Audit Phase: V-MIL (Military Forensics)
Audit Date: 2026-05-01
Auditor Note: All findings are grounded exclusively in the research memo above. Claims marked as unverified or discarded in the memo are excluded from substantive findings. Evidence gaps are noted where relevant. No scores, tiers, or BRS/V-domain values are assigned.
AXA Group is an insurance and financial services conglomerate. It does not operate as a defence contractor, systems integrator, or equipment supplier in its own right, and no public evidence has been identified of any direct contract, tender award, framework agreement, or MOU between AXA Group (as a corporate entity) and the Israeli Ministry of Defence (IMOD), the Israel Defense Forces, the Israel Prison Service, or Israel Border Police.
The material finding in this domain is indirect, arising through AXA Venture Partners (AVP), AXA’s venture capital arm, which led a $5 million Series A funding round for Hub Security (subsequently rebranded HUB Cyber Security Ltd., NASDAQ: HUBC) in May 2020.12 The co-investors in that round included OurCrowd.2
Hub Security was co-founded by veterans publicly identified in the company’s own investor-facing materials as alumni of IDF Unit 8200 (signals intelligence and offensive cyber) and IDF Unit 81 (classified military technology research), giving the company a direct lineage from Israeli military intelligence infrastructure.12
The defence procurement nexus crystallised in September 2022, when Hub Security announced it had been awarded a tender by the Israeli Ministry of Defence valued at NIS 4.2 million (approximately $1.2 million USD at then-prevailing rates), covering Hub’s hardware and software products and services over a three-year period running from 2022 through 2025.3 This contract was therefore active and in its performance phase at the outbreak of the October 2023 conflict.
In October 2023, immediately following the outbreak of hostilities, Hub Security issued a public statement confirming its participation in strengthening Israel’s “digital defenses,” with the company’s CEO — publicly described as a retired IDF Major General — stating the firm was “committed to providing cutting-edge solutions to defend against cyber threats.”5
A critical confirmatory data point is furnished by SEC filings dated 30 September 2023, which list AVP Early Stage II S.L.P. (managed by AXA Venture Partners) as a beneficial owner of 8,785,035 shares of HUB Cyber Security, representing 8.94% of outstanding shares at that date.6 This establishes that AXA had not exited its position prior to the October 2023 escalation, and that the AVP stake was live and material at the time Hub Security was publicly engaged in Israel’s wartime cyber defence posture. AXA Venture Partners’ public portfolio page corroborates the active portfolio relationship.32
A subsequent procurement event is documented in late 2024 / early 2025, when Hub Security announced a further contract award — a NIS 16 million agreement (~$4.3–5 million USD) awarded by the Israeli Ministry of Interior to “enhance secure cyber and data protection capabilities in critical government environments.”433 The precise execution date of this contract, and whether it post-dates or pre-dates any potential AVP divestment or reduction of its Hub Security stake, has not been confirmed from a primary source and constitutes a material evidence gap. The full EDGAR filing history for Hub Security (CIK 1905660) is publicly accessible and should be reviewed for subsequent beneficial ownership disclosures.26
No public evidence has been identified of AXA Group appearing in SIBAT (Israel’s Defence Export & Defence Cooperation Directorate) listings, Israeli defence exhibition catalogues (e.g., ISDEF, Eurosatory Israeli exhibitor registries), or defence procurement registries in any jurisdiction.
AXA Group does not manufacture physical products of any kind; accordingly, no ruggedised, tactical, mil-spec, or defence-grade product lines exist under the AXA brand. The dual-use analysis in this domain therefore concerns exclusively AXA’s investee companies and the technology characteristics of those investments.
Hub Security — dual-use cybersecurity technology:
Hub Security’s core product lines — Hardware Security Modules (HSMs), Confidential Computing platforms, and encrypted data processing infrastructure — are explicitly marketed using the descriptor “military-grade” security.12 These are inherently dual-use technologies: they have documented civilian enterprise applications (financial sector data protection, cloud security) and, simultaneously, are supplied under the confirmed IMOD contract.3 The civilian and military end-use cases share identical technical platforms; no separate “tactical variant” manufacturing process has been identified, and the prior suggestion that Hub produces distinct military-specific product lines is not supported by available evidence. The products are commercial-off-the-shelf (COTS) security infrastructure with confirmed military end-users.
