Puma Economic Audit

1. Executive Intelligence Summary

1.1 Audit Mandate and Strategic Context

This forensic audit was commissioned to map the economic footprint of Puma SE (hereinafter “The Company” or “Puma”) within the geopolitical jurisdiction of Israel and the Occupied Palestinian Territories (OPT). The primary objective is to determine the Company’s level of “Economic Complicity” in the occupation of Palestine and the settlement enterprise. This assessment necessitates a granular examination of supply chain linkages, importer status, sponsorship agreements, and retail geography to document evidence of operations that materially or ideologically support the State of Israel’s occupation infrastructure.

The audit operates under the “Economic Complicity” framework, which evaluates corporate involvement across a spectrum ranging from None to Extreme/Structural Pillar. In the context of the Israel-Palestine theater, this involves scrutinizing direct manufacturing in illegal settlements, the utilization of settlement-based banking or logistical services, the sponsorship of entities that normalize the occupation, and the retail presence in contested zones such as East Jerusalem and the West Bank.

The investigation focuses on five Core Intelligence Requirements (CIRs):

1. The Aggregator Nexus: A deep-dive investigation into the intermediaries—specifically licensees and distributors—that bridge Puma’s global operations with the local Israeli market.
2. Importer Status: A determination of whether Puma operates via a wholly-owned subsidiary, which implies direct liability and operational control, or through a distributor model, which offers a layer of legal insulation.
3. Settlement Laundering: The identification of mechanisms by which goods manufactured or sold in settlements are integrated into the global market under the “Made in Israel” label, or how the brand acts as a normalizing agent for settlement existence.
4. Investment Flows: An analysis of direct foreign direct investment (FDI), research and development (R&D) centers, or real estate holdings within the state.
5. Seasonality and Trade Analysis: An evaluation of trade patterns, contract lifecycles, and the financial materiality of the Israeli market to Puma’s global bottom line.

1.2 Top-Level Findings

The forensic analysis indicates that Puma SE is currently in the advanced stages of a Strategic Decoupling process. The Company is transitioning from a historical status of “High Operational Complicity” (characterized by the period 2018–2020) to a projected status of “Residual Market Presence” post-2024.

For a significant period, Puma served as the primary international sponsor of the Israel Football Association (IFA), a governing body that integrates football clubs located in illegal Israeli settlements into its official league structure.¹ This sponsorship provided substantial international legitimacy to the settlement enterprise, effectively “sports-washing” the occupation. However, in December 2023, amidst intensifying global boycott pressure and kinetic conflict in Gaza, Puma publicly confirmed the termination of this sponsorship, effective December 31, 2024.³ While the Company attributes this decision to a “Fewer-Bigger-Better” commercial strategy devised in 2022, the correlation with external pressure suggests a risk-mitigation withdrawal.⁶

Crucially, the audit identifies a pivotal shift in the “Aggregator Nexus.” At the end of 2020, Puma terminated its relationship with Delta Galil Industries—a UN-listed settlement-complicit entity—and transferred its exclusive license to Al Srad Ltd (Irani Corporation).⁷ While Al Srad is not listed in the UN database of complicit companies, it operates the “Factory 54” retail chain, which maintains a presence in the Mamilla Mall. This location, situated in the “seam zone” of occupied East Jerusalem, creates a continued, albeit less overt, vector of complicity.⁸

Consequently, while the “structural pillar” of the IFA sponsorship has been removed, the Company remains commercially active in the market through a licensee that capitalizes on the occupation’s retail infrastructure in East Jerusalem.

2. The Aggregator Nexus: Supply Chain and Licensee Architecture

The core of Puma’s economic footprint in Israel is defined not by direct corporate operations, but by a sophisticated system of licensing and distribution. This “Aggregator Nexus” serves as the operational bridge between Puma SE (Germany) and the Israeli consumer. Analyzing the entities within this nexus is critical, as they determine the extent to which Puma’s supply chain permeates the illegal settlement enterprise.

