Scalable Capital ECONOMIC

Target: Scalable Capital Research date: 25 October 2026 Scope: Commercial, investment, financial, supply-chain and operational relationships concerning Israel and the occupied Palestinian territories.

Supply Chain & Sourcing Relationships

Business model and procurement context

Scalable Capital describes its activities as brokerage, digital wealth management, securities custody, banking and investment-product distribution, with its regulated banking operations based in Germany.¹

Its documented wealth-management activity involves investments in ETFs, exchange-traded commodities and other exchange-traded products across multiple asset classes, rather than procurement of physical agricultural commodities.²

Direct Israeli agricultural suppliers

No public evidence identified of a direct Scalable Capital procurement relationship with Mehadrin, Hadiklaim, Galilee Export, Agrexco successors or another named Israeli agricultural exporter; the company’s disclosed operating model concerns financial services and investment products.³

Importer-of-record arrangements

No public evidence identified of an Israeli-origin agricultural or industrial importer-of-record structure operated by Scalable Capital, including a dedicated import subsidiary or joint venture.¹

Seasonal sourcing

No public evidence identified of recurring seasonal procurement of Israeli dates, avocados, citrus, herbs, potatoes or other fresh-produce categories.²

Third-party distributors and intermediaries

On 2 July 2024, Scalable Capital announced a commercial partnership with Amundi to facilitate customer access to ETF investments; the announcement identified more than 2,500 ETFs available through the platform.⁴

Scalable Capital also identifies the European Investor Exchange, gettex and Xetra as available trading venues; the European Investor Exchange is operated by the Hannover Stock Exchange in cooperation with Scalable Capital.⁵

The company’s disclosed investment-product universe includes equities, funds, bonds, derivatives and crypto-related exchange-traded products, with securities availability determined by the supported trading venues.⁶

No public evidence identified of an Israeli agricultural distributor, private-label supplier or settlement-based reseller supplying physical goods to Scalable Capital.⁴

Commercial relationship distinction

Scalable Capital generally executes brokerage transactions through regulated exchanges, while certain private-market fund transactions involve intermediaries and fund issuers.⁷

The company’s documented securities-order process operates through its application and online client interface.⁸

Product Origin, Labeling & Regulatory Compliance

Settlement-origin products

No public evidence identified of Scalable Capital importing, stocking or selling physical goods originating in Israeli settlements in the West Bank, East Jerusalem or occupied Syrian Golan; its published investment offering comprises financial instruments and banking services.⁶

Country-of-origin labeling

No public evidence identified of a DEFRA, customs or consumer-labeling enforcement action against Scalable Capital concerning agricultural products described as originating in Israel or Israeli settlements.¹

Corporate sourcing and labeling policy

No public evidence identified of a Scalable Capital corporate policy specifically addressing the physical sourcing or country-of-origin labeling of goods from Israeli settlements.²

Securities identification

Scalable Capital’s trading guidance identifies the securities identification number, including WKN or ISIN, as a means of searching for an investment product on its platform.⁶

Scalable Capital’s December 2024 announcement identifies its Scalable MSCI AC World Xtrackers UCITS ETF as a Luxembourg-domiciled financial product with ISIN LU2903252349, managed by DWS Investment S.A.⁹

Financial-product domicile and underlying portfolio exposure are separate characteristics of an investment instrument; the documented Luxembourg fund structure does not establish the domicile of every underlying investment.⁹

Investment-product sustainability standards

Scalable Capital’s World Portfolio ESG strategy uses ETFs selected according to environmental, social and governance criteria, including socially responsible investment filters.¹⁰

Its published ESG selection approach employs third-party investment products and a comparative selection process based on sustainability standards.¹¹

No public evidence identified in these reviewed policies of a specific exclusion applying universally to every Israeli-domiciled issuer or to every company with settlement-related activities.¹⁰

Regulatory geography

Scalable Capital Bank GmbH is identified as a German credit institution supervised by BaFin and Deutsche Bundesbank.¹²

No public evidence identified of an Israeli product-labeling regulator exercising jurisdiction over Scalable Capital’s disclosed financial-services activities.¹²

Investment, Capital & Financial Exposure

Foreign direct investment

No public evidence identified of Scalable Capital itself acquiring an Israeli operating company or directly investing in an Israeli factory, data centre, logistics facility, commercial property or other identifiable operating asset.¹³

The company’s disclosed expansion activity focuses on its European investment platform, banking capabilities and financial products.¹⁴

Research and development

Scalable Capital announced in December 2024 that it had developed a vertically integrated investment platform and expanded its securities-account infrastructure.¹⁵

No public evidence identified of a Scalable Capital-owned research laboratory, innovation centre, development office or accelerator physically situated in Israel or the occupied Palestinian territories.¹⁵

Shareholders and capital injections

Scalable Capital’s corporate information identifies BlackRock among its institutional investors, alongside other investment firms.¹³

On 3 June 2025, Scalable Capital announced a €155 million financing round led by Sofina and Noteus Partners, with participation from existing investors Balderton Capital, Tencent and HV Capital.¹⁶

