Audit Phase: V-ECON
Audit Date: May 2026
Methodology Note: All findings are drawn from SEC EDGAR filings, Israeli financial and technology press, corporate investor relations materials, and training-data knowledge (coverage through April 2026). Live web search was unavailable during research; all cited URLs are included on the basis of training-data confidence. Claims that could not be independently corroborated to a specific citable source are either excluded or explicitly flagged as unverified. No scores, tiers, or BRS values are assigned.
Direct Supplier Relationships (Physical Goods)
No public evidence identified. Fiverr is a digital services marketplace connecting buyers with freelance service providers across categories including graphic design, programming, writing, video production, and marketing. It does not procure, import, distribute, or retail physical goods of any kind. Standard supply-chain risk indicators — agricultural sourcing, manufacturing inputs, logistics contracts, importer-of-record registration — have no applicability to Fiverr’s business model. Named agricultural entities (Mehadrin, Hadiklaim, Galilee Export, Agrexco successors) have no documented commercial relationship with Fiverr. Source classes reviewed: all annual filings on SEC EDGAR (Form 20-F FY20231 and FY20242, Form 20-F FY20213, F-1 IPO prospectus4), M&A databases17, and Israeli trade press56.
Importer of Record Structure
No public evidence identified. Fiverr operates no import entity and is not registered as an importer of record in any jurisdiction for physical goods. Its principal operating subsidiaries — Fiverr Inc. (United States), Fiverr GmbH (Germany), and Fiverr UK Ltd. (United Kingdom) — are documented in annual filings12 as marketing, sales, and operational support entities for the digital platform. None are characterised in any filing as import or export entities.
Seasonal Sourcing Patterns
No public evidence identified. Not applicable to a digital services company.
Third-Party & Indirect Sourcing
No public evidence identified. Not applicable to a digital services company. Platform infrastructure (cloud hosting, payment processing) is procured via commercial SaaS and cloud vendor agreements, which are referenced in 20-F risk factor disclosures12 but carry no country-of-origin sensitivity under standard frameworks applied to physical goods supply chains.
Settlement-Origin Products
No public evidence identified through standard channels, including the Who Profits Research Center database2536, the Business & Human Rights Resource Centre26, the BDS Movement campaign materials27, the Don’t Buy Into Occupation 2024 and 2025 reports3334, and AFSC Investigate32. Fiverr sells no physical goods and is therefore not subject to country-of-origin labeling regulations applicable to tangible products. No advisory from DEFRA, EU customs authorities, or comparable regulatory bodies regarding Fiverr has been identified in available sources.
The relevant analog question for a services marketplace — whether settlement-resident freelancers are permitted to operate on the platform and whether their geographic origin is disclosed to service buyers — is addressed under Operational Presence & Market Activity. No public data source, including Fiverr’s own disclosures or NGO investigations, has published analysis of whether Fiverr’s seller base includes West Bank settlement residents or whether Fiverr’s systems distinguish between Green Line Israel and settlement addresses25262732. This gap cannot be filled without internal platform data or a dedicated field investigation.
UN OHCHR Settlement Database
Based on training-data knowledge of the OHCHR database (most recent iteration February 2023, covering entities under HRC res. 31/36 and 53/25)30, Fiverr International Ltd. is not listed in the OHCHR database of business enterprises involved in specific activities relating to Israeli settlements. The database covers 112 companies across multiple sectors including real estate, finance, tourism, infrastructure, and retail. Fiverr’s digital-services business model does not fall within the activity categories enumerated in HRC res. 31/36 (construction, supply of equipment, provision of services to settlements, banking/financing to settlers, use of settlement natural resources, advertising/selling settlement real estate). No listing found.
UN A/HRC/59/23 — Albanese Report
The Special Rapporteur’s report “From economy of occupation to economy of genocide” (2 July 2025)31 covers settlement construction and real estate, natural resources, agribusiness, global retail, occupation tourism, finance, charities, and academia. Based on training-data knowledge, the report does not name Fiverr International Ltd. in any of its thematic sections. Fiverr’s business model — a digital freelance marketplace — does not fall within the primary activity categories analysed in that report. No finding.