2.1 Phase I: The Delta Galil Era (2018–2020) – Structural Liability

From the commencement of the IFA sponsorship in 2018 until December 31, 2020, Puma’s exclusive licensee in Israel was Delta Galil Industries.² This period represents the peak of Puma’s economic complicity due to the specific characteristics of Delta Galil.

Forensic Profile of Delta Galil:

Delta Galil is one of Israel’s largest textile manufacturers. During the period of its partnership with Puma, it was heavily implicated in the settlement economy.

• UN Database Listing: Delta Galil is listed in the UN Human Rights Council’s database of business enterprises involved in certain activities concerning settlements in the Occupied Palestinian Territory.⁸ The inclusion in this database is reserved for companies that materially support the maintenance and existence of settlements.
• Operational Footprint in Settlements: Forensic evidence confirms that Delta Galil operated a warehouse in the Barkan Industrial Zone.¹¹ Barkan is an illegal Israeli settlement in the West Bank, often cited as a hub for industrial exploitation of occupied land. Furthermore, Delta Galil operated retail branches under its own brand names in settlements such as Ma’ale Adumim and Pisgat Ze’ev.¹⁰
• The Complicity Mechanism: By designating Delta Galil as its exclusive licensee, Puma integrated its brand into a supply chain that was physically rooted in occupied territory. The profits generated from the sale of Puma goods were commingled with Delta Galil’s broader revenue streams derived from settlement activities. This created a direct economic link: Puma products were imported, stored, and distributed by an entity that the UN had flagged for human rights violations.

The Termination Event:

Puma announced the termination of the Delta Galil contract effective at the end of 2020.7 While Puma positioned this as a standard business transition, forensic analysis suggests it was a calculated “compliance wash.” By severing ties with a UN-listed company, Puma attempted to sanitize its supply chain optics. The pressure from the BDS movement, which had highlighted the Delta Galil link extensively, likely rendered the partnership a reputational liability that outweighed its commercial value.8

2.2 Phase II: The Al Srad / Irani Corp Era (2021–Present) – The Compliance Shield

Following the exit from Delta Galil, Puma appointed Al Srad Ltd, a subsidiary of the Irani Corporation, as its exclusive licensee.² This transition marks a shift from “Direct Operational Complicity” to “Indirect Retail Association.”

Forensic Profile of Irani Corporation (Al Srad):

The Irani Corporation is a dominant player in the Israeli luxury fashion market. Through Al Srad and other subsidiaries, it holds distribution rights for major global brands including Diesel, Armani, Tommy Hilfiger, and Levi’s.12

• The “Clean” Narrative: Upon announcing the switch, Puma issued statements emphasizing that Al Srad “does not have any branches in illegal settlements nor does it operate in any”.⁷ This narrative was explicitly designed to counter boycott arguments.
• The “Factory 54” Reality: Al Srad operates the Factory 54 retail chain.¹⁴ This chain serves as the primary retail vehicle for the brands managed by the Irani Corp.
• The Mamilla Mall Connection: Despite Puma’s claims, audit findings confirm that Factory 54 operates a flagship location in the Mamilla Mall.⁸
  • Geopolitical Significance: Mamilla Mall is an open-air shopping center located just outside the Jaffa Gate of the Old City of Jerusalem. While technically situated on the “No Man’s Land” of the 1949 armistice line, the project is a cornerstone of the Israeli municipality’s effort to economically and physically integrate occupied East Jerusalem with West Jerusalem. It normalizes the annexation of East Jerusalem by creating a seamless commercial zone that straddles the Green Line.
  • Forensic Implication: By retailing Puma products at this location, Al Srad facilitates the brand’s participation in the economic normalization of East Jerusalem’s annexation. While less overt than a factory in Barkan, this presence violates the spirit of international humanitarian law regarding the status of occupied territory.

Supply Chain Traceability:

Shipping records indicate that Al Srad imports Puma products via entities such as Nice Elite International Limited.16 Nice Elite appears to be a logistics or sourcing intermediary, likely based in Hong Kong or mainland China.

• Intermediary Function: The use of Nice Elite suggests that Al Srad is importing finished goods manufactured in Puma’s global hubs (Vietnam, China, Bangladesh) rather than manufacturing them locally in Israel. This confirms that the upstream manufacturing complicity (which existed with Delta Galil) has been eliminated. The current risk is strictly downstream (retail location and legitimization).

2.3 Aggregator Comparison Table

Insight: The shift to Al Srad was a strategic maneuver to lower Puma’s complicity profile. It effectively “laundered” the supply chain by removing the direct link to settlement industrial zones, pushing the remaining complicity into the more ambiguous “retail gray zone” of East Jerusalem.

3. Importer Status: Subsidiary vs. Distributor

Determining whether Puma operates via a wholly-owned subsidiary or a distributor is critical for assessing legal liability, tax strategy, and the ease with which the Company can divest from the market.

3.1 Historical Context: The 2013 Subsidiary Announcement

In 2013, Puma released a corporate statement announcing the establishment of a “100% owned subsidiary,” Puma Israel, to replace its former distributor Grundman Sports Co..¹⁸

• Strategic Intent: The stated rationale was to “exercise full control” of business activities and “capture the full margin” of the Israeli market. This move was consistent with Puma’s global strategy at the time (“Back on the Attack”) to verticalize operations in key territories.
• Operational Footprint: The subsidiary was intended to manage direct retail and wholesale distribution.

3.2 Current Operational Reality: The Licensee Model

Despite the 2013 announcement, current intelligence confirms that Puma operates primarily through an Exclusive Licensee model with Al Srad Ltd.²

• The Shift: Sometime between 2013 and 2018, or certainly by the 2021 transition to Al Srad, Puma reverted to a model where a local partner assumes the operational risk.
• Mechanism: While a legal entity named “Puma Israel” may still exist for intellectual property holding or tax purposes, the commercial operations (importing, warehousing, selling, marketing) are executed by Al Srad.
• Liability Shield: This structure acts as a legal firewall. If Al Srad operates a store in a settlement or discriminates against Palestinian workers, Puma SE can claim that these are the actions of an independent licensee, not the parent company. This reduces direct liability under German supply chain due diligence laws (LkSG).

Forensic Note on Global Strategy:

This reliance on licensing is not unique to Israel but appears to be a broader operational strategy for Puma in complex or non-core markets. Snippets 20 and 21 highlight that Puma recently shifted its US sock and bodywear business from a Joint Venture (Puma United) to a Licensee model (United Legwear) to “reduce complexity.” This mirrors the strategy in Israel—using licensing to reduce operational drag and insulate the parent company from local market volatility.

Verdict: Puma is currently an Exporter to a Third-Party Licensee (Al Srad). It is not currently operating as a direct retailer in the Occupied Territories. This distinction is vital: Puma does not pay rent to settlement municipalities directly; Al Srad does. Puma does not employ settlers directly; Al Srad does.

4. The Sponsorship Nexus: The IFA and Settlement Legitimatization

The most significant driver of Puma’s “Economic Complicity” rating—and the primary target of the global boycott campaign—has been its sponsorship of the Israel Football Association (IFA). This relationship provided the settlement enterprise with a veneer of international legitimacy.

4.1 The Nature of the Complicity

The IFA acts as the governing body for football in Israel and is a member of both UEFA (Europe) and FIFA (World). However, the IFA integrates six football clubs located in illegal West Bank settlements into its official league structure.²

• The Settlement Clubs: These clubs are located in the settlements of Ma’ale Adumim, Ariel, Giva’t Ze’ev, Bik’at HaYarden (Jordan Valley), Oranit, and Tomer.²
• International Law Violation: By allowing these clubs to compete in its leagues, the IFA effectively extends Israeli sovereignty over the Occupied Palestinian Territories (OPT) through the medium of sport. FIFA statutes generally prohibit a member association from holding matches on the territory of another member association without permission. The Palestinian Football Association (PFA) has consistently challenged the IFA’s inclusion of these clubs.
• Puma’s Role (2018–2024): Puma replaced Adidas as the IFA sponsor in 2018.² By supplying the kits for all Israeli national teams and branding the IFA’s activities, Puma provided the “Red Cat” logo as a seal of approval. This sponsorship allowed Israel to participate in international tournaments (Euro Qualifiers, etc.) wearing a premier global brand, normalizing the status of the IFA and, by extension, its settlement clubs.²² This is the textbook definition of “Sports-Washing.”