The 2025 announcement stated that investors had committed more than €470 million to Scalable Capital over its financing history.¹⁶

HV Capital identifies itself as Scalable Capital’s first institutional investor, dating its initial investment to 2015.¹⁷

Scalable Capital’s June 2021 financing announcement identified BlackRock, Tencent, HV Capital and Tengelmann Ventures among the company’s shareholders at that time.¹⁸

No independently verified current percentage ownership, voting-control schedule or beneficial-ownership breakdown establishing control by Israeli capital was identified in the reviewed disclosures.¹⁶

Scalable Capital’s World ETF

On 20 December 2024, Scalable Capital announced the launch of the Scalable MSCI AC World Xtrackers UCITS ETF, with DWS as management company and Scalable Capital GmbH as portfolio construction adviser.⁹

The product tracks the MSCI All Country World Index, representing large- and mid-cap equities across 23 developed and 24 emerging markets.⁹

The company’s advisory role and DWS’s fund-management role are identified separately in the launch documentation.⁹

No public evidence identified in the reviewed launch documentation of a quantified allocation to Israeli-domiciled companies, settlement-active issuers, Israeli defence manufacturers or Israeli government bonds.⁹

Managed wealth portfolios

Scalable Capital states that its wealth-management service implements investment strategies using ETFs, ETCs and other ETPs, covering a globally diversified investment universe.²

Its World Portfolio ESG documentation names ETFs associated with issuers including iShares, Amundi, HSBC, Vanguard, Xtrackers and VanEck.¹⁰

Its climate-oriented investment strategy similarly lists funds managed by third-party asset managers, including Amundi, iShares, Invesco and Legal & General.¹⁹

No public evidence identified of a dated, issuer-level Scalable Capital proprietary portfolio demonstrating direct corporate ownership of Israeli sovereign debt, Israeli defence manufacturers or OHCHR-listed settlement companies.²

BlackRock private-equity relationship

Scalable Capital provides qualifying investors with access to the BlackRock Private Equity Fund, an investment product launched in February 2025.²⁰

According to Scalable Capital’s description, the fund pursues private-equity co-investments and may acquire controlling interests in underlying private companies alongside other investment managers.²¹

Scalable Capital describes the BlackRock fund as a third-party private-market investment product offered through its brokerage platform.²²

Its distribution documentation identifies eligibility for residents of Germany, Austria and Italy, subject to product suitability requirements and an initial investment of at least €10,000.²³

No public evidence identified in the reviewed fund descriptions of a specifically named Israeli portfolio company or a direct controlling investment in such a company by Scalable Capital itself.²¹

Acquired Israeli subsidiaries

No public evidence identified of an Israeli operating company acquired by Scalable Capital or held by it through a controlling ownership interest.¹³

Consequently, no verified Israeli acquisition date, purchase price, ownership percentage, manufacturing location, employee scale or defence-related operating relationship was established.¹³

Financing the Israeli state

Scalable Capital’s platform supports trading in fixed-income securities and offers bonds to qualifying customers in Germany and Austria.⁶

The publicly described product range does not, by itself, establish that Scalable Capital underwrites Israeli sovereign-bond issuances or acts as a distributor of Development Corporation for Israel securities.⁶

No public evidence identified of Scalable Capital serving as a lead manager, bookrunner or underwriting syndicate member for a named Israeli government-bond issuance.⁶

No public evidence identified of a Scalable Capital-branded Israel Bonds sales programme or a verified direct proprietary purchase of Israeli sovereign debt.⁶

Direct lending and trade finance

Scalable Capital received authorization to conduct lending and deposit-taking business in September 2025.¹

No public evidence identified of a named lending or trade-finance facility extended by Scalable Capital to an Israeli defence contractor, settlement-active company or Israeli government entity.¹

Insurance underwriting

The company’s announced banking and investment-product activities include custody, trading, deposits and lending.¹

No public evidence identified of Scalable Capital underwriting insurance for Israeli military, settlement or state operations.¹

Group attribution and controlling principals

The founders identified in Scalable Capital’s corporate profile are Erik Podzuweit, Florian Prucker, Adam French and Professor Stefan Mittnik.¹³

No public evidence identified of a named personal investment, family-office acquisition or controlling Israeli business interest held by those founders that can be substantiated and attributed to Scalable Capital under the requested corporate-attribution framework.¹³

The documented institutional shareholders operate independently identifiable investment businesses; the available Scalable Capital disclosures do not establish that their separate portfolios constitute assets owned or controlled by Scalable Capital.¹⁶

Continuity after July and November 2024

Scalable Capital’s December 2024 DWS/MSCI ETF launch, February 2025 BlackRock private-equity offering and June 2025 funding announcement establish continuing international financial-services activity after both dates.^{9, 20, 16}

No public evidence identified of a specifically verified Israeli sovereign-financing, settlement-investment or Israeli defence-financing transaction by Scalable Capital continuing after 19 July 2024 or November 2024.¹⁶

