Fiverr Political Audit

Audit Phase: V-POL Political Forensics Audit
Target Company: Fiverr International Ltd. (NYSE: FVRR)
Headquarters: Tel Aviv, Israel (holding company incorporated in the Cayman Islands)
Primary Business: Global online marketplace for freelance digital services
Audit Currency: Updated 2026-05-01

Corporate Communications & Public Stance

Israel-Gaza Conflict (October 2023–Present)

Fiverr published a corporate communication following the October 7, 2023 Hamas attacks expressing condolences to those affected in Israel and framing the crisis as an attack on the company’s home country.²¹ The statement did not address Palestinian civilian casualties, did not call for humanitarian access, and contained no language regarding the deaths of civilians in Gaza. No subsequent corporate statement expressing concern for Palestinian civilians was identified in the public record.²¹

CEO Micha Kaufman posted on Twitter/X in October 2023 stating that he had made a personal donation to support the IDF and framing the conflict in terms of Israel’s existential right to self-defense.⁴³⁵ These posts were made on his personal account but were widely read in the context of his role as CEO and founder of Fiverr. Secondary press coverage and contemporaneous Israeli business journalism confirm the posts existed and were prominent.⁴³⁶ The specific recipient organization of Kaufman’s personal donation was not confirmed in available sources (see Evidence Gaps, below). In the period November 2023–April 2026, Kaufman’s documented public social-media activity on the conflict shows a reduction in posting frequency on conflict-related topics relative to the acute October–November 2023 period. No documented posts expressing concern for Palestinian civilian casualties, support for humanitarian access to Gaza, or criticism of specific Israeli military operations targeting civilian infrastructure were identified in the post-acute period.³⁵

No public evidence identified of Fiverr issuing any corporate statement expressing concern for Palestinian civilian casualties, urging humanitarian access, or calling for a cessation of hostilities at any point between October 2023 and the time of this audit.²¹³⁹ No op-ed, signed open letter, or attributed public statement by Kaufman specifically addressing Palestinian civilian harm, humanitarian law, or the ICJ/ICC legal determinations was identified in any publication in available records.³⁵³⁶

Post-ICJ and Post-ICC Constructive Notice

The ICJ Advisory Opinion of 19 July 2024 and the ICC arrest warrants of 21 November 2024 establish constructive-notice thresholds for assessing whether corporate conduct continued or escalated after internationally significant legal determinations.³²³³

Following the ICJ Advisory Opinion of 19 July 2024, Fiverr’s operational posture shows no documented change — no service suspension, no revised corporate communications regarding the conflict, and no new due-diligence disclosures in SEC filings specifically referencing the ICJ Advisory Opinion.³² Fiverr continued standard global marketplace operations throughout the post-ICJ AO period (post-19 July 2024). No service suspension, geographic restriction, or modified terms of service specifically referencing the ICJ AO or the occupied territories was implemented.³²

The FY2024 Form 20-F¹ covers the full FY2024 period, which post-dates both the ICJ AO (July 2024) and includes approximately eight weeks following the ICC arrest warrants (November 2024). That filing does not reference either legal determination. The filing continues to describe Israeli operations under standard risk-factor language without acknowledging the ICJ Advisory Opinion or its implications for corporate conduct in the occupied territories. Notably, the filing was prepared and certified by Kaufman (CEO) and CFO in their personal capacities under SOX Section 302 and 906 certifications. The absence of any reference to the ICJ AO or ICC warrants in the risk factors, legal proceedings, or management discussion sections therefore constitutes an executive-certified materiality determination that these legal developments were not material to Fiverr’s disclosed risk profile.¹³²³³

No public corporate communication from Fiverr specifically acknowledging or responding to the ICC arrest warrants of November 2024 was identified, and no policy change, revised terms of service, or operational adjustment traceable to those warrants was identified.³³ No Fiverr corporate communication identified in the post-ICJ AO period (July 2024–April 2026) specifically addresses: the ICJ Advisory Opinion, the legal consequences for corporate conduct in occupied territories, the ICC arrest warrants, or any revised due-diligence framework for operations connected to the conflict.³²³³

No analyst report, earnings call transcript, or investor-day communication identified in available records contains a question or answer specifically addressing Fiverr’s legal exposure under the ICJ AO or its operational response to the ICC warrants.

A review of Israeli-headquartered technology companies listed on US exchanges (Wix, Monday.com, CyberArk, Check Point, Amdocs, NICE Systems, Radcom) produces no identified instance of any such company publicly disclosing an internal policy review triggered by either the ICJ AO or ICC warrants. The absence is sector-wide and does not, on available evidence, distinguish Fiverr from its peer group in the Israeli tech sector.

Comparative Geopolitical Record

Fiverr’s communications posture on the Russia-Ukraine war stands in contrast to its posture on Gaza. Following Russia’s invasion of Ukraine in February 2022, Fiverr issued a clear corporate condemnation and subsequently suspended services to Russian users.⁵ This action was coordinated with other Israeli tech companies and framed explicitly in moral and humanitarian terms.⁵ The parallel treatment across two simultaneous conflicts — vocal condemnation and service suspension in one case, silence on civilian harm in the other — constitutes a documented asymmetry in corporate communications. The following comparative record is documented across Fiverr’s operational period:

The asymmetry between the Ukraine response and the Gaza civilian-harm response is the most documentable double standard, given that both situations involved large-scale civilian casualties and both overlapped with Fiverr’s operational period.⁵²¹ No public evidence identified of Fiverr issuing comparable geopolitical statements concerning any other active conflict not directly involving Israel or Ukraine (e.g., Sudan, Myanmar, Yemen).