The company’s IDF Unit 8200 and Unit 81 heritage is relevant to dual-use classification: Unit 8200 is Israel’s primary signals intelligence and offensive cyber unit, analogous to the US NSA or UK GCHQ, and alumni-founded companies routinely develop technologies applicable across both commercial and state-security markets.12
Neura — behavioural AI / IoT (historical investee):
AXA Strategic Ventures (AXA’s corporate venture arm, distinct from AXA Venture Partners) led an $11 million Series A investment in Neura, an Israeli AI and IoT startup whose technology generates behavioural identity profiles by analysing smartphone and IoT sensor data to predict individual user behaviour patterns.1415 This investment was made approximately 2015–2016. Neura was subsequently acquired by Twilio in 2019, at which point it ceased to operate as an independent Israeli entity and the AXA investment relationship concluded. This is therefore a historical, closed exposure and does not represent an active dual-use risk. Claims in prior analysis characterising Neura as an ongoing active exposure or as having been adopted by Israeli security services for targeting purposes were not supported by verifiable evidence and are excluded from this audit’s findings.
Export control applicability:
Hub Security’s HSM and confidential computing products are subject to Israeli domestic export control regulations under the Defence Export Control Law (5766-2007, administered by SIBAT/DECA). No public evidence has been identified of third-country export licence applications, end-user certificate proceedings, or government export control reviews arising from AXA’s investment relationship with Hub Security or from any other AXA-linked investee’s supply to Israeli defence end-users. This gap should be addressed through targeted review of Israeli DECA public records and relevant third-country licensing authority records.
AXA Group does not manufacture, supply, or operate heavy machinery, construction equipment, or engineering vehicles. No public evidence has been identified of AXA Group holding direct contracts for construction, maintenance, servicing, or expansion of checkpoints, detention facilities, military bases, the separation barrier, or settlement-related physical infrastructure.
The material finding in this domain arises from AXA’s asset management arm’s investment in CAF (Construcciones y Auxiliar de Ferrocarriles), the Spanish rail and transport manufacturer.
CAF leads the TransJerusalem J-Net consortium (alongside Shapir Engineering) contracted to expand the Jerusalem Light Rail (JLR) Red Line and construct the Green Line. This infrastructure serves to link settlement neighbourhoods in East Jerusalem — including Pisgat Ze’ev, French Hill, and Neve Yaakov — with West Jerusalem, integrating occupied territory into Israeli municipal transport infrastructure in a manner assessed by multiple international legal bodies as facilitating and consolidating the occupation.1819
AXA’s position as an investor in CAF has been documented by the “Don’t Buy into Occupation” (DBIO) coalition, a research and advocacy consortium led by FIDH and CNCD-11.11.11.1819 The most recently published iteration, DBIO V (November 2025), continues to include this finding.18 The FIDH report from November 2022 provides earlier documentation of the same holding.19
The UN Special Rapporteur’s 2025 report on the “economy of occupation and genocide” (A/HRC/59/23, Francesca Albanese) addresses the role of infrastructure investment in sustaining the occupation economy, and the Law for Palestine database derived from this report encompasses entities in the infrastructure category relevant to this audit.2021
Evidential qualification: The precise quantum of AXA’s equity or debt exposure to CAF has not been verified from a primary AXA regulatory filing (e.g., AXA Investment Managers UCITS fund disclosures or AMF regulatory submissions). The DBIO/FIDH references confirm AXA’s investor status and CAF’s role in the JLR, but the specific holding size and the currency of AXA’s position as of the audit date requires confirmation from AXA IM’s primary fund disclosures. AXA’s relationship to the JLR project is that of an equity investor in CAF, not a direct engineering or construction contractor.
AXA Investment Managers — holdings in global defence and aerospace primes:
Research conducted by the BDS Movement’s “Stop AXA Assistance to Israeli Apartheid” coalition and the NGO Ekō, based on portfolio data as of 30 June 2024, reported AXA holding approximately $150.43 million across eleven companies identified as supplying weapons systems to Israel, comprising approximately $78.87 million in equity and $71.56 million in corporate bonds.7813 The companies named in this research include Boeing, Lockheed Martin, General Dynamics, RTX (Raytheon Technologies), BAE Systems, L3Harris, Rolls-Royce, and Northrop Grumman, among others.8
Evidential qualification: This figure originates from advocacy coalition research, not from AXA’s own regulatory filings or from a regulated primary financial data provider. AXA Investment Managers managed approximately €850+ billion in assets globally as of 2023–2024,27 a scale at which holdings in major US and UK defence primes through diversified equity indices and investment-grade bond mandates are routine and structurally expected. The $150.43 million figure is treated as partially verified — the category of holdings (positions in these named firms) is consistent with the known composition of large diversified asset managers, but the precise quantum has not been independently confirmed from AXA IM’s primary disclosures. Primary verification would require cross-reference against AXA IM’s published fund holdings, Form 13F filings (for US-domiciled assets), and UCITS transparency reports.
Elbit Systems — confirmed divestment:
Multiple independent sources, including the Ekō/Profundo research report of June 2024 and the Ireland Palestine Solidarity Campaign, confirm that AXA divested its holdings in Elbit Systems by approximately 2018–2019,71112 prior to the current conflict. This divestment is described in campaign documentation as having been secured following sustained pressure from the “Stop AXA” campaign.711 The August 2024 Middle East Monitor report confirms the completion of both the Israeli bank and Elbit divestments.12
AXA’s own Responsible Investment Policy documentation addresses exclusions for controversial weapons categories, primarily cluster munitions and anti-personnel mines.28 Whether any Israeli defence entities beyond Elbit Systems appear on AXA’s formal exclusion list, and whether that list was updated following October 2023, requires verification against AXA’s most current responsible investment policy publications.28
Joint development and co-production:
No public evidence has been identified of joint development programmes, co-production agreements, technology transfer arrangements, or licensed manufacturing agreements between AXA Group and any Israeli defence firm (including Elbit Systems, Israel Aerospace Industries, Rafael Advanced Defense Systems, or IMI Systems/Elbit Land).
AXA’s connection to strategic platforms (e.g., Iron Dome’s Tamir interceptor co-produced by RTX and Rafael; F-35 components supplied by multiple primes; Merkava components supplied by US firms) is exclusively an indirect investment relationship arising from AXA IM’s holdings in firms such as RTX and Lockheed Martin. AXA itself does not supply sub-systems, components, or materials to these platforms.
AXA does not operate as a catering, facilities management, fuel supply, transport, telecommunications, or logistics services provider. No public evidence has been identified of AXA Group holding contracts to provide support services of any kind to IDF bases, military training facilities, detention centres, or security installations.
AXA XL / Harel Insurance — Global Partner Network relationship:
AXA XL, AXA Group’s commercial property & casualty and specialty insurance arm, operates a multinational Global Partner Network through which locally licensed insurers act as fronting and network partners for cross-border programme clients. Harel Insurance Investments & Financial Services Ltd. — Israel’s second-largest general insurer16 — is identified in published materials as functioning in the capacity of AXA’s network partner / fronting insurer in Israel.1617
This commercial arrangement is a standard insurance industry mechanism and is documented in Harel’s publicly available investor relations materials.17 The terms of the AXA XL–Harel Global Partner agreement, including any territorial exclusions or policy-scope limitations relating to occupied territories or defence risks, are not available in the public record and constitute an evidence gap. Whether the arrangement extends to or is utilised in connection with any defence, settlement, or military-related insurance risks in Israel or the occupied territories is unknown from available public documentation.
Catastrophe bond / ILS market:
The prior analysis referenced AXA XL’s ILS Capital Management unit as a potential participant in the Turris Re catastrophe bond programme, which covers Israeli earthquake risk and is sponsored by Migdal Insurance. General Artemis.bm records document ILS market activity in Israel,2930 but specific confirmation of AXA XL’s participation as an investor in Turris Re tranches was not identified in available sources. This claim is unverified and is excluded from substantive findings. Primary bond prospectus or AXA XL disclosure documentation would be required for confirmation.
AXA Group is not a weapons manufacturer, prime contractor, ordnance producer, or licensed manufacturer of any lethal platform or sub-system. This domain section is structurally inapplicable to AXA’s direct corporate activities.
Munitions and precursor materials: No public evidence identified of AXA supplying ammunition, explosive ordnance, chemical propellants, warhead components, or munitions precursors to any end-user in any jurisdiction.
Strategic and existential defence systems: AXA does not design, manufacture, or integrate components for Iron Dome, David’s Sling, Arrow missile defence, combat aircraft, main battle tanks, warships, or ballistic missile systems.
Sub-system and critical component supply: No public evidence identified. AXA’s sole connection to strategic defence platforms is as a passive financial investor in global asset management funds and mandates that hold positions in companies — including RTX (Raytheon Technologies) and Lockheed Martin — which themselves supply or co-produce components for Israeli strategic platforms (e.g., RTX’s co-production of Iron Dome’s Tamir interceptor with Rafael Advanced Defense Systems).8 This is an indirect, multi-remove investment relationship. AXA does not itself supply, co-produce, or sub-contract any element of these platforms.
Hub Security — non-kinetic military capability: Hub Security’s confirmed IMOD-contracted products are cybersecurity infrastructure (HSMs, confidential computing), not munitions or weapons systems in any conventional sense.3 They are non-kinetic in character, though they support military digital operations.
Export licensing proceedings:
No public evidence has been identified of any government decision — in France, the United Kingdom, the European Union, the United States, or any other jurisdiction — to grant, deny, suspend, or revoke export licences specifically in connection with AXA Group’s investment activities, AXA XL’s insurance underwriting, or the products of AXA’s investee companies supplied to Israeli military or security end-users.
Hub Security’s HSM and confidential computing products, which are supplied under the confirmed IMOD contract,3 are subject to Israeli domestic export control regulation administered by SIBAT/DECA (Defence Export Control Agency). No evidence of third-country export licence applications or denials arising from this supply relationship, and no evidence of any end-user certificate controversy, was found in available sources.
Arms embargo and sanctions compliance:
No investigations, citations, enforcement actions, or compliance notices related to AXA’s adherence to arms embargoes, export control regimes, or sanctions affecting defence trade with Israel were identified in available public record. AXA’s activities in Israel fall within financial services and insurance, which are generally outside the scope of arms embargo instruments, though EU and national sanctions regimes affecting financial flows are applicable.
Regulatory compliance — French AMF / ACPR:
AXA is dually regulated in France by the ACPR (Autorité de contrôle prudentiel et de résolution) and the AMF (Autorité des marchés financiers). Whether either regulator has reviewed, queried, or acted upon AXA’s defence-linked investment holdings or its investee companies’ relationships with Israeli defence entities has not been identified in available public record. AXA’s Universal Registration Document (DEU) filed annually with the AMF provides the primary vehicle for ESG and responsible investment disclosures.27
Legal challenges and judicial review:
No court proceedings, judicial reviews, or legal challenges brought against AXA, or brought against any government in connection with AXA’s defence supply or investment activities relating to Israel, were identified in available sources. Source classes examined include UK High Court records, French administrative courts (Conseil d’État, tribunaux administratifs), EU Court of Justice records, and ICC/ICJ public dockets — all via training knowledge.