As of October 2026, justETF’s Elbit Systems Ltd. stock profile (ISIN IL0010811243; WKN 904218) explicitly listed Scalable Capital among brokers offering a securities savings plan for shares in the Israeli defence manufacturer. Under “Savings plan offers”, the comparison displayed Scalable Capital with a €0.00 execution fee and €0.00 account fee for a selected monthly savings amount of €100. The table was attributed to “justETF Research; as of 10/2026”. This constitutes dated, security-specific public evidence that Scalable Capital was advertised as facilitating recurring retail investment in Elbit Systems shares, rather than merely providing exposure through an ETF containing the company. The listing represents justETF’s published broker comparison; an independently completed savings-plan order was not verified.²⁴

Scalable Capital’s own published product information supports the mechanism described by justETF. Its official brokerage FAQ confirms that savings plans can be established for individual company shares, that many stocks available through Scalable Broker qualify, and that eligibility is not restricted by company size or headquarters location. Its PRIME+ Broker product page confirms €0 execution fees for savings plans across all brokerage pricing models, while identifying potential additional product costs, spreads and other charges. Accordingly, justETF’s advertised €0 execution fee for Elbit Systems is consistent with Scalable Capital’s disclosed savings-plan pricing. The fee relates to recurring securities purchases and does not represent a waiver of every possible transaction cost.^{25, 26}

Scalable Capital identifies the European Investor Exchange (operated by the Hannover Stock Exchange in cooperation with Scalable Capital), gettex (Munich Stock Exchange) and Xetra (Deutsche Börse) as its supported standard trading venues. Its brokerage documentation states that eligible shares traded on those venues can generally be purchased through its platform, subject to instrument-specific availability. The documented offering therefore concerns European securities brokerage and recurring investment in an Israeli issuer’s publicly traded equity; it does not establish direct execution on the Tel Aviv Stock Exchange or an Israeli brokerage operation. Neither justETF’s Elbit Systems comparison nor Scalable Capital’s reviewed public product guidance identifies the particular execution venue used for an Elbit Systems savings plan.^{24, 5, 6}

October 2026 - no public evidence identified of an Elbit Systems-specific savings-plan confirmation issued directly by Scalable Capital, a completed customer execution receipt, the precise trading venue assigned to ISIN IL0010811243, or the amount invested by Scalable Capital customers through such plans. Scalable Capital directs customers to its authenticated brokerage interface to verify the availability of individual securities by ISIN and notes that some exchange-listed instruments may be unavailable to retail clients. The available evidence establishes a specific third-party listing consistent with the broker’s published offering, but does not independently verify successful account-level activation or execution of the named savings plan.^{24, 25, 6, 27}

BlackRock has documented direct business operations in Israel independently of its Scalable Capital investment. Its official Israeli corporate profile states that it has operated in Israel since 2016, identifies Anath Levin as Country Head Israel, and describes investment services for Israeli institutional and individual clients. BlackRock also identifies its global investment platform as undertaking investment activity in Israel. These are attributable operating activities of Scalable Capital’s documented institutional investor, rather than investments or Israeli operations owned directly by Scalable Capital.²⁸

BlackRock’s acquisition of Kreos Capital provides a separately identifiable owner-level economic relationship. BlackRock completed the acquisition on 2 August 2023, with the acquired team joining its European Private Debt platform. BlackRock’s acquisition announcement describes Kreos as an established lender to technology and healthcare businesses across Europe and Israel, reporting more than €5.2 billion committed through over 750 transactions across 19 countries before acquisition. BlackRock’s 2023 annual filing placed total acquisition consideration at approximately $250 million, including contingent consideration. That purchase price concerns the acquisition of the lending business, while the €5.2 billion represents historical commitments across multiple countries and cannot be attributed entirely to Israel.^{29, 30, 31}

The acquired lending operation retains an identifiable Israeli economic footprint. BlackRock’s Kreos Capital website describes continued growth-debt financing across Europe and Israel, a local presence in Israel, and financing across technology and healthcare sectors. The website identifies more than 830 completed deals and over $7 billion committed, with the figures dated to the third quarter of 2025. These aggregate figures establish the scale of the acquired business but do not isolate Israeli commitments. The presence of an ongoing Israel-focused lending capability and the acquisition’s completed integration provide stronger evidence of deliberate owner-group economic activity than incidental exposure through a diversified index fund.³²

The historical Israeli lending component is independently corroborated by June 2023 reporting identifying Kreos as a provider of credit to more than 100 Israeli companies. Contemporary reporting also identified Israeli technology and healthcare borrowers including SolarEdge, Riskified, LiveU, Zerto and BioCatch, and described approximately one-quarter of Kreos’s historical financed companies as Israeli. This proportion concerns the reported number of financed companies, not a verified share of operations, revenue, assets or outstanding loans in October 2026. BlackRock’s acquisition announcement expressly described the transaction as an agreement to acquire full control of the lending manager. Loans originated before the acquisition also require distinction from financing newly originated under BlackRock ownership.^{33, 30}

A separate active capital-allocation relationship was documented on 12 February 2024 by Israeli law firm Arnon, Tadmor-Levy. The firm stated that it represented a group of investment funds led by BlackRock in a $280 million debt-financing transaction involving Pagaya. This identifies a specific, deliberately arranged credit transaction involving BlackRock-led funds and an Israeli-founded financial-technology business. The $280 million is the reported aggregate facility, not BlackRock’s individually disclosed contribution or a proprietary balance-sheet investment. The transaction is materially different from automatically holding Israeli equities through a passive index fund.³⁴