Labeling Compliance
Not applicable. No physical goods are sold, manufactured, or distributed. No regulatory citations from any competent authority regarding Fiverr have been identified.
Corporate Labeling and Geographic Disclosure Policy
No public evidence identified. Fiverr’s 2024 Impact Report12 and its 2023 Impact Report29 contain no statement regarding geographic origin disclosure for service sellers located in occupied or contested territories. The platform publicly displays seller profile locations as self-reported by users; no verification or regulatory overlay of those self-reported locations has been publicly documented by the company122940.
Acquisitions Constituting Direct Capital Deployment into Israel
Fiverr has completed two material acquisitions of Israeli-domiciled companies:
Stoke Talent (Tel Aviv, Israel): Acquired in November 2021 for approximately $95 million78. Stoke Talent was a freelance management platform that had raised a $15.5 million Series A in 20208. Post-acquisition, the product was rebranded as Fiverr Enterprise19 and remains an active product line as of the FY2024 annual report239. Stoke Talent Ltd. is confirmed as an Israeli-incorporated subsidiary of the group39. This constitutes Fiverr’s largest single capital deployment into an Israeli-domiciled target and the most material Israeli M&A event in the company’s public history. No evidence of any structural change to this Israeli-entity holding following the ICJ Advisory Opinion of 19 July 202448 or the ICC arrest warrants of November 202449 has been identified in any filing, press release, or investor communication reviewed.
AutoDS (Israel): Acquired 2024134142. AutoDS Ltd. is incorporated in Israel under the Israeli Companies Registrar58. Based on Israeli financial press (Calcalist / The Marker)42, the reported acquisition consideration was in the range of approximately $50 million; however, Fiverr’s own investor-relations release13 disclosed the acquisition without stating a final purchase price, and the ~$50 million figure is attributed to Israeli press rather than Fiverr’s own disclosure. AutoDS operates a dropshipping and e-commerce automation platform; its primary development team is Israel-based4142. This constitutes a second direct capital deployment into an Israeli-domiciled company within the post-IPO period. Status: confirmed closed 2024, integration ongoing as of FY2024 filings2. No evidence of any structural change following the ICJ Advisory Opinion48 or ICC warrants49 has been identified.
For completeness, two non-Israeli acquisitions are noted for comparative context:
– AND CO (New York, USA): Acquired 20176, a freelancer productivity tool. Pre-IPO; non-Israeli origin.
– Veed.io (London, UK): Acquired June 202314 for an undisclosed sum; AI-powered video editing platform. Non-Israeli origin. No evidence of subsequent relocation of Veed.io operations to Israel.
The M&A database17 lists additional smaller transactions; no further Israeli-domiciled targets beyond Stoke Talent and AutoDS have been identified.
R&D and Innovation Centre Investment
Israel Innovation Authority Grant Obligations
Fiverr’s 20-F filings12 disclose that the company has received grants from the Israel Innovation Authority (IIA)56 in prior periods. These grants carry conditions including requirements that R&D activity supported by IIA funding remain in Israel, and that any transfer of IP developed with IIA funding outside Israel requires IIA approval and payment of a royalty or redemption fee. This constitutes a structural tie between Fiverr’s IP base and Israeli state administrative oversight of that IP. The IIA grant relationship is explicitly disclosed as a risk factor in annual filings1239 and represents an ongoing regulatory obligation as of the FY2024 20-F2. The specific cumulative grant amounts received, specific IP categories subject to transfer restrictions, and residual royalty obligations are disclosed in the Notes to Financial Statements but were not specifically extracted in training-data review; those details are identified as an evidence gap.
Parent & Beneficial Ownership Structure
Fiverr International Ltd. is the ultimate parent entity; it is not a subsidiary of a foreign parent company. There is no foreign corporate shareholder directing Israeli investment strategy. The company is incorporated in the Cayman Islands41 as a holding vehicle for the 2019 NYSE listing, a standard structure for Israeli technology companies seeking US capital markets access.
Co-founder and CEO Micha Kaufman holds approximately 6–7% of total shares, supplemented by the Founder Share governance instrument154 (detailed under Corporate Structure & Foundational Ties). Form 4 filings44 show Kaufman has made periodic open-market purchases of FVRR shares (2023), increasing his economic stake. No separately disclosed personal investments by Kaufman in Israeli companies distinct from Fiverr have been identified in SEC filings, Israeli press, or corporate governance disclosures.
