Starling Bank POLITICAL

Corporate Communications & Public Stance

• Starling’s ethics statement says the bank will “never donate to a political party, politician or party political campaign group,” a stated restriction that does not address non-party advocacy groups, charities, military-welfare bodies, or personal giving by principals.¹

• The reviewed corporate materials did not yield a supportable Starling corporate statement specifically addressing Israel, Palestine, Gaza, the October 2023 attacks, or subsequent hostilities.^{1, 2, 3}

• Starling’s 2022 annual report referred to the war in Ukraine as a macroeconomic and cost-of-living risk, rather than making a substantive corporate statement on that conflict.⁴

• No public evidence identified in the reviewed corporate materials of a later public statement revising the bank’s position on Israel, Palestine, Gaza, Zionism, occupation, or Palestinian rights.^{1, 2, 3, 5, 6}

Operations in Occupied or Contested Territories

• Starling’s current business-payment help page lists the Gaza Strip (State of Palestine) and West Bank (State of Palestine) among territories from which it cannot accept payments.⁷

• The same current page remained publicly available in September 2026, confirming that both entries were publicly displayed after July 2024 and November 2024; it does not establish when either entry was introduced, whether the policy was continuous, or the effective date of any internal restriction.⁷

• The page states that its list is subject to change and separately directs users elsewhere for the countries to which it can facilitate outgoing payments; it does not identify an Israel-specific outbound-payment rule.⁷

• Starling supplies no operational, legal, sanctions, correspondent-bank, anti-money-laundering, conflict-related, or political explanation for the Gaza Strip and West Bank entries on that territorial-restriction page.⁷

• The published inbound-restriction list also includes Afghanistan, Belarus, Central African Republic, Cuba, Democratic Republic of Congo, Haiti, Iran, Iraq, Lebanon, Libya, Mali, Myanmar, Nicaragua, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, and Zimbabwe, among others.⁷

• That list establishes identical published inbound treatment for the named Palestinian territories and the other listed jurisdictions, but does not establish a common rationale for every jurisdiction.⁷

• A separate Starling help page says foreign-currency payments can use correspondent and intermediary banks and that its euro-payment intermediary does not allow payments to or from EU high-risk third countries; that page does not connect those restrictions to Gaza or the West Bank.⁸

• Starling’s general account-restriction explainer describes account restrictions as safety and financial-crime controls, but does not address country or territory restrictions, Gaza, the West Bank, Israel, or Palestine.⁹

• No public evidence identified in the reviewed live sources of the restriction’s inception date, an archived earlier version of the territorial list, a Starling explanation for the entries, affected-user numbers, individual payment cases, duration of denial, or downstream effects on Palestinian economic or advocacy activity.^{7, 8, 9}

• A 2022 Bank of Israel conference report records Sam Everington of Starling Bank participating in a discussion on UK neobanking experience, but does not identify a Starling contract, licence, subsidiary, integration, or operational deployment in Israel or the occupied Palestinian territory.¹⁰

• Starling’s FY26 results state that its UK licensed bank provides personal, business, and joint current accounts in the UK, while Engine by Starling provides SaaS technology to banks internationally.⁶

• Starling disclosed Engine agreements with Tangerine, a Canadian Scotiabank subsidiary, and New Zealand’s SBS Bank; Engine’s public case-study index identifies projects in Romania, Australia, Canada, and New Zealand.^{6, 11}

• Engine’s AMP Bank GO case study describes work beginning in October 2023 and a February 2025 public launch in Australia.¹²

• No public evidence identified in the reviewed official materials, Companies House records, Bank of Israel conference record, Engine public-client material, and targeted searches of a Starling or Engine branch, subsidiary, service contract, reseller, customer deployment, or procurement arrangement in Israel, the West Bank, Gaza, East Jerusalem, or an Israeli settlement; this is source-scoped and does not exclude undisclosed relationships.^{10, 13, 14, 15, 5, 6, 16, 11}

• The supplied document-scoped scans found no Starling mention in the specified OHCHR settlement-business database materials, the UN Special Rapporteur’s A/HRC/59/23 report, Who Profits’ Touring Israeli Settlements, or the BDS Movement’s November 2024 corporate-priority guide.^{17, 18, 19, 20}