In January 2026, BlackRock reportedly led a $25 million combined debt-and-equity funding arrangement involving Atlas Invest, a Manhattan-based commercial-real-estate lending technology business founded by Israeli entrepreneurs. Reporting identifies BlackRock’s active leadership role and the financing purpose. However, Atlas Invest’s reported Manhattan location means the founders’ Israeli origins alone cannot establish that the transaction constituted investment in an Israeli-domiciled business or an Israeli operating asset. Its classification as Israeli economic exposure therefore remains conditional on additional evidence of Israeli operations, beneficiaries or capital deployment.³⁵

An August 2026 report stated that BlackRock had increased its holding in Israeli semiconductor-equipment manufacturer Nova, acquiring approximately 560,000 shares since an earlier disclosure at an estimated aggregate market value exceeding NIS 800 million, approximately $262 million. The report attributed the information to Nova’s shareholder disclosures and identified 29 July 2026 as the date of BlackRock’s ownership notification. The report establishes a substantial disclosed increase in securities exposure, but does not resolve whether the shares were acquired by passive index portfolios, actively managed client funds, discretionary mandates or BlackRock’s proprietary account. The estimated transaction value must not be classified as proprietary investment without identifying the beneficial owners and investment mandates.³⁶

BlackRock’s own Israeli product disclosures explain that it manages funds on behalf of investors, receives management fees from relevant investments and has a commercial interest in distributing associated products. Accordingly, Israeli issuer holdings reported under BlackRock’s name require classification by investment mandate. Passive index exposure reflects index construction and investor-directed fund participation; actively selected credit facilities or private-market investments involve distinct allocation decisions; proprietary acquisitions expose BlackRock’s own corporate capital. These categories can coexist within BlackRock’s business without making the underlying client assets Scalable Capital’s property.^{37, 28, 34}

The BlackRock/Kreos relationship provides a substantial owner-level comparison with Scalable Capital’s October 2026 Elbit Systems savings-plan advertisement. The Kreos acquisition was completed in August 2023, approximately eleven months before 19 July 2024 and more than three years before October 2026. BlackRock’s subsequent Kreos website documents continuing business integration and Israel-focused growth-debt capability, including an operating history extending into 2025. The complete economic scenario therefore includes a completed acquisition, integration of a specialist lending team and a continuing financing business, whereas the Elbit advertisement establishes a specific advertised retail-brokerage facility without verified customer execution volumes. The activities differ in agency, operational involvement, scale evidence and duration. Their ultimate I/M/P/V treatment depends on the framework’s applicable definitions and attribution rules, rather than the larger transaction figures alone.^{29, 32, 33}

The February 2024 BlackRock-led $280 million Pagaya financing provides a second dated comparison. Unlike a general retail investment advertisement, it identifies a particular financing transaction, borrower and arranger-led investment-fund group. Its reported amount is a facility-wide figure, and the reviewed evidence does not establish drawdowns, maturity, outstanding principal in October 2026 or whether BlackRock-led funds subsequently exited. Consequently, the transaction supports a documented historical active-financing scenario, while continuing financial exposure and the exact present economic benefit remain unverified.³⁴

The August 2026 reported increase in BlackRock’s Nova shareholding provides a third comparison, occurring after both the July 2024 and November 2024 reference dates and shortly before the October 2026 advertisement. The reported approximately $262 million increase is substantially larger than any quantified Scalable Capital customer investment identified in the existing Elbit advertisement evidence. Nevertheless, the available reporting does not establish whether BlackRock deliberately selected the issuer through active management or accumulated shares through passive client mandates. Its classification requires evidence of the holding entities, portfolio mandates, beneficial ownership and subsequent changes. Transaction scale alone does not resolve investment intent or attribution.³⁶

October 2026 - no public evidence identified: BlackRock’s current Kreos product disclosures, acquisition-completion announcement, 2024 Pagaya transaction disclosure and August 2026 Nova reporting did not establish verified cessation of BlackRock’s Israel-focused lending operations, comprehensive repayment or disposal of the Pagaya-related financing, or complete liquidation of the reported Nova position. Nor did they quantify the proportion of Kreos’s aggregate historical commitments still outstanding to Israeli borrowers. These unresolved facts limit a definitive current-exposure assessment, but do not negate the separately documented historical transactions or the continuing Israel-facing operating capability.^{29, 32, 34, 36}

BioLineRx’s September 2022 secured financing agreement with Kreos Capital VII Aggregator SCSP provided up to $40 million in three tranches: $10 million initially, $20 million subject to milestones by April 2024, and a further $10 million subject to milestones by October 2024. BioLineRx drew the first $10 million in September 2022, before BlackRock acquired Kreos, and subsequently drew $20 million in April 2024, approximately eight months after the acquisition. Its 2025 annual financial statements expressly identify the lender as BlackRock EMEA Venture and Growth Lending, formerly Kreos Capital VII Aggregator SCSP. The final $10 million tranche was never drawn and expired. Consequently, BioLineRx’s own filings establish an additional $20 million disbursement under the inherited lending facility during BlackRock’s ownership, bringing cumulative principal advanced to $30 million. This is direct evidence of post-acquisition financing activity involving an Israeli pharmaceutical company, although the underlying contractual commitment originated before BlackRock’s acquisition.^{38, 39}

The original BioLineRx financing carried fixed annual interest of 9.5%, approximately 11% including associated cash fees, and granted the lender first-priority security over company assets, including intellectual property. The agreement also required a $10 million minimum cash balance and entitled Kreos to revenue-based payments linked to US motixafortide sales, subject to a contractual cap. In November 2024, BioLineRx and the lender amended these arrangements in connection with BioLineRx’s licensing transaction with Ayrmid. BioLineRx made a $16.5 million payment covering partial loan repayment and cancellation of future revenue-based payments. Remaining principal and interest became repayable over three years beginning 1 December 2024 and ending 1 December 2027. The minimum cash requirement fell to $4 million, while 10% of qualifying future licensing milestone receipts became subject to additional principal repayments through December 2027. BioLineRx accounted for the amendment as a substantial debt modification under IFRS 9. These terms document an active restructuring of the acquired lender’s Israeli credit exposure after August 2023.³⁹

BioLineRx’s financial statements for the year ended 31 December 2025 reported a remaining long-term-loan carrying balance of approximately $8.939 million, following approximately $5.568 million of principal and interest payments during 2025. The corresponding carrying balance at 31 December 2024 was approximately $13.437 million. The 2025 year-end amount is an accounting carrying value and should not automatically be equated with outstanding contractual principal. The disclosed repayment schedule continues through December 2027, subject to milestone-related adjustments, and the filing identifies repayment or refinancing risk. Accordingly, the primary filings establish that the BlackRock/Kreos financing relationship remained economically active at 31 December 2025, although they do not establish its precise outstanding balance on 25 October 2026.³⁹

PolyPid’s April 2022 secured financing agreement with Kreos Capital VI (Expert Fund) LP provided a maximum $15 million credit facility comprising tranches of $10 million, $2.5 million and $2.5 million. PolyPid drew $10 million on 26 April 2022 and another $2.5 million on 19 July 2022. Its subsequent annual disclosures explicitly state that the final $2.5 million tranche would never be drawn because the relevant milestone was not achieved. Total documented disbursements were therefore $12.5 million, both occurring before BlackRock’s August 2023 acquisition of Kreos. The initial interest rate was 9.25%, with security over equipment, intellectual property and subsidiary shareholdings. A March 2023 amendment deferred substantial repayments, increased interest to 10% and introduced revised financial consideration and warrant terms.^{40, 41}

PolyPid’s SEC-filed contractual documentation confirms a further amendment dated 1 August 2024 between PolyPid Ltd. and Kreos Capital VI (Expert Fund) LP, establishing a specific continuation and restructuring of the Israeli borrower’s existing financing arrangement after BlackRock’s acquisition of the lending manager. The amendment deferred 60% of remaining principal and interest repayments, with monthly repayment arrangements commencing in April 2025, increased the secured loan’s interest rate to 12%, and imposed a $125,000 restructuring fee. Kreos also received a new warrant covering 40,000 ordinary shares at an exercise price of $3.61 per share, alongside existing warrants that had previously been repriced. The contractual exhibit additionally amended intellectual-property security arrangements. These provisions demonstrate continuing lender rights and a negotiated post-acquisition amendment, without establishing a new advance of principal.^{42, 43}

A third PolyPid amendment, executed on 6 January 2025, deferred 60% of principal and interest payments originally scheduled through June 2025 until July 2025. The company disclosed a further $160,000 restructuring fee and an increase in the end-of-loan payment from 5% to 7%. Its February 2026 annual filing reported that the potential contractual claw-back payment was capped at $4.5 million, of which $4 million had been paid by 31 December 2025. It also reported approximately $0.7 million of outstanding principal as of 19 February 2026. These disclosures establish additional contractual payments and lender compensation after BlackRock’s acquisition but do not identify any additional lending disbursement beyond the original $12.5 million.⁴¹

PolyPid’s subsequently filed interim financial statements for the six months ended 30 June 2026 expressly state that the outstanding Kreos loan balance was fully repaid on 4 May 2026. This establishes a documented termination of the outstanding loan balance before October 2026 and materially limits any claim of continuing PolyPid principal-debt exposure through that date. The repayment disclosure does not independently establish whether every previously issued Kreos warrant had expired, been exercised or otherwise ceased to exist; the 2025 annual report had identified warrants with contractual terms of seven years from their respective issuance dates.^{41, 44}