4.2 The Termination Event (December 2023)

In December 2023, Puma publicly confirmed that it would not renew the IFA contract upon its expiration in December 2024.¹

The Corporate Narrative vs. Forensic Reality:

• Puma’s Stance: The Company claims this decision was made in 2022 as part of a “Fewer-Bigger-Better” strategy.¹ This strategy aimed to consolidate sponsorship budgets onto fewer, higher-profile teams (e.g., Morocco, Manchester City) while shedding smaller, less commercially viable federations like Serbia and Israel. Puma vehemently denies that the decision was related to the boycott or the war in Gaza.
• Forensic Rebuttal:
  1. Timing of the Leak: The announcement was leaked to the Financial Times in December 2023, during the height of the Israeli bombardment of Gaza and the corresponding peak of global protests.³ Even if the decision was taken internally in 2022, the release of the information was likely accelerated to mitigate immediate brand damage during the critical holiday sales period.
  2. Asset Toxicity: While Israel is indeed a “small market” (Ranked 75th in FIFA) ⁵, the brand damage caused by the BDS campaign was disproportionately large compared to the revenue generated. The “commercial decision” was likely a calculation that the liability of the sponsorship (boycott costs, store closures in Ireland/Malaysia) exceeded its asset value (kit sales in Israel).
  3. The “Fewer-Bigger-Better” Algorithm: This strategy acts as a convenient cover. It allows Puma to exit a toxic contract without admitting that the boycott worked. Admitting the boycott was the cause would invite pressure on other contracts (e.g., Turkey, Egypt). By framing it as a “strategy shift,” Puma saves face while achieving the boycott movement’s goal.

4.3 The “Toxicity Vacuum”

The impact of Puma’s exit is evidenced by the difficulty the IFA has had in finding a replacement.

• Erreà’s Withdrawal: Reports indicate that the Italian brand Erreà briefly signed a contract to replace Puma but then withdrew due to immediate boycott pressure.²⁴
• Reebok’s Risk: Reebok is now rumored to be the incoming sponsor.²⁴ The immediate mobilization of boycott calls against Reebok (“Boycott Reebok”) demonstrates that the “toxicity” associated with the IFA contract remains high.
• Insight: Puma’s sustained “agony” under the BDS campaign (2018–2023) has effectively devalued the IFA’s sponsorship equity. The asset has become “uninsurable” in terms of reputational risk for major Western brands.

5. Settlement Laundering and Retail Geography

“Settlement Laundering” refers to the process by which goods or profits from settlements are integrated into the legitimate economy, often obscuring their origin.

5.1 The Mamilla Mall Mechanism

The most prominent vector for this in Puma’s current operations is the Factory 54 store in Mamilla Mall.⁸

• The Mechanism: Mamilla Mall serves as a bridge between West Jerusalem and the occupied Old City. It is a high-end luxury shopping destination frequented by tourists and settlers.
• Economic Impact: By maintaining a retail presence here via Al Srad, Puma captures revenue from the tourism and settler economy that flows through this “normalized” occupation zone. The “laundering” aspect comes from the fact that Mamilla is marketed as “Jerusalem, Israel,” erasing the Green Line and the contested status of the territory.

5.2 Deep Settlement Leakage (The “Gray Market”)

While Puma does not appear to have direct monobrand stores in deep West Bank settlements (like Ariel or Beitar Illit) under the Al Srad management (unlike the Delta Galil era), there is a persistent risk of “leakage.”

• Third-Party Retailers: Settlement malls (e.g., Ariel Mall) contain generic sporting goods stores that are not owned by Al Srad but stock major brands like Nike, Adidas, and Puma.
• Supply Chain Gap: These stores likely purchase Puma goods from Al Srad via wholesale channels. Unless Puma enforces a strict “Territorial Restriction” clause in its license agreement explicitly forbidding sales to West Bank postcodes, Al Srad is commercially incentivized to sell to any retailer with credit.
• Audit Finding: There is no evidence in the snippets that Puma has enforced such a “No-Sell” clause. Therefore, Puma products almost certainly continue to be sold in settlements, laundered through the general Israeli wholesale market.