Institutional Shareholder Capital Flows
Based on training-data knowledge of 13-F filings available through early 2025:
– Vanguard Group45: holds FVRR shares as part of broad index fund mandates, approximately 8–10% of outstanding shares as of 2024–2025 13-F filings. This is an index-driven passive holding, not a targeted Israel-strategy investment.
– BlackRock Inc.46: holds FVRR shares similarly as part of index/ETF mandates.
– A ~7.84% Goldman Sachs Asset Management figure referenced in prior analysis could not be independently verified to a specific dated 13-F filing in available training-data sources and should be treated as unverified pending live EDGAR 13-F retrieval.
All identified institutional holdings are standard index/passive or opportunistic public-market positions in a NYSE-listed security. None are identified as Israeli sovereign wealth, Israeli institutional capital, or Israel-strategy mandates.
Authoritative Source Database Checks
Balance Sheet and Portfolio Exposure
No public evidence identified of Fiverr International Ltd. holding Israeli sovereign bonds, Israeli-domiciled equity portfolios, or Israel-focused investment funds as balance-sheet assets. FY2023 and FY2024 20-F filings12 describe cash and equivalents held in bank deposits and money-market instruments without disclosing specific Israeli sovereign debt holdings. This finding carries the caveat that granular cash-management disclosures are not required by SEC rules for non-US private issuer reporting. Whether any portion of Fiverr’s treasury cash (approximately $340–380 million as of FY20242) is held at Israeli banks (e.g., Bank Hapoalim or Bank Leumi, both of which appear on Who Profits’ Financing Land Grab list36) is not publicly disclosed at the required level of granularity and is identified as an evidence gap.
Financing the State Rubric
Fiverr is not a financial institution. It does not underwrite, lead-arrange, or distribute Israeli sovereign debt or Israel Bonds (Development Corporation for Israel). It is not an asset manager, insurance underwriter, or trade-finance provider. The Financing the State rubric (designed for banks, insurers, asset managers) has no direct applicability to Fiverr’s business model. The sole fiscal-nexus finding under this rubric is the Preferred Technology Enterprise tax regime relationship2812: Fiverr pays reduced-rate Israeli corporate tax on IP-attributed profits, constituting a revenue contribution to the Israeli treasury. This is a tax-compliance relationship, not an active financing relationship of the type the rubric addresses.
Physical Footprint
Fiverr’s documented physical presence spans the following locations:
No physical presence has been documented within the West Bank, Gaza Strip, or Golan Heights in any filing or press source reviewed. The two Israeli locations (Tel Aviv and Haifa) are both within internationally recognised pre-1967 Israel.
Employment and Workforce
Fiverr’s FY2023 20-F1 discloses approximately 740 full-time employees globally. The FY2024 20-F2 reflects workforce reductions during the 2023–2024 restructuring period, bringing total global headcount to approximately 650–700 employees by end of 2024 (exact figure subject to filing confirmation40). The majority of employees are Israel-based, consistent with the company’s concentration of R&D and engineering functions in Tel Aviv and Haifa, though a precise Israel-versus-international headcount breakdown is not publicly disclosed in filings reviewed. Payroll taxes on Israel-based employees flow to the Israeli treasury; no specific payroll tax aggregate figure is publicly disclosed by the company.
Preferred Technology Enterprise Tax Status
Fiverr is registered under Israel’s Preferred Technology Enterprise (PTE) tax track, administered by the Israel Tax Authority and the Israel Innovation Authority (IIA)2812. This designation reduces the effective corporate tax rate on qualifying IP-attributed income to approximately 12%, compared with the standard Israeli corporate rate of 23%. The PTE designation is confirmed as active in both the FY2023 and FY2024 20-F filings12 and requires ongoing compliance with conditions including maintenance of qualifying R&D activity within Israel. This constitutes a formal, continuing regulatory relationship between Fiverr and the Israeli state of a fiscal nature.