AXA’s ESG exclusion framework:
AXA’s publicly disclosed Responsible Investment Policy incorporates exclusions for controversial weapons, with documented coverage of cluster munitions, anti-personnel mines, biological and chemical weapons, and nuclear weapons outside the NPT framework.28 No public documentation confirms that Israeli defence entities beyond Elbit Systems are included on AXA’s exclusion list, nor that any formal policy update addressing the post-October 2023 conflict environment has been adopted. The Ekō/Profundo research assessed that AXA’s divestment from Israeli banks and Elbit represents a de facto portfolio decision rather than a codified ESG exclusion policy update.10
Organised campaigns:
The “Stop AXA” campaign — coordinated by a coalition including the BDS Movement, Ekō, the Ireland Palestine Solidarity Campaign (IPSC), and associated national affiliates — has operated as an organised, multi-year campaign specifically targeting AXA since approximately 2016–2017, initially focusing on AXA’s holdings in Israeli banks, subsequently broadening to Elbit Systems, and latterly to US and UK defence prime holdings.7
The BDS Movement maintains dedicated campaign infrastructure for AXA, including a campaign hub page7 and a specific research report published in 2024 alleging AXA’s complicity in financing weapons manufacturers supplying the Gaza conflict.813 The Madison-Rafah Sister City Project has similarly publicised campaign achievements in relation to AXA divestments.22 AXA appears on Ethical Consumer’s published boycotts list in connection with this campaign.23
NGO and academic reports:
Ekō / Profundo (June 2024): An independently commissioned research report confirmed AXA’s divestment from all five major Israeli banks (Bank Hapoalim, Bank Leumi, Mizrahi Tefahot, Israel Discount Bank, First International Bank of Israel) and from Elbit Systems, while documenting continued holdings in US and UK defence primes and providing specific holding values.910 Refinitiv data examined in that report found only a trace residual (~$130,000) in Bank Leumi, attributed to reporting lag rather than active holding.10
FIDH / CNCD “Don’t Buy into Occupation” (DBIO) series: The DBIO report series, co-published by FIDH and CNCD-11.11.11 across multiple iterations from 2019 through 2025, has named AXA in the context of investment in companies operating in or financing the occupation, including CAF (Jerusalem Light Rail) and Israeli financial institutions.181931 The most recent published edition, DBIO V (November 2025), continues this documentation.18
UN Special Rapporteur, A/HRC/59/23 (2025): The report by Special Rapporteur Francesca Albanese on the “economy of occupation and genocide” addresses the role of financial institutions and investors in sustaining the occupation economy.21 The Law for Palestine database derived from this report includes companies in sectors where AXA holds investments.2021 Whether AXA is itself named directly in the body of the Special Rapporteur’s report requires verification against the primary text.
APAN / Australian advocacy (2023): AXA was referenced in the Australian Palestinian Advocacy Network’s submission to the Australian government’s feasibility study on trade and investment with Israel, conducted by DFAT.24
Who Profits: No specific Who Profits company profile for AXA Group was identified in available sources. Who Profits primarily profiles companies with direct operational presence in occupied territories; AXA, as a financial investor, does not appear to have generated a dedicated Who Profits entry.
Business & Human Rights Resource Centre: BHRRC has published documentation on Israeli banks financing illegal settlements, relevant to AXA’s now-divested banking holdings.25
European Council on Foreign Relations (ECFR) Differentiation Tracker: Tracks EU member state and institutional differentiation policies regarding settlement-linked entities; provides regulatory context for AXA’s operating environment in European markets.34
AXA’s documented responses:
