targeting HSBC’s holdings in BAE Systems, Raytheon, and Caterpillar ¹⁰.

From December 2025 onward, People Against Genocide mounted a direct-action campaign targeting HSBC branches across the United Kingdom ²³. On 13 December 2025, groups took action at over ten HSBC branch locations across England and Scotland, including Catford, Lewisham, Ilford, Tottenham Court Road, Fulham, Birmingham, Wokingham, Brighton, Newcastle, Edinburgh, and Glasgow ²³³⁹. Brighton and Hove News independently confirmed protest activity at Brighton’s HSBC branch on 14 December 2025 ³⁹. By March 2026, HSBC had reduced its Elbit holding to 651 shares, and by 30 April 2026 it had completed full divestment of all remaining Elbit shares ²⁴²⁵. Campaign groups attributed the April 2026 divestment to the sustained direct-action campaign ²⁴²⁵.

Corporate Response and Policy Positions

HSBC confirmed its December 2018 Elbit divestment by email to the Palestine Solidarity Campaign and War on Want, stating that it “strongly supports [the] observance of international human rights principles as they apply to business” ¹⁵¹²¹⁷. In January 2019, Chief Legal Officer Stuart Levey attributed the divestment to HSBC’s cluster munitions policy, denied BDS motivation, and affirmed continued banking services to Israeli companies ²⁴³. Elbit Systems contested the stated rationale, publicly denying that it produces cluster munitions ²⁰; the Stop Explosive Investments network noted that Elbit had confirmed exiting cluster munitions production but acknowledged the complications arising from the IMI acquisition ¹⁹.

HSBC has published successive versions of its Defence Equipment Sector Policy, with the most recent version - the “Defence Equipment Policy Statement” - dated 27 June 2024 ²⁷, and a predecessor version dated December 2022 ²⁸. No HSBC public statement specifically addressing its post-October 2023 Israel-related investment positions was identified during this research session. No public statement explaining the April 2026 Elbit divestment has been identified ²⁴²⁵.

Constructive Notice and Timeline

HSBC held 12,826 shares in Elbit Systems as of the Q2 2024 13F filing (approximately August 2024), a position maintained following the ICJ Advisory Opinion on the illegality of Israel’s occupation issued on 19 July 2024 ²¹²³. Following the ICC issuance of arrest warrants for Israeli Prime Minister Netanyahu and Defence Minister Gallant in November 2024, HSBC actively increased its Elbit position by 27.22%, reaching 16,317 shares valued at approximately $8,318,407 by November 2025 ²³²⁴²⁵. HSBC maintained its Elbit shareholding through multiple shareholder resolutions, NGO campaign calls, and the December 2025 direct-action branch protests, completing full divestment only on 30 April 2026 ²⁴²⁵.

End Notes