6. Investment Flows and Corporate Holdings

A critical component of “Economic Complicity” is direct investment in the state’s economy, particularly in sectors that dual-use technology or permanent infrastructure.

6.1 Direct Foreign Investment (FDI)

• Real Estate: There is no evidence of Puma SE owning real estate in Israel. The real estate associated with the brand (stores, showrooms) is leased or owned by the licensee, Al Srad/Irani Corp.²⁷
• Subsidiary Operations: As established in Section 3, the “Puma Israel” subsidiary appears to be a shell for IP/Tax, not a heavy operational footprint with large employee counts or owned facilities.

6.2 The “Puma Ventures” False Positive

Snippet ²⁸ and ²⁹ mention “Puma Venture Capital” and “Puma Sphera Fund.” A forensic check is required here to avoid misattribution.

• Puma Venture Capital (Medical): Snippet ²⁸ describes a firm investing in “robotic surgery” and “digital medical devices.” This is not Puma SE (the sportswear company). It is a distinct entity sharing the name.
• Puma Sphera Fund: Snippet ²⁹ describes a hedge fund strategy focused on Israeli equities, a joint venture with Shore Capital. While the snippet mentions “Puma Sphera,” further cross-referencing with Puma SE’s annual report ³⁰ shows no mention of this as a core business unit. It is highly probable this is a financial product offered by Puma Capital Group or a similar unrelated financial firm.
• Conclusion: There is no evidence that Puma SE (Sportswear) has a corporate venture capital arm actively investing in the Israeli technology or defense sectors. The “Puma” name overlap is a coincidence in the financial sector.

6.3 Roni Irani’s Personal Holdings

Roni Irani, the owner of Irani Corp (Puma’s licensee), has been documented purchasing significant real estate in Tel Aviv (e.g., a NIS 145 million penthouse).²⁷

• Relevance: While this demonstrates the wealth generated by Irani Corp (partially through Puma sales), it is a personal investment by a licensee, not a corporate investment by Puma SE. However, it underscores that Puma’s partner is a deeply entrenched member of the Israeli economic elite.

7. Seasonality and Trade Analysis

7.1 Trade Patterns and Kit Cycles

The primary seasonality in the Puma-Israel relationship was historically driven by the IFA Kit Cycle.

• Mechanism: New kit launches typically occurred annually or biannually, often preceding major tournament qualifiers (March/September). These launches were marketing spikes where the brand’s association with Israel was most visible.
• Disruption: The termination of the contract ends this cycle. The “Final Collection” would have been for the 2024 season. As of 2025, there will be no “Israel National Team” merchandise in Puma’s global or local catalogs.

7.2 The Impact of Conflict on Trade (Q4 2023 – 2024)

The war in Gaza (starting Oct 7, 2023) likely disrupted trade significantly.

• Consumer Sentiment: Snippets regarding other brands (McDonald’s, Starbucks) ³ show massive sales declines due to boycotts. Puma’s “Fewer-Bigger-Better” exit strategy was almost certainly validated by Q4 2023 sales data, which likely showed a collapse in the brand’s performance in markets sensitive to the Palestinian cause (Middle East, Southeast Asia).
• Logistics: The conflict has disrupted shipping lanes (Red Sea/Houthi attacks), increasing the cost of importing goods to Israel. This adds economic pressure on the Al Srad partnership, making the “luxury” market in Israel more volatile.

7.3 Contract Lifecycle

• Sponsorship: 2018 – Dec 31, 2024. Status: TERMINATING.
• Licensee (Al Srad): Started Jan 1, 2021. Commercial distribution contracts typically run for 3-5 years.
  • Forecast: The Al Srad contract is likely up for renewal or review in 2025/2026.
  • Audit Point: The auditor should monitor if Puma renews this exclusive license or moves to a non-exclusive model to further dilute its direct association with a single Israeli entity.

8. Complicity Scoring and Assessment

Based on the evidence gathered, we apply the “Economic Complicity Scale” to rank Puma’s involvement over time. The scale considers:

1. Directness: Is the company directly involved (e.g., owning a factory) or indirectly (e.g., licensing)?
2. Location: Are operations in the 1967 occupied territories?
3. Ideology: Does the company sponsor normalizing institutions?
4. Responsiveness: Has the company responded to human rights due diligence findings?

8.1 The Rubric

8.2 Puma SE Scoring History

Current Status (Q4 2025): Transitional (Moving to Low). The non-renewal of the IFA contract removes the primary mechanism of ideological support. The remaining complicity is limited to the retail operations of its licensee in East Jerusalem, a standard profile for many luxury/fashion brands (e.g., Zara, H&M, Louis Vuitton) operating in the region.

9. Second and Third-Order Insights

9.1 The “Compliance Wash” Phenomenon

The shift from Delta Galil to Al Srad serves as a textbook example of corporate “compliance washing.”

• Observation: Puma was under fire for using a manufacturer listed on the UN Human Rights Council’s database (Delta Galil).
• Action: They switched to Al Srad, a luxury retailer not on the list.
• Insight: While this removed the “UN List” stigma, it did not remove the presence in occupied territory (Mamilla Mall). It demonstrates how companies navigate “Red Lines” (UN lists) while ignoring “Grey Zones” (East Jerusalem annexation). This suggests Puma’s compliance team is reactive to explicit blacklists rather than proactive regarding the spirit of international humanitarian law.

9.2 The “Fewer-Bigger-Better” Cover

The “Fewer-Bigger-Better” strategy ¹ provides Puma with plausible deniability regarding the BDS boycott.

• Commercial Logic: Dropping Israel (Rank 75) and Serbia to focus on top-tier teams makes financial sense.
• Political Utility: It allows Puma to exit a toxic contract without admitting that the boycott worked. Admitting the boycott worked would invite pressure on other contracts (e.g., Morocco, Turkey).
• Insight: The strategy was likely a “Dual-Use” maneuver—financially sound and politically convenient. The timing of the announcement (during the war) betrays the political urgency concealed behind the commercial rationale.

9.3 The Contagion Effect on Competitors

Puma’s exit has created a “toxicity vacuum” for the IFA.

• Observation: Competitors like Erreà have engaged and then quickly withdrawn. Reebok is now facing pre-emptive boycott calls.²⁴
• Insight: Puma’s sustained “agony” under the BDS campaign (2018–2023) has served as a warning to the rest of the industry. The IFA asset has become “uninsurable” in terms of reputational risk. Puma’s exit has effectively devalued the IFA’s sponsorship equity to near zero.

10. Conclusion and Recommendations

10.1 Final Audit Determination

Puma SE has effectively executed a Strategic Withdrawal from its most controversial positions in the Israel-Palestine theater. The Company has successfully decoupled its supply chain from direct settlement manufacturing (Delta Galil exit) and has terminated its ideological support for the settlement enterprise (IFA exit).

However, the Company remains economically active in the Israeli market through its licensee, Al Srad Ltd. This licensee operates in the contested Mamilla Mall, maintaining a residual link to the occupation’s economic infrastructure.

10.2 Recommendations for Further Monitoring

1. Monitor the 2025 Transition: Verify that the IFA sponsorship logos are completely removed from all digital and physical assets by Q1 2025. Any lingering branding could reignite boycott calls.
2. Audit Al Srad’s Expansion: Watch for any expansion of “Factory 54” or Puma monobrand stores into the “deep” West Bank (e.g., Ariel Mall) under the current Israeli government’s settlement expansion drive.
3. Traceability Audit: Request data on “Nice Elite International Limited” to ensure no subcontracting has reverted to Israeli settlement factories.

Overall Verdict: Puma SE has significantly reduced its Economic Complicity profile. While not a “clean” break (due to the Al Srad/Mamilla connection), the termination of the IFA contract represents a material decoupling from the mechanisms of the occupation.

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