At AXA’s April 2024 Annual General Meeting, Group CEO Thomas Buberl publicly stated the group held “zero investments in Israeli banks, direct or indirect.”911 This statement was subsequently corroborated by the Ekō/Profundo independent research.910
The confirmation of the full Israeli bank and Elbit divestment was reported across multiple advocacy and media outlets in August 2024.1222 The IPSC characterised this as a “huge victory” for the Palestine solidarity movement.11
AXA has not adopted a formal written policy prohibiting investment in Israeli banks, settlement-linked entities, or Israeli defence-related companies as a category, according to campaign assessments of its responsible investment framework.10 The divestment from Israeli banks and Elbit appears to be a de facto portfolio decision. No public policy statement or corporate commitment specifically addressing AXA’s continued holdings in US and UK defence primes in the context of the Gaza conflict has been identified as of the audit date.28
The “Stop AXA” campaign’s publicly stated remaining demands concern AXA’s holdings in US and UK arms manufacturers supplying Israel, and the absence of a codified exclusion policy for Israeli defence and settlement-linked entities.78
https://www.prnewswire.com/news-releases/axa-ventures-leads-5-million-investment-in-next-generation-cybersecurity-startup-hub-security-301054886.html ↩↩↩↩
https://en.globes.co.il/en/article-military-grade-cybersecurity-co-hub-security-raises-5m-1001328045 ↩↩↩↩↩
https://investors.hubsecurity.com/news-releases/news-release-details/hub-security-wins-nis-42-million-tender-israeli-department ↩↩↩↩
https://investors.hubsecurity.com/news-releases/news-release-details/hub-cyber-security-awarded-nis-16-million-government-contract ↩
https://www.nasdaq.com/press-release/hub-cyber-security-ltd.-participates-in-strengthening-israels-digital-defenses-amidst ↩
https://www.sec.gov/Archives/edgar/data/1905660/000101376223002062/ea186345ex99-1_hubcyber.htm ↩
https://bdsmovement.net/AXA-Bankrolling-Weapons-Manufacturers-Facilitating-Gaza-Genocide ↩↩↩↩↩
https://www.eko.org/media/axa-divests-from-israeli-banks-financing-war-crimes-against-palestinians ↩↩↩
https://aks3.eko.org/images/AXA_investments_Israeli_banks_report_2024.pdf ↩↩↩↩↩
https://www.middleeastmonitor.com/20240821-axa-insurance-firm-completes-divestment-from-israel-banks-arms-manufacturers/ ↩↩↩
https://bdsmovement.net/news/new-report-french-insurer-axa-complicit-israel%E2%80%99s-war-crimes ↩↩
https://www.axa.com/en/press/press-releases/ventures-digital-investment ↩
https://en.globes.co.il/en/article-israeli-iot-startup-neura-raises-11m-1001096360 ↩
http://www.igudbit.org.il/eng/?CategoryID=420&ArticleID=435 ↩↩
https://www.harel-group.co.il/investor-relations/DocLib/BDI_Harel_Hashkaot_Bituach_eng_2017.pdf ↩↩
https://www.fidh.org/IMG/pdf/2022_11_29_dbio-report-def_2-1-1.pdf ↩↩↩↩
https://law4palestine.org/wp-content/uploads/2025/08/Database-of-Companies-Named-in-the-UN-Special-Rapporteurs-Report-on-the-Economy-of-Occupation-and-Genocide.pdf ↩↩
https://www.un.org/unispal/document/a-hrc-59-23-from-economy-of-occupation-to-economy-of-genocide-report-special-rapporteur-francesca-albanese-palestine-2025/ ↩↩↩
https://madisonrafah.org/activists-force-axa-to-divest-from-all-israeli-banks/ ↩↩
https://www.ethicalconsumer.org/ethicalcampaigns/boycotts ↩
https://www.dfat.gov.au/sites/default/files/feasibility-study-israel-submissions-apan.pdf ↩
https://www.business-humanrights.org/en/latest-news/israeli-banks-involved-in-financing-illegal-settlements-in-palestine-who-profits-report/ ↩
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=1905660&type=20-F&dateb=&owner=include&count=40 ↩
https://www.axa.com/en/investor/publications/universal-registration-document ↩↩
https://www.axa.com/en/responsibility/our-commitments/responsible-investment ↩↩↩↩
https://www.artemis.bm/news/stone-ridge-ils-reinsurance-funds-pass-3b-interval-hits-1-66b/ ↩
https://www.artemis.bm/news/insurance-linked-investment/page/92/ ↩
https://www.fidh.org/en/region/north-africa-middle-east/israel-palestine/ ↩
https://www.axavp.com/portfolio/ ↩
https://www.moomoo.com/news/post/63436141/hub-cyber-security-ltd-secures-nis-16-million-government-contract ↩
https://ecfr.eu/special/differentiation-tracker/ ↩