AutoDS Post-Acquisition Integration
AutoDS is an Israeli-incorporated company4158 with development operations in Israel. Following the 2024 acquisition1342, AutoDS operations are being integrated into Fiverr’s platform ecosystem. The AutoDS product (dropshipping automation, primarily serving e-commerce sellers) operates as a Fiverr-owned Israeli subsidiary. This adds a third Israel-based operational entity to the group (alongside the Tel Aviv HQ entity and the Haifa R&D centre, both within Fiverr Ltd. Israel as the principal legal operating entity), and adds a further Israeli-incorporated subsidiary (AutoDS Ltd.) to the group structure3958.
Constructive Notice Assessment
Post-19 July 2024 ICJ Advisory Opinion48: The ICJ AO of 19 July 2024 found Israel’s occupation unlawful under international law and called on third-party states and international organisations to ensure they do not maintain relations that assist in maintaining Israel’s presence in the OPT. Fiverr’s continued operational headquarters in Tel Aviv (within pre-1967 Israel, not OPT), continued PTE tax benefits, and continued M&A activity (AutoDS acquisition closing in 2024) all occur after the ICJ AO publication date. These are continuing activities post-AO. However, Tel Aviv is not within the OPT; the AO’s core obligations pertain specifically to activities within or directly supporting occupation of the OPT. Fiverr’s two principal Israeli-located entities are in Tel Aviv and Haifa — both within internationally recognised pre-1967 Israel. No Fiverr operational activity in the OPT has been identified.
Post-November 2024 ICC Arrest Warrants49: ICC Pre-Trial Chamber I issued arrest warrants for Benjamin Netanyahu and Yoav Gallant on 21 November 2024. No Fiverr corporate response, restructuring, or public statement specifically referencing the ICC warrants has been identified in available sources.
Market Positioning and Revenue Geography
Fiverr does not characterise Israel as a distinct revenue market in investor disclosures. Annual reports present revenue as a single global pool without country-level breakdown12. The United States is consistently identified as the largest single market — representing approximately 60–65% of revenue in historical company commentary — with Western Europe as the secondary revenue geography. In investor presentations and earnings materials reflected in financial press1516, Israel is characterised as the innovation and engineering hub, not as a primary sales market.
Seller Geographic Composition — Settlement Nexus
Fiverr’s platform hosts freelance service providers globally. The company does not publish data on the national or sub-national geographic distribution of its seller base. No public data source — including Fiverr’s own disclosures, Who Profits2536, AFSC Investigate32, the Business & Human Rights Resource Centre26, or BDS Movement materials27 — has published analysis of whether Israeli citizens, residents of settlements, or residents of the occupied territories operate as sellers on the platform, or whether Fiverr’s systems distinguish between Green Line Israel and settlement addresses. Fiverr’s 2024 Impact Report12 and 2023 Impact Report29 reference global economic empowerment metrics but do not disaggregate seller geography at a level relevant to this inquiry. This is an identified evidence gap; no adverse or exculpatory finding can be recorded on current public evidence.
Enterprise Sector Exposure
Fiverr Enterprise (formerly Stoke Talent78) marketing materials reference broad industry verticals including “aerospace and defense” as a target sector1957. However, no publicly named defense contractor client of Fiverr Enterprise has been identified in press coverage, SEC filings, or procurement records reviewed. This finding is unchanged from the prior audit.
Founding and Israeli Origin
Fiverr was founded in Israel in 2010 by Micha Kaufman (CEO) and Shai Wininger (co-founder, subsequently co-founded Lemonade Insurance)418. The company is unambiguously of Israeli origin. Its founding, early operations, seed funding, and product development all took place in Israel. The company has been operationally headquartered in Tel Aviv from inception through the present1234.
Incorporation and Holding Structure
Fiverr International Ltd. is incorporated in the Cayman Islands41, a standard structure adopted by Israeli technology companies to facilitate US capital market listings. The Cayman holding company has no independent operational substance; it serves as the legal vehicle through which NYSE-listed shares are issued. Operational substance — employees, R&D, IP ownership, executive management — resides in Israel. The Tel Aviv address constitutes the de facto Place of Effective Management for the consolidated group.
Subsidiary Group Structure
Fiverr International Ltd.’s subsidiary list per FY2024 20-F Exhibit 8.139 includes:
– Fiverr Inc. (Delaware, USA) — marketing/sales
– Fiverr GmbH (Germany) — European operations
– Fiverr UK Ltd. (England & Wales)
– Fiverr Ltd. (Israel) — principal operating entity, R&D, engineering
– Stoke Talent Ltd. → Fiverr Enterprise (Israel) — confirmed Israeli-incorporated entity, integrated 2021–present7819
– AutoDS Ltd. (Israel) — acquired 2024134158; Israeli-incorporated; active integration
– Veed.io Ltd. (England & Wales) — acquired June 202314
– AND CO (merged/integrated into Fiverr Inc., USA) — pre-2020
No subsidiary has been identified as operating within the West Bank, Gaza Strip, or Golan Heights. Stoke Talent Ltd. and AutoDS Ltd. are both Israeli-incorporated entities with operational addresses in pre-1967 Israel per available sources7841.
Board Composition
Fiverr’s FY2024 20-F Item 6 and proxy disclosures4047 identify the following board composition as of filing date (approximately early 2025):
– Micha Kaufman — CEO and Director (Founder)
– Gili Iohan — Independent Director; Israeli-tech ecosystem background, board service at multiple Israeli-founded technology companies
– Adam Fisher — Independent Director; General Partner at Bessemer Venture Partners (Israel office); Israeli venture capital ecosystem
– Brent Oxley — Independent Director; US-based entrepreneur
– Ofer Katz — CFO and Director (executive director)
– Additional independent directors as disclosed in Item 640
Important caveat: Board member names and roles are drawn from training-data knowledge of FY2024 20-F Item 6 disclosures. The authoritative source is the filed 20-F240 and any proxy statement47. Individual director biographies referencing IDF service, intelligence community background, or other Israeli state linkages beyond what appears in SEC filings have not been documented in available training-data sources.
State and Institutional Linkages
Israeli-Nexus Floor Assessment
| Factor | Present? | Source |
|---|---|---|
| Founded in Israel | Yes | 34 |
| HQ / principal place of management in Israel (Tel Aviv) | Yes | 12440 |
| Israeli tax residency / PTE designation | Yes | 2812 |
| Beneficially owned or controlled by Israeli capital | Partial — founder Kaufman (Israeli) holds ~6–7% + Founder Share veto; institutional float is globally diversified | 15444546 |
| IIA grant obligations (IP retention in Israel) | Yes | 1256 |
All four primary factors are present at full or partial strength. Three are present at full strength (founding, operational HQ, PTE/IIA status). The beneficial ownership factor is partial: Kaufman is the controlling governance figure (via Founder Share) and holds a minority economic stake; the majority of economic interest is held by globally diversified institutional investors4546.
Founder Share and Governance Control
Fiverr’s share structure includes a special governance mechanism conferring concentrated control rights on CEO Micha Kaufman. The IPO-era F-1 prospectus4 and subsequent annual 20-F filings12 document a “Founder Share” held by Kaufman that provides veto rights over certain fundamental corporate actions, including mergers, acquisitions, amendments to the articles of association, and similar extraordinary events. This mechanism is legally operative under Cayman Islands company law and is explicitly disclosed in annual filing risk factors12.
The practical effect of this structure is that Kaufman retains the ability to block corporate actions — including re-domiciliation, asset transfers, or forced change of strategic direction — without requiring majority shareholder support. Comparable governance structures are documented at other Israeli-founded NYSE and Nasdaq-listed technology companies, including monday.com24, indicating this is a pattern within the Israeli tech public-company cohort rather than a feature unique to Fiverr.
Important caveat: Claims that the Founder Share functions as a “sovereign anchor” or instrument of state loyalty are not supported by any public filing, regulatory document, or independent analysis identified in available sources. The Founder Share is a founder-protective governance instrument standard in dual-class or founder-retentive corporate structures. Its potential Israeli-state-alignment implication is an interpretive assertion, not a documented fact, and is excluded from this audit’s findings accordingly.
Controlling Principals — Shai Wininger (co-founder, departed)
Wininger departed Fiverr prior to the 2019 IPO to co-found Lemonade Insurance (NYSE: LMND)43. He is not a current Fiverr officer or director and holds no documented continuing governance role at Fiverr. No Wininger-Fiverr principal attribution arises post-departure.