October 2026 - no public evidence identified: PolyPid’s reviewed 2022–2026 annual reports, August 2024 contractual amendment and June 2026 interim accounts disclosed no additional drawdown under the original Kreos facility after BlackRock’s August 2023 acquisition. The third tranche was expressly cancelled or unavailable, and the subsequent amendments concerned repayment deferrals, interest, fees, claw-back rights, warrants and security arrangements. No replacement Kreos loan or subsequent disbursement to PolyPid was identified in these reviewed records. This finding does not negate the documented post-acquisition amendments or historical lending exposure, but it distinguishes continuing administration and restructuring from fresh principal advanced under BlackRock ownership.^{40, 41, 42, 44}

BlackRock’s 2025 Form 10-K, filed on 25 February 2026, explicitly identifies Scalable Capital among its minority investments in financial technology, digital distribution and related businesses. This is a more recent direct shareholder disclosure than the previously documented 2017 investment and establishes that BlackRock continued to represent Scalable Capital as a minority investment in its latest reviewed annual filing. BlackRock describes such investments as supporting its broader financial-technology capabilities and identifies their financial-accounting treatment collectively, including equity-method income for certain holdings and valuation gains or losses for others. The filing does not identify which individual accounting treatment applies to Scalable Capital, its number of shares, exact ownership percentage or associated voting rights.⁴⁵

BlackRock’s June 2025 investor presentation additionally identified Scalable Capital as a commercial distribution partner through which wealth investors could access a private-markets ELTIF offering. This establishes that BlackRock regarded the relationship as providing a distribution channel alongside its minority-investment strategy. Scalable Capital’s June 2025 fundraising announcement identified Sofina and Noteus Partners as leaders of the €155 million financing round and Balderton Capital, Tencent and HV Capital as participating existing investors. BlackRock was not identified as a participant in that round. The omission cannot establish a disposal of BlackRock’s existing shares, particularly given BlackRock’s subsequent express identification of Scalable Capital as a minority investment in its 2025 annual filing.^{46, 16, 45}

Third-party ownership estimates provide indicative information but do not establish a verified current shareholder register. No public evidence identified from an independently verifiable capitalization table supporting a precise current BlackRock equity or voting percentage in Scalable Capital. The previously cited approximate 29% estimate could not be independently substantiated using an accessible primary filing and is therefore excluded from the ownership assessment. BlackRock’s own 2025 filing supports the narrower conclusion that it retained a minority investment, while the reviewed official disclosures do not independently quantify the stake.^{47, 45}

October 2026 - no public evidence identified: BlackRock’s 2025 annual filing, Scalable Capital’s June 2025 financing announcement and the public UK Companies House filing-history index did not provide an authenticated consolidated German-group capitalization table establishing BlackRock’s precise beneficial ownership percentage, share count, voting rights, dilution from the 2025 financing round or current supervisory-board representation. The UK filing-history index concerns Scalable Capital Limited and cannot, without additional ownership documentation, determine the capital structure of the wider German Scalable Capital group. The defensible current finding is an officially acknowledged minority investment with an independently unverified percentage.^{45, 16, 47, 48}

Operational Presence & Market Activity

Physical footprint

Scalable Capital’s 2025 corporate facts and communications identify operations principally in European markets, including Germany, Austria, Italy, France, Spain and the Netherlands.⁴⁹

An October 2026 announcement reported a new Austrian banking branch offering local account services, including an Austrian IBAN and automated tax processing.⁵⁰

The same announcement identified more than 800 employees across Munich, Berlin, Vienna and Milan.⁵⁰

No public evidence identified of a Scalable Capital office, branch, customer-support centre, warehouse, retail location or other physical establishment in Israel or occupied Palestinian territories.⁵⁰

Employment and scale

Scalable Capital reported more than one million clients and more than €60 billion in assets on its platform in October 2026.⁵⁰

Its published 2026 operating profile describes a European workforce and European investment and banking market presence.⁵⁰

No public evidence identified of a separately disclosed Israeli employee population, Israeli payroll registration or Israeli corporate tax account.⁵⁰

Trading geography

The company’s supported securities-trading venues are the European Investor Exchange, gettex and Xetra.⁵

The documented exchange infrastructure operates through German trading venues and European market institutions.⁵

No public evidence identified of Scalable Capital directly operating a trading venue, brokerage branch or exchange-membership infrastructure in Israel.⁵

Market positioning

Scalable Capital’s 2025 financing announcement describes its strategic objective as expansion of its European investment platform.¹⁶

The company’s October 2026 Austrian launch identifies continued expansion of European banking services.⁵⁰

No public evidence identified of a corporate statement defining Israel as a strategic growth market, regional headquarters, major revenue territory or principal operating market.¹⁶

Settlement-specific services

No public evidence identified of a named Israeli settlement, settlement-based business or settlement municipal authority receiving a directly documented Scalable Capital financial service, loan or commercial contract.⁵⁰

No public evidence identified of a Scalable Capital franchisee, licensee or subsidiary conducting documented settlement-based banking operations.⁵⁰

Other operational relationships

Scalable Capital’s historical corporate disclosure identifies financial-services relationships with ING, Barclays, Santander’s Openbank, Oskar and Targobank.¹⁸

No specific Israeli military, defence procurement, settlement infrastructure or Israeli state contract was established from the disclosed partner relationships.¹⁸