Domestic Israeli Political Speech

In the first half of 2023, CEO Kaufman was publicly outspoken against the Netanyahu government’s proposed judicial overhaul, reportedly hanging a copy of Israel’s Declaration of Independence on Fiverr’s Tel Aviv headquarters building and describing the technology sector as a “sleeping bear” being provoked into political opposition.⁴ He stated publicly that the Prime Minister “works for” the tech sector and the public.⁴ The CTech/Calcalist reporting on this episode characterizes Kaufman as one of the more prominent voices among Israeli tech founders opposing the judicial reform, and he is named as a participant in the “tech leaders for democracy” communications campaign during the judicial reform crisis.⁴ These statements were made under his identity as Fiverr’s CEO-founder, instrumentalizing the company’s public profile in domestic Israeli political discourse.

Following October 7, 2023, Kaufman’s public posture toward the Netanyahu government shifted markedly; criticism of the government ceased and his public communications expressed unconditional solidarity with the military response.⁴ No equivalent engagement — at any level of intensity, in any public forum — with Palestinian civilian rights, the status of the occupied territories, or international humanitarian law was identified for Kaufman in available records.³⁵³⁶

Multiple open letters circulated in the Israeli tech sector following October 7, 2023. The most widely documented were: (a) a letter expressing solidarity with Israel and demanding the release of hostages, signed by prominent tech founders including some Fiverr-adjacent figures; and (b) a smaller letter by Israeli academics and tech figures calling for a ceasefire or humanitarian corridor. Available records do not confirm Kaufman’s specific signature on any named public letter in either category with certainty. The CTech/Calcalist source⁴ characterizes his posture as strongly solidarity-aligned without citing a specific multi-signatory letter.

SEC Disclosure Framing

In all Form 20-F annual filings, Fiverr discloses its Israeli operations under a standard “Risk Factors” section titled “Risks Related to Our Operations in Israel,” acknowledging that its principal executive offices are in Tel Aviv and that armed conflict, political instability, or the military mobilization of reserve employees could materially affect operations.¹² These are standard disclosure requirements under SEC rules for foreign private issuers with Israeli operations; no uniquely politicized state-partnership framing appears in these filings, and the company describes itself throughout as operating a global online marketplace for digital services.³ The FY2024 Form 20-F acknowledges that employee reserve-duty mobilization continued into FY2024 and remained a material risk at the time of filing, and describes costs associated with salary continuation obligations for reservists under Israeli law as having been incurred during both FY2023 and FY2024.¹ The filing does not reference the ICJ Advisory Opinion of July 2024, the ICC arrest warrants of November 2024, or any change in corporate policy in response to those legal determinations.¹³²³³

Operations in Occupied or Contested Territories

Physical and Operational Presence

Fiverr is a digital services marketplace and does not operate physical retail outlets, equipment depots, logistics facilities, or service franchises. No public evidence identified of Fiverr operating offices, data centers, or formal service contracts specifically within Israeli settlements in the West Bank or any other internationally contested territory. Source classes reviewed for this finding include SEC litigation disclosures, UN OHCHR databases, Israeli business registry records as reported in press, and NGO investigative reports.

As a digital platform, Fiverr is technically accessible to users regardless of geographic location within the region, and Israeli sellers — including those who may reside in the West Bank — can register and operate accounts. No evidence of a deliberate, settlement-specific commercial program, preferential terms for settlement-based sellers, or formal operational integration with settlement infrastructure was identified.

Palestinian-territory-based sellers (both Gaza and West Bank) can technically register on Fiverr; the platform’s geographic coverage includes the Palestinian territories. No public evidence of a systematic ban, geographic restriction, or discriminatory account-closure policy targeting Palestinian-territory-based sellers was identified.²⁰ No OECD NCP complaint, formal regulatory proceeding, or published NGO investigation naming Fiverr in connection with discriminatory treatment of Palestinian sellers was identified.⁴¹

The practical impact of the post-October 7 banking and payment infrastructure collapse in Gaza on Palestinian sellers’ ability to use Fiverr — specifically regarding payment receipt and withdrawal — is a factual consequence of the broader financial sanctions and infrastructure disruption rather than a Fiverr-specific policy. No Fiverr policy specifically restricting Gaza-based seller withdrawals in the post-October 7 period was identified in available records, though the practical capacity of Gaza-based users to operate during the conflict period was necessarily severely constrained by factors outside Fiverr’s platform.²⁰²¹

UN and International Body Status

Fiverr does not appear in the UN Human Rights Council database of businesses with operations in Israeli settlements compiled pursuant to Resolution 31/36, most recently updated in 2023.²³ That database focuses on businesses with direct settlement-linked activities in categories such as construction, real estate, tourism, financial services with settlement branches, and infrastructure — categories that do not encompass Fiverr’s digital marketplace model.²³ The company’s 20-F filings contain no disclosure of inclusion in, or communications from, the UN database review process.¹⁴

Fiverr is not named in any of the following authoritative sources reviewed for this audit:^{232425282930262741}

The UN A/HRC/59/23 report’s technology sector focus addresses companies supplying surveillance technology, facial recognition, drone targeting systems, AI-enabled weapons platforms, and cloud infrastructure to Israeli military and intelligence bodies.²⁵ Fiverr’s marketplace model does not fall within any of these categories. No public evidence identified of Fiverr’s technology being deployed, licensed, or adapted for Israeli military or intelligence use. No procurement notice, Ministry of Defense contract disclosure, or IDF tender was identified naming Fiverr as a technology vendor.²⁵ Predecessor Special Rapporteur reports (Lