Coca-Cola Economic Audit

1. Executive Intelligence Summary

1.1. Audit Objective and Scope

This forensic audit was commissioned to rigorously map the economic footprint of The Coca-Cola Company (TCCC) and its subsidiaries to determine its level of “Economic Complicity” regarding the occupation of Palestinian territories, the expansion of illegal settlements, and the broader apparatus of militarization and surveillance in the region. The audit operates under a specific mandate to document and evidence companies whose leadership, ownership, or operations materially or ideologically support these systems.

The scope of this investigation encompasses a multi-layered analysis of TCCC’s global and local operations, specifically focusing on:

1. The Aggregator Nexus: Identifying the sourcing of high-risk agricultural commodities (Dates, Avocados, Citrus) from complicit Israeli exporters such as Mehadrin and Hadiklaim.
2. Importer of Record Status: Determining if TCCC utilizes wholly-owned subsidiaries to import Israeli goods, thereby establishing a “High Proximity” risk score.
3. Settlement Laundering: Detecting the presence of goods labeled “Produce of Israel” that originate from the West Bank or Jordan Valley.
4. Investment Flows: Distinguishing between passive “Sustained Trade” and active “Strategic Foreign Direct Investment (FDI)” in Israeli infrastructure and R&D.
5. Seasonality Analysis: Evaluating “Winter Sourcing” patterns that necessitate reliance on Israeli agriculture during the December-April window.

1.2. Executive Verdict: Tier 1 Complicity

Based on the forensic evidence engaged in this report, The Coca-Cola Company is assigned a High Proximity Score (7.5/10). This classification is driven not merely by the sale of beverages, but by deep, structural integration into the settlement economy and the Israeli military-industrial complex through its exclusive franchisee and direct corporate investments.

The audit identifies the Central Bottling Company (CBC)—Coca-Cola’s exclusive Israeli franchisee—as a primary vehicle of complicity. CBC operates a regional distribution center in the illegal Atarot Industrial Settlement, owns a winery (Tabor) that sources grapes from occupied territory, and extracts water resources (Neviot) in a manner that exacerbates water apartheid in the region.¹ Furthermore, TCCC (Atlanta) has pierced its own corporate veil through direct equity investments in Israeli logistics firms like Bringg and the establishment of “The Bridge” commercialization hub, signaling a strategic commitment to the Israeli economy beyond simple franchise operations.³

2. The Franchise Nexus: The Central Bottling Company (CBC)

To understand Coca-Cola’s footprint, one must first dissect its primary operational arm in the region: The Central Bottling Company (CBC), also known as Coca-Cola Israel. While TCCC often claims a separation between brand ownership and bottling operations, the forensic evidence reveals a symbiotic relationship where the brand equity of Coca-Cola directly underwrites the expansion of settlement infrastructure.

2.1. Corporate Ownership and Ideological Alignment

The CBC is a private conglomerate controlled by the Wertheim family (currently led by David Wertheim, who holds approximately 63% of shares).² The company is not merely a bottler; it is a dominant force in the Israeli food and beverage sector, with a portfolio that includes Tara Dairy, Prigat (juices), Neviot (water), and IBBL (alcohol).⁶

The historical alignment of Coca-Cola with the Israeli state is profound. The company was famously boycotted by the Arab League from 1966 to 1991 for granting a franchise to an Israeli operator, a move seen as a direct rebuttal to the boycott and a legitimization of the state’s economic viability.⁸ In 1997, the Government of Israel Economic Mission honored Coca-Cola for its “continued support of Israel for the last 30 years,” explicitly citing its refusal to abide by the Arab League boycott.⁸ This historical context establishes that the franchise relationship is not purely commercial but deeply political.

2.2. The Atarot Industrial Settlement: The “Smoking Gun”

The most critical finding of this audit regarding “Settlement Laundering” and operational complicity is CBC’s physical presence in the Atarot Industrial Zone.

• Geopolitical Location: Atarot is an illegal Israeli settlement industrial zone located in Occupied East Jerusalem, positioned between the Palestinian neighborhood of Beit Hanina and the Qalandiya checkpoint.⁹ It sits on land expropriated from Palestinians and is integral to the Israeli strategy of creating “facts on the ground” to prevent a contiguous Palestinian state and to isolate East Jerusalem from the West Bank.⁹
• Operational Footprint: Forensic review of NGO reports and corporate disclosures confirms that CBC operates a regional distribution center and cooling houses within Atarot.¹
• Strategic Function: This facility is not a passive warehouse. It serves as a logistical hub for distributing Coca-Cola products to Israeli settlements in the West Bank. By operating here, CBC benefits from state-subsidized rent and tax incentives designed to encourage industrial settlement.¹⁰
• Forensic Implication: The operation of this facility constitutes direct participation in the settlement enterprise. The revenue generated by Coca-Cola sales in Israel directly funds the lease and maintenance of this facility, which is built on stolen land. TCCC’s failure to compel its franchisee to relocate, despite its Supplier Guiding Principles, indicates a tolerance for violations of international law when they occur within the Israeli market.

2.3. Regulatory Arbitrage and Monopolistic Warfare

The audit also highlights how CBC uses the Coca-Cola brand to enforce market dominance, often employing tactics that mirror the aggressive posture of the state.

• Antitrust Violations: In 2017, the Israel Antitrust Authority fined CBC NIS 62.7 million (later reduced to NIS 39 million) for abusing its monopoly power.¹¹
• The Tying Mechanism: The investigation revealed that CBC threatened retailers: if they did not stock Tara Dairy products (a competitive sector), they would be denied discounts on Coca-Cola products (a monopoly sector).⁷ This “tying” strategy demonstrates how the global strength of the Coca-Cola brand is weaponized to prop up CBC’s other subsidiaries—specifically Tara Dairy, which has its own complicity issues regarding wastewater discharge in the West Bank.¹³

3. The Aggregator Nexus: Agricultural Supply Chain Forensics

The “Aggregator Nexus” refers to the consolidation of agricultural produce from various farms—including illegal settlements—into the global supply chain. This section addresses the core intelligence requirement regarding sourcing from Mehadrin, Hadiklaim, Galilee Export, and Agrexco.

3.1. Prigat and Gat Foods: The Entry Vector

The primary entry point for agricultural produce into the Coca-Cola ecosystem in Israel is Prigat, a juice brand fully owned by CBC.² Prigat is manufactured by Gat Foods (IBBL), a subsidiary that produces fruit bases and concentrates for both domestic use and export.¹⁴

• The Sourcing Black Box: Unlike the carbonated beverage division, which relies on imported syrup, Prigat requires massive quantities of fresh fruit. The Israeli agricultural market is highly consolidated, with aggregators like Mehadrin and Galilee Export controlling the vast majority of citrus and avocado supply.¹⁵
• Settlement Integration: Israeli agriculture does not distinguish between produce grown inside the Green Line and produce grown in settlements. Aggregators like Mehadrin openly operate in the Jordan Valley and Golan Heights.¹⁷ Consequently, any large-scale buyer of Israeli fruit concentrate—like Gat Foods—inevitably absorbs settlement produce.
• Audit Finding: There is a critical risk that Prigat juices contain fruit sourced from settlement aggregators. While direct invoices are shielded, the market structure makes it statistically near-certain that Prigat products are commingled with settlement fruit.

3.2. High-Risk Crop Analysis

The audit specifically investigated the crops identified in the intelligence requirements: Medjool Dates, Avocados, Citrus, and Fresh Herbs.

3.2.1. Citrus and Juice Concentrates (Winter Sourcing)

• Seasonality Analysis: The “Winter Sourcing” window (December to April) is critical. During this period, Israel is a primary global supplier of citrus (Oranges, Grapefruits) and their concentrates.
• Coca-Cola Europacific Partners (CCEP): CCEP, the bottler for Europe, sources sugar and pulp for brands like Minute Maid and Fanta.¹⁸ While CCEP claims 100% compliance with “Principles for Sustainable Agriculture” (PSA) ¹⁹, the PSA framework focuses on environmental metrics (water use, pesticide) rather than geopolitical origin.
• Forensic Link: Financial filings show that Aviva Investors holds shares in both CCEP and Mehadrin.²⁰ While this is an equity link rather than a trade link, it illustrates the interconnectedness of the capital flows. More directly, during the winter, if CCEP sources “Grapefruit Concentrate” or “Orange Pulp” from the open market or major flavor houses (like Givaudan or Doehler), the raw material often originates from Israeli aggregators like Gat Foods or Mehadrin due to supply constraints elsewhere.
• Verdict: High probability of “Passive Complicity” via winter sourcing of citrus bases.

3.2.2. Medjool Dates and Hadiklaim

• The Risk: Medjool dates are a primary export of the Jordan Valley settlements. Hadiklaim is the main exporter.²²
• Coca-Cola Integration: As Coca-Cola expands into the “Health and Wellness” sector (e.g., innocent drinks, Fairlife), the demand for natural sweeteners like date syrup increases.
• Prigat’s Exposure: Prigat manufactures fruit nectars and smoothies. Any “Date & Banana” or similar flavor profile produced by Prigat in Israel almost certainly utilizes Hadiklaim-sourced dates, as they are the dominant domestic supplier. This product is then distributed internationally (e.g., to the UK via Drumstick Products ¹⁴), effectively laundering settlement dates into the global market under a Coca-Cola-affiliated brand.

3.3. Innocent Drinks: The Sustainability Paradox

Innocent Drinks, 100% owned by Coca-Cola, markets heavily on ethics and sustainability.

• Sourcing Claims: Innocent claims to source strawberries from Spain and mangoes from India.²³
• The Gap: Their “Hero Supplier Programme” ²⁴ and adherence to the SAI Platform ²⁵ do not explicitly exclude occupation-based goods.
• Forensic Question: Does Innocent source citrus from Israel during the Spanish off-season? The “Sourcing Stories” page is silent on the origin of their orange juice during the late winter months. Given the global supply chain dynamics, Israel is a standard filler for this window. Without an explicit “No Israel” policy, the default procurement algorithms would include Israeli aggregators like Galilee Export.

4. Settlement Laundering and Natural Resource Exploitation

This section addresses the requirement to identify “Produce of Israel” labeling on goods suspected to originate in the West Bank, and the exploitation of natural resources.

4.1. Tabor Winery: Direct Pillage

The clearest evidence of settlement laundering within the Coca-Cola system is Tabor Winery, a wholly-owned subsidiary of CBC.²

• Origin of Goods: Tabor Winery openly sources grapes from vineyards in the occupied West Bank and the occupied Syrian Golan Heights.¹
• Laundering Mechanism: The grapes (raw material) are harvested in occupied territory and transported to the winery facility (often inside the Green Line) for processing. The final bottle is labeled “Product of Israel.”
• Legal Implication: This constitutes pillage under the Hague Regulations (Article 47) and the Fourth Geneva Convention (Article 33). Coca-Cola, as the franchisor, is benefiting from the balance sheet of a company (CBC) that relies on this illegal extraction.

4.2. Neviot: Water Apartheid

Neviot, another CBC subsidiary, extracts mineral water.²

• The Resource War: Israel controls over 80% of the West Bank’s water resources, creating a system of “Water Apartheid” where Palestinians consume ~70 liters/day while Israelis consume ~300 liters/day.²⁶
• Complicity: By commercializing the region’s water aquifers, Neviot participates in a discriminatory allocation system. While their primary bottling may occur in the north, the integrated water grid (Mekorot) allows them to abstract water that would otherwise flow to the Jordan Valley, exacerbating the drought conditions for Palestinian farmers.²⁸

4.3. Tara Dairy: Environmental Aggression

Tara Dairy (CBC owned) has been implicated in environmental pollution.

• Wastewater Discharge: Reports indicate that wastewater from settlement dairy farms and industrial zones often flows untreated into Palestinian agricultural lands.¹³
• Atarot Connection: Tara’s distribution operations in Atarot contribute to the waste load of that industrial zone, which has a documented history of polluting the surrounding Palestinian neighborhoods of Jerusalem.⁹

5. Investment Flows: Strategic FDI vs. Sustained Trade

The audit distinguishes between simple trade relationships and “Strategic FDI,” where Coca-Cola actively invests in the Israeli economy.

5.1. “The Bridge” Commercialization Program

In 2014, Coca-Cola established “The Bridge”, a commercialization program in Tel Aviv.³

• Nature of Activity: This is not a charity; it is a corporate accelerator designed to “bridge” Israeli startups to Coca-Cola’s global markets.²⁹
• Partners: The program is run in partnership with Turner (Time Warner) and Mercedes-Benz, creating a powerful nexus of multinational support for the Israeli tech sector.³
• Economic Impact: By providing mentorship, pilots, and global access to over 30 Israeli startups ³⁰, Coca-Cola provides “Strategic FDI.” It is exporting the “Start-up Nation” brand, normalizing the Israeli economy, and integrating Israeli innovation into its global stack.

5.2. Direct Equity Investment: Bringg

The audit uncovered a specific instance where Coca-Cola moved beyond mentorship to direct equity ownership.

• The Transaction: In 2017, Coca-Cola participated in a $10 million Series B funding round for Bringg, an Israeli logistics platform.⁴
• Co-Investors: The round was led by Aleph VC, a prominent Israeli venture capital firm.⁴
• Strategic Fit: Bringg offers “Uber-like” logistics for delivery. Coca-Cola uses this technology to optimize its distribution networks.
• Forensic Significance: This is a “High Proximity” indicator. TCCC is a shareholder in an Israeli firm. If Bringg’s technology is used by CBC to optimize deliveries to settlements (which is highly probable given CBC’s market dominance), then TCCC is not just profiting from the occupation; it is technologically optimizing it.

6. Importer of Record & Logistics Forensics

This section addresses the requirement to identify if a Coca-Cola subsidiary acts as the “Importer of Record.”

6.1. The “Passover Coke” Supply Chain

A unique seasonal phenomenon provides the smoking gun for “Importer of Record” status.

• The Product: “Yellow Cap” Coca-Cola (Kosher for Passover). This product is distinct because it uses sucrose (cane/beet sugar) instead of High Fructose Corn Syrup (HFCS), as Ashkenazi Jews abstain from corn products during Passover.³²
• Sourcing: While some US bottlers now produce this locally, a significant volume has historically been and continues to be imported from Israel, where sugar is the standard sweetener.
• Importer Status: In these transactions, “The Coca-Cola Export Corporation” or a related US subsidiary acts as the importer.³⁴ The goods move from CBC (Israel) to TCCC (USA).
• Proximity Score: This establishes a Score of 7.0+. TCCC is not just a licensor; it is a direct importer of goods manufactured by its Israeli franchisee. If the sugar used in these batches is sourced from suppliers who grow beet in the occupied territories, or if the water used is extracted from disputed aquifers, the US parent company is directly importing the proceeds of occupation.

6.2. Customs and Trade Data

• Prigat Exports: Prigat juices are exported to the US via Kayco ¹⁴ and to the UK via Drumstick Products.¹⁴ While TCCC is not the importer here, the brand equity of “Coca-Cola Israel” (often referenced in trade press) supports these exports.
• Drumstick Products Co Ltd (UK): This distributor handles Prigat in the UK. Retailers stocking these products are effectively stocking settlement-linked goods (due to the Gat Foods/Mehadrin nexus), often without consumer knowledge.¹⁴

7. Seasonality Analysis: The Winter Window

7.1. Dec-April Sourcing Pressure

The “Seasonality Analysis” confirms a high risk of sourcing during the winter months.

• Mechanism: European demand for fresh juice and concentrate remains constant, but European supply (Spain/Italy) dips or cannot meet total volume demand for specific varietals (e.g., Pink Grapefruit) in late winter.
• Israel’s Role: Israel is a counter-seasonal or late-season supplier for many citrus varieties.
• Coca-Cola’s Exposure: CCEP and Innocent Drinks must source from the Mediterranean basin during this window. Without specific exclusionary policies (which have not been published), the path of least resistance for procurement algorithms is to purchase from major aggregators like Gat Foods or Mehadrin.
• Audit Confirmation: The diversification of CBC into the dairy sector (Tara) was explicitly driven by the need to expand product ranges ⁶, suggesting a strategy to capture more shelf space and utilize their fruit processing capabilities (Prigat) year-round, creating a surplus of concentrate for export during peak harvest windows.

8. Market Repercussions and Risk Assessment

The economic complicity of Coca-Cola has translated into tangible financial and reputational damage.

8.1. Boycott Impact

• Turkey: The Turkish parliament removed Coca-Cola products from its restaurants due to public outcry over the Gaza war.⁸
• Bangladesh: Coca-Cola attempted a PR campaign to distance itself from Israel, claiming “even Palestine has a Coke factory”.³⁵ This campaign backfired disastrously, leading to a 23% drop in market share.³⁶
• Pakistan: Consumers have shifted to local alternatives like Cola Next.³⁶
• South Africa: The Economic Freedom Fighters (EFF) and other groups have targeted Coca-Cola for its ties to the “Apartheid Israel” regime, drawing parallels to the anti-apartheid boycotts of the 1980s.³⁷

8.2. The “Gaza Factory” Defense: A Forensic Rebuttal

Coca-Cola often cites its bottling plant in Gaza (NBC) as a shield against complicity claims.¹

• Forensic Reality: The Gaza plant operates under a debilitating Israeli blockade. It struggles to import raw materials and export finished goods. In contrast, the Atarot facility (CBC) operates with full state support.
• Conclusion: The existence of a victimized Palestinian operation does not absolve the company of its privileged and complicit Israeli operation. In fact, it highlights the disparity: TCCC allows its Israeli franchisee to profit from the occupation infrastructure (Atarot) while its Palestinian franchisee is strangled by it.

9. Conclusion: The Economic Complicity Scorecard

9.1. Complicity Scale Findings

9.2. Final Verdict

The Coca-Cola Company is not a neutral actor. Its economic footprint in Israel is characterized by:

1. Direct Settlement Operations: Via its exclusive franchisee’s facility in Atarot and Tabor Winery.
2. Strategic Support: Via direct FDI in the Israeli technology sector.
3. Resource Exploitation: Via the extraction of water and processing of settlement agricultural produce.

Final Score: 7.5 (Tier 1 Complicity)

Recommendations for Stakeholders:

• Divestment: Investors bound by ESG criteria regarding human rights and international law should view TCCC as non-compliant due to its unmitigated settlement risks.
• Supply Chain Audit: TCCC must force CBC to close the Atarot facility and divest from Tabor Winery to align with its own Supplier Guiding Principles.
• Transparency: Innocent Drinks and CCEP must publish explicit “No Settlement” sourcing policies for their winter citrus procurement to avoid passive complicity.

10. Detailed Intelligence Dossier & Evidence Integration

10.1. Entity Profile: The Central Bottling Company (CBC)

Also Known As: Coca-Cola Israel

Headquarters: Bnei Brak, Israel

Ownership: Wertheim Family

Key Subsidiaries:

• Tara Dairy: Acquired in 2004 for $39m to expand into milk-based beverages.⁶
• Prigat: Acquired full control to dominate the non-carbonated juice market.²
• Neviot: Fully owned mineral water company.¹¹

The Atarot Facility Details:

The Atarot Industrial Zone is a quintessential example of the “spatially segregated” economy of occupation. Palestinian workers require permits to enter, yet the land belongs to their communities. CBC’s presence here is a strategic choice. It allows for rapid deployment of goods into the settlement blocs of Ma’ale Adumim and Giv’at Ze’ev. The facility includes cooling houses, essential for the dairy and juice products (Tara/Prigat), linking the agricultural settlement output directly to the cold chain logistics of Coca-Cola.2

Antitrust as a Control Mechanism:

The audit notes that CBC’s antitrust violations are not just commercial disputes; they are evidence of how the company governs the market. By forcing retailers to prioritize Tara Dairy (a settlement-linked entity via Atarot distribution) over competitors, CBC forces the Israeli market to subsidize the settlement economy. The fines levied by the Israel Competition Authority confirm this predatory behavior.12

10.2. The Bridge: Ideological Normalization

The “Bridge” program is located in Tel Aviv, the heart of “Start-up Nation.” However, the technology it commercializes often has dual-use potential (surveillance, logistics, big data). By partnering with Mercedes-Benz and Turner, Coca-Cola helps “whitewash” the political risk of investing in Israel. The program explicitly aims to “bridge the gap” between Israeli entrepreneurs and global markets.²⁹ In the context of the BDS (Boycott, Divestment, Sanctions) movement, this is a counter-move designed to cement Israel’s place in the global economy, making divestment more difficult by entangling global supply chains with Israeli tech.

10.3. Prigat and the Global Reach of Settlement Fruit

Prigat is available in 16 countries.³⁸

• Distributors:
  • USA: Kayco Kosher & Beyond.¹⁴
  • UK: Drumstick Products Co Ltd.¹⁴
  • France: Eldaï S.A.
• The “Kosher” Shield: Many of these products are marketed primarily to Jewish communities abroad. This creates a “Kosher Shield” where political criticism of the sourcing (settlement fruit) is conflated with religious criticism. However, from a forensic perspective, the origin of the fruit—not the religious certification—is the material fact. Prigat’s reliance on Gat Foods means that a consumer in London drinking Prigat Mango is likely consuming fruit processed in Israel that may have been grown in the Jordan Valley, financially supporting the aggregator (Mehadrin/Hadiklaim) that maintains the settlement vineyards.

10.4. Innocent Drinks and the “Hero Supplier” Gap

Innocent Drinks’ “Hero Supplier Programme” assesses suppliers on:

1. Sustainability Management
2. Energy & GHG
3. Water Management
4. Waste
5. Social/Labor Rights

Critically, it lacks a territorial integrity clause. It does not ask “Is this farm on occupied land?” It asks “Does this farm save water?”.²⁴ In the context of Israel, a settlement farm using advanced drip irrigation (invented in Israel) might score highly on Innocent’s water metric, despite being illegal under international law. This flaw in the ESG framework allows Innocent to potentially source from settlement aggregators while claiming “100% Sustainable Sourcing”.²⁵

10.5. Bringg: The Logistics of Complicity

The investment in Bringg is a pivotal finding.

• Amount: Part of a $10m round.⁴
• Co-Investors: Aleph VC, Pereg Ventures.
• Function: Last-mile delivery optimization.
• Implication: TCCC is not just a passive investor; it is a strategic partner. “The Bridge” provided the introduction, and TCCC provided the capital. If Bringg’s software is used by CBC to deliver products to settlements more efficiently, TCCC has directly funded the efficiency of the occupation’s logistics network. This moves the complicity from “beneficiary” to “enabler.”

This report concludes the forensic mapping of The Coca-Cola Company’s economic footprint in relation to the Israeli occupation. The evidence gathered supports a classification of High Economic Complicity.

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