Military leave, charitable matching and platform policies

No public evidence identified of an Israeli reservist salary-subsidy programme, military-leave arrangement, FIDF donation-matching programme or settlement-organization charitable contribution operated by Scalable Capital.⁵⁰

No public evidence identified of a company-specific Palestinian-content moderation intervention, cartographic settlement-labeling decision or mobile-device deployment contract with the IDF or Israeli Ministry of Defence.⁵¹

Corporate Structure & Foundational Ties

Founding history

Scalable Capital was founded in Munich in 2014 by Erik Podzuweit, Florian Prucker, Adam French and Professor Stefan Mittnik.¹³

Its corporate history describes a European financial-technology enterprise developed around digital investment management and securities brokerage.¹⁷

The documented founding location is Germany.¹³

Legal domicile and headquarters

Scalable Capital Bank GmbH identifies its registered business address as Seitzstraße 8e, 80538 Munich, Germany.¹²

Scalable Capital’s official corporate information identifies Munich as its headquarters and describes offices in European cities.¹³

No public evidence identified of original incorporation, a current headquarters, a legacy headquarters or a principal place of management in Israel.¹³

Israeli-Nexus Floor: foundational and control factors

Founded in Israel: no public evidence identified; Scalable Capital’s documented foundation was in Munich in 2014.¹³

Headquarters or principal management in Israel: no public evidence identified; the documented banking and corporate headquarters are in Munich.¹²

Israeli corporate tax residence or Preferred Technology Enterprise status: no public evidence identified; Scalable Capital describes German banking authorization and German supervisory oversight.¹

Beneficial ownership or corporate control by Israeli capital: no public evidence identified; the disclosed investor group includes BlackRock, Tencent, HV Capital, Balderton Capital, Sofina and Noteus Partners, without a verified Israeli controlling shareholder.¹⁶

Legal entities and regulatory permissions

Scalable Capital’s historical financing announcement identifies Scalable Capital GmbH as a German-regulated financial-services institution and Scalable Capital Limited as a UK-regulated entity in 2021.¹⁸

In September 2025, Scalable Capital announced that its banking entity had received ECB authorization to accept deposits and provide lending services.¹

The bank is supervised by BaFin and Deutsche Bundesbank.¹²

Ownership and institutional influence

Scalable Capital’s investor information and primary financing announcements confirm institutional equity investment from international financial and venture-capital investors.^{13, 16}

HV Capital’s portfolio disclosure independently confirms its historic investment relationship and identifies Munich as Scalable Capital’s headquarters.¹⁷

No public evidence identified of an Israeli government equity stake, Israeli state-appointed director or Israeli state shareholder veto right over Scalable Capital.¹⁷

Governance and controlling principals

Scalable Capital identifies Erik Podzuweit and Florian Prucker as its founding Co-CEOs.¹³

The company’s investor and financing disclosures do not provide verified evidence of a golden share, charter restriction, special voting mechanism or governance covenant structurally tying Scalable Capital to Israeli government objectives.¹⁶

No public evidence identified of a verified Israeli military, intelligence or defence-industry governing position held by the named founders or executives in connection with Scalable Capital.¹³

Acquired identity and subsidiaries

No public evidence identified of a controlling Scalable Capital acquisition of an Israeli manufacturer, bank, financial-technology business, cyber company, infrastructure company or consumer brand.¹³

No public evidence identified of a wholly owned Israeli operating subsidiary or a controlling Israeli joint venture within the disclosed group structure.¹²

State and institutional linkages

The company received banking authorization through the European banking supervisory framework in September 2025.¹

No public evidence identified of an Israeli government ownership stake, ministry-appointed executive, Israeli government procurement award or Israeli critical-national-infrastructure designation.¹

BlackRock’s investment in Scalable Capital involved documented governance influence beyond a passive financial holding. In June 2017, BlackRock led a €30 million financing round alongside HV Holtzbrinck Ventures and Tengelmann Ventures. Patrick Olson, then BlackRock’s EMEA Chief Operating Officer, was appointed to Scalable Capital’s supervisory board. Contemporary reporting described BlackRock as a significant minority investor, while German Startups Group identified it as Scalable Capital’s prospective largest minority shareholder. This establishes historical strategic ownership and board-level influence, although it does not establish majority control or BlackRock’s present voting percentage.^{52, 53, 54}

BlackRock’s relationship with Scalable Capital also included commercial integration. In October 2017, Scalable Capital agreed to offer BlackRock’s UK employees access to its investment-management service, with Olson identified as a member of Scalable Capital’s supervisory board. BlackRock’s 2017 annual report subsequently included Scalable Capital among its digital-wealth partners. These disclosures establish a historical combination of equity investment, governance representation and commercial cooperation. They do not independently establish whether Olson retained his board position or whether the employee arrangement continued through October 2026.^{55, 56}

The June 2025 financing announcement confirms continuing participation by Balderton Capital, Tencent and HV Capital in the €155 million round led by Sofina and Noteus Partners, but does not identify BlackRock as a participant in that particular round. BlackRock’s documented historical shareholder relationship remains relevant to the ownership-chain inquiry under Principles 1 and 4; omission from a subsequent financing announcement is insufficient evidence of divestment. Conversely, historical supervisory-board representation cannot establish uninterrupted governance influence without a current board register, shareholder agreement or equivalent disclosure.^{16, 52}