• No public evidence identified in the reviewed sources of an Israel/Palestine-related court action, regulatory action, OECD National Contact Point complaint, organised boycott/divestment/sanctions campaign, or Starling corporate response concerning occupied-territory operations; this is source-scoped rather than a comprehensive legal-database conclusion.^{17, 18, 19, 20, 21}

Internal Governance, Content & Retail Policies

• Starling’s ethics statement commits to a workplace free from harassment and bullying and says employees should be able to raise operational concerns internally or externally without fear of consequences, while containing no Israel/Palestine-specific employee-speech provision.¹

• In 2024, UK Lawyers for Israel reported that an Engine by Starling job application asked candidates whether they had lived or worked in Ukraine, Russia, Israel, or Belarus during the preceding five years.²²

• The advocacy-group article published Starling’s response that the question could cause concern, that Starling did not believe it breached the Equality Act, and that the question had already been removed from its careers site.²²

• This published matter concerns a geographic-history hiring question and is not public evidence of discipline, dismissal, or other enforcement against pro-Palestinian employee speech.²²

• No public evidence identified in the bounded review of Israel/Palestine-specific platform moderation, editorial suppression, retail-product labelling, settlement-origin categorisation, employment litigation, or union disputes.^{1, 18, 19, 20, 13}

Brand Heritage & State Partnerships

• Starling’s board biography states that Chair Colin Bell previously spent 16 years in the British Army, including operational service and appointments involving the UK Ministry of Defence and NATO.²³

• Starling presents Bell’s military experience as professional biography rather than military branding or an Israel-related affiliation.²³

• Starling personnel’s participation in the 2022 Bank of Israel payments conference was described as a conference discussion rather than a sponsorship, formal partnership, state honour, or government-procurement arrangement.¹⁰

• No public evidence identified in the reviewed sources that Starling uses Israeli military heritage, defence-sector links, state-security origins, Israeli state honours, or “Brand Israel” activity in its branding.^{10, 23, 18, 19}

Lobbying, Advocacy, Financing & Logistics

• Starling says its investments are principally low-risk, high-quality bonds, mortgages, and customer lending, while its reviewed ethics page does not publish Israel-specific investment or lending disclosures.¹

• Starling’s charity-partnerships page identifies Sports Aid, the National Trust, Action for Children, and Smart Works, and does not identify Israel/Palestine, military-welfare, settlement, JNF/KKL, FIDF, or reservist beneficiaries.²⁴

• The charity-page finding describes the organisations listed on that page and does not establish the full scope of historic charitable expenditure.²⁴

• Starling announced a debut bond sale in June 2026 that it said was oversubscribed by international investors; the announcement does not identify Israel/Palestine-related financing or a related counterparty.¹⁶

• No public evidence identified in the bounded review of Starling corporate lobbying on Israel-Palestine, donations to IDF/FIDF/JNF/KKL or settlement organisations, military-welfare financing, or conflict-period logistical assistance for Israeli state, military, or aligned entities.^{1, 24, 10, 17, 18}

Corporate Structure & Primary Mission

• Starling Bank Limited remains an active England-and-Wales private company limited by shares, incorporated on 18 June 2014 under company number 09092149 and classified under SIC 64191, “Banks.”¹³

• The register records a London registered office and accounts made up to 31 March 2026; FY26 consolidated accounts were filed on 12 July 2026, although their full text was unavailable for review in the underlying research because of retrieval-size limits.^{13, 25}

• Starling states that Starling Bank Limited trades as “Starling,” is PRA-authorised, and is FCA/PRA-regulated under FRN 730166; the Bank of England’s CHAPS-participant list also identifies Starling Bank Limited with that FRN and LEI 213800AE5VSF3V1PAV23.^{26, 27, 28}

• Starling Intermediate Holdings Limited is Starling Bank Limited’s sole active PSC, holding at least 75% of shares and voting rights and the right to appoint or remove directors.^{29, 30, 31}

• Starling Group Holdings Limited is the active PSC of Starling Intermediate Holdings Limited, with the same stated control characteristics.³¹

• Harald McPike-Zima is Starling Group Holdings Limited’s sole active PSC, with more than 25% and not more than 50% of shares and voting rights and stated control over trustees of a trust.²¹

• The 2025 reorganisation records McPike-Zima’s cessation as a direct Starling Bank PSC on 27 June 2025 and Starling Group Holdings Limited’s cessation as direct bank-level PSC on 30 September 2025, when Starling Intermediate Holdings Limited became the direct PSC.^{29, 21, 30, 31}

• The resulting registered control chain is Starling Bank Limited → Starling Intermediate Holdings Limited → Starling Group Holdings Limited → Harald McPike-Zima; Companies House control bands do not establish McPike-Zima’s ultimate economic ownership through the full chain or the identities of relevant trusts.^{29, 21, 30, 31}

• Starling describes itself as independent from other banks and identifies current or former employees, Harry McPike, Chrysalis Investments, Fidelity, Railpen, Qatar Investment Authority, Millennium Management, and Goldman Sachs as part-owners, without publishing ownership percentages or a geopolitical mandate on that page.³²

• Engine by Starling Limited, Starling FS Services Limited, and Fleet Mortgages Limited are active UK companies; Starling’s FY25 report additionally identifies Murmur Financial Services Limited, MFSI Holdings Limited, and Murmur Financial Services International DAC in subsidiary/intercompany disclosures.^{33, 34, 14, 15, 35, 5}

• Starling announced an agreement to acquire Ember in August 2025, subject to customary closing conditions, and stated in May 2026 that it had acquired Ember; the reviewed materials do not identify the acquired legal entity, acquisition vehicle, completion date, or consideration.^{36, 6}

• Starling describes the group as comprising its UK bank, Engine by Starling, and Fleet Mortgages, with headquarters in London and 12 offices worldwide; its FY26 webpage identifies offices in New York, Toronto, Dubai, and London.^{5, 6}

• The reviewed register evidence does not identify a state-held share, governmental founder, Israeli state body, or corporate mission tied to advancing Israeli state infrastructure or geopolitical objectives, while not excluding non-PSC investors, contractual counterparties, or undisclosed activity.^{13, 29, 21, 30, 31}

Executive & Leadership Footprint

• Companies House records Colin Bell, Raman Bhatia, Julie Chakraverty, Declan Ferguson, John Mountain, Daniel Olley, and Darren Pope as current Starling Bank directors.³⁷

• Starling identifies Bell as Chair, Bhatia as Group CEO, and Declan Ferguson as Group CFO.²³

• Anne Boden founded Starling and resigned as a Starling Bank director on 30 June 2024, while Starling’s March 2024 announcement stated that Bhatia would become Group CEO after Boden stepped back.^{37, 38}

• The current reviewed registers do not show Boden as an active director or PSC of Starling Bank, Starling Intermediate Holdings Limited, or Starling Group Holdings Limited.^{29, 37, 30, 39}

• Starling’s disclosed board biographies list external appointments for directors but do not name Israel/Palestine advocacy, settlement, IDF, JNF/KKL, FIDF, AIPAC, CFI, or anti-BDS affiliations.²³

• No public evidence identified in the prior bounded review of a supportable primary record linking the named directors, Anne Boden, or Harald McPike-Zima to Israel/Palestine political contributions, military-welfare donations, settlement organisations, defence/cyber investments, or relevant public advocacy.^{23, 21, 37}

• Examiner-directed cross-domain principal research reviewed McPike Global Family Office’s public description and selected portfolio, which list Starling, Tembo, Acre, Health Data Analytics Institute and Imagr.ai but expressly do not disclose the full portfolio; those pages cannot establish a complete investment-absence conclusion.^{40, 41}

• The same cross-domain research identified a U.S. private foundation bearing the McPike-Zima name: its 2015 Form 990-PF identifies Harald McPike as an $11 million substantial contributor, and the latest located IRS-recorded return reports $1.605 million of 2024 charitable disbursements and $56.117 million in net assets.^{42, 43} The accessible 2023 and 2024 return presentation did not render the complete itemised grant schedule, so no recipient-level conclusion concerning Israel, Palestine, military-welfare, settlement, or political-advocacy organisations is established.⁴²

• The completed work remains public-record and search scoped: it does not establish the absence of private investments, undisclosed portfolio holdings, unrendered foundation grants, or personal conduct outside the reviewed corporate, register, portfolio and tax-return materials.^{23, 29, 21, 37, 30, 39, 40, 42}