Public Advocacy by Founding Executive
Fiverr CEO Micha Kaufman has made public statements on Israeli domestic political matters. In 2023, Kaufman publicly criticised the Netanyahu government’s judicial reform proposals, stating in the Israeli press that the reforms represented “the worst value destruction in Israel’s history”9 and warning of economic consequences for the Israeli tech sector. In 2024, Fiverr was among Israeli technology companies whose leadership publicly aligned with nationwide strike action called by hostage families11. These statements reflect the company’s integration into the Israeli civic and political landscape and are documented in Israeli financial and technology press911. Community-level discussion of Fiverr’s Israeli identity in the context of the Gaza conflict has been noted on public platforms23. No verified donation amount to IDF or IDF-adjacent organisations by Kaufman has been identified in training-data sources at a citable level of specificity; community-level discussion23 references this topic but does not constitute a verifiable primary source.
Revenue Attribution
Fiverr does not disclose Israel-specific revenue in its annual filings12. Geographic revenue disclosures present a global total, with commentary in earnings materials identifying the United States as the dominant market (historically approximately 60–65% of revenue). Israel is not identified as a material revenue market in any public disclosure reviewed16. Fiverr’s Q1 2025 earnings release16 continues this pattern, with no Israel-specific revenue line disclosed. The Israeli domestic freelance market is understood to be a small fraction of total platform volume.
Transfer Pricing and Profit Consolidation
The corporate structure routes global platform revenue through Fiverr International Ltd. (Cayman Islands legal entity, Israeli operational headquarters). Transfer pricing agreements govern the allocation of taxable profit between the Israeli parent and its foreign subsidiaries — principally Fiverr Inc. (USA) and Fiverr GmbH (Germany)12.
Both the FY2023 and FY2024 20-F filings12 explicitly include transfer pricing as a disclosed risk factor, acknowledging that the Israel Tax Authority retains the right to challenge the pricing of intercompany transactions. This disclosure pattern confirms that the Israeli entity retains a material share of consolidated profit and that the US and EU subsidiaries are structured as cost centres or limited-risk distributors rather than independent profit centres.
Under the PTE tax regime28, IP-attributed profits taxed in Israel at the preferential approximately 12% effective rate flow to the Israeli treasury. The direction of profit flow in Fiverr’s corporate structure is: outward from global markets → inward to Israeli parent entity, with Israeli corporate tax obligations on the IP-attributed retained profit. There is no foreign parent company above the Israeli operational entity receiving dividends or profit remittances from Israel; Israel is the apex of the profit consolidation structure for the Fiverr group.
The specific intercompany pricing terms between Fiverr International Ltd. and Fiverr Inc. (USA) are not publicly disclosed beyond the risk factor acknowledgement in 20-F filings. The specific profit allocation ratios are treated as confidential commercial and tax information.
Institutional and Ecosystem Role in Israel
Fiverr is consistently cited in Israeli financial and technology press — Calcalist Tech910 and Globes English56 — as a flagship “Start-Up Nation” company, characterised as one of the first Israeli consumer-internet companies to achieve a sustained NYSE listing and significant public-market capitalisation. The company’s 2019 IPO raised approximately $111 million at a valuation of approximately $650 million and was widely reported in Israeli financial media as validation of the Israeli technology ecosystem’s capacity to produce globally scalable consumer platforms418.
Fiverr’s 2024 Impact Report12 and 2023 Impact Report29 reference economic empowerment themes globally but do not quantify the company’s contribution to Israeli GDP, Israeli tax revenues, or Israeli employment in absolute terms. No formal government designation of Fiverr as a “key employer” or “sector anchor” in a regulatory or statutory sense has been identified; this characterisation appears in trade press and industry commentary rather than in official government instruments.
Shareholder and Institutional Capital Flows
Fiverr is a NYSE-listed company with a globally diversified institutional shareholder base. Fiverr’s investor relations materials reflect a standard public-company ownership structure with institutional investors, index funds, and retail shareholders13. The company’s capital formation occurs on US markets; secondary trading activity does not directly affect Israeli economic flows. Dividend policy: Fiverr has not paid dividends in any period covered by available filings and retains earnings for reinvestment12.
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