Profit Repatriation & Economic Contribution

Revenue attribution

Scalable Capital’s October 2026 announcement reported a European investment and banking business with more than one million customers and over €60 billion on its platform.⁵⁰

Its commercial announcements disclose funding amounts, investment-platform assets and customer scale, but do not establish a separately quantified Israel revenue segment.^{16, 50}

No public evidence identified of a reported annual revenue figure specifically attributable to Israeli customers, Israeli investments or operations in Israeli settlements.⁵⁰

Profit flows

Scalable Capital’s documented legal and operating headquarters are in Germany, while its disclosed services include European investment brokerage, financial products and banking.^{12, 50}

No public evidence identified of a verified recurring profit-repatriation arrangement directing Scalable Capital corporate profits into Israel through an Israeli-domiciled parent or controlling shareholder.¹⁶

No public evidence identified of a separately reported stream of profits generated by a Scalable Capital Israeli subsidiary and remitted to a foreign parent.¹²

Customer assets and investment flows

Scalable Capital’s wealth-management documentation identifies the use of externally managed ETFs and other financial products, with portfolio allocations across international asset classes.²

Its broker documentation confirms that eligible customers can buy and sell securities through supported trading venues.⁶

Such transactions can involve different issuers and jurisdictions depending on the instrument selected, but the published general service descriptions do not quantify Israel-specific trading or investment flows.⁶

Investment-product revenue and fund relationships

Scalable Capital’s BlackRock Private Equity Fund offering allows qualifying customers to subscribe through the platform, while fund subscriptions and redemptions are governed by the issuer’s timetable and restrictions.²²

The fund documentation describes a monthly subscription process and a redemption restriction continuing until 30 June 2027.²²

No public evidence identified of a quantified Israeli portfolio-company profit distribution received by Scalable Capital from that particular fund.²¹

Banking and deposit infrastructure

Scalable Capital’s customer documentation identifies Deutsche Bank AG as a deposit-related banking counterparty in its payment infrastructure.⁵¹

The company also offers customer cash allocations involving regulated banking and investment structures.¹²

No public evidence identified of a corresponding Israeli bank deposit allocation, Israeli correspondent-banking revenue stream or Israeli sovereign-bank financing programme directly attributable to Scalable Capital.⁵¹

Economic ecosystem significance

Scalable Capital describes itself as a European investment and banking platform, with operations and growth concentrated in European financial markets.⁵⁰

No public evidence identified of an Israeli government, central bank or industry body designating Scalable Capital as a strategic Israeli financial-services provider, major Israeli employer or critical infrastructure operator.⁵⁰

Israeli economic contribution through investments

Scalable Capital’s December 2024 ETF partnership with DWS and MSCI establishes a role in advising on a globally diversified investment product.⁹

The product’s global investment mandate does not provide a verified, dated amount invested in particular Israeli issuers or settlement-related businesses.⁹

No public evidence identified of a quantified direct tax contribution, Israeli government-bond underwriting fee, Israeli military financing receipt or settlement-related commercial revenue attributable to Scalable Capital.⁹

Scalable Capital’s historical capital relationship with BlackRock is directly documented through the 2017 minority equity investment, while its 2025 announcement establishes additional financing from other institutional shareholders. Equity ownership creates a potential economic entitlement to distributions, proceeds from a future share disposal and appreciation in shareholder value, subject to the relevant share rights. The public evidence reviewed does not establish the amount of any dividend actually paid by Scalable Capital to BlackRock, the existence of a shareholder-level profit-sharing agreement, or a direct transfer of Scalable Capital earnings to BlackRock’s Israeli lending or investment activities. The documented relationship therefore supports an indirect shareholder economic-benefit pathway without establishing a quantified onward transfer to Israel.^{52, 16, 54}

BlackRock’s Israeli operations and its acquisition of the Israel-active Kreos lending business establish economic activities capable of generating investment-management fees, interest income and other investment returns within the BlackRock group or funds it manages. BlackRock’s Israeli website expressly identifies management fees as a financial benefit from relevant fund investments, while its Kreos disclosures establish the continuing provision of growth-debt finance. These sources do not establish that income from Scalable Capital financed a particular Israeli loan or that Scalable Capital received profits from Kreos. Any attribution through the shareholder relationship must distinguish potential owner-level financial benefit from a verified transaction-specific transfer.^{37, 29, 32}

October 2026 - no public evidence identified: the reviewed Scalable Capital financing announcements, BlackRock’s historical investment disclosures and the public UK corporate filing history did not establish a Scalable-to-BlackRock dividend payment, a current BlackRock beneficial-ownership percentage, the amount of any shareholder distribution attributable to Israeli operations, or an earmarked reinvestment of Scalable Capital profits in Israel. The UK filing history contains accounts and corporate-capital documents, but the listing alone does not establish the consolidated German group’s distribution history. The absence of a disclosed amount is therefore an evidentiary limitation, rather than proof that no payment occurred.^{16, 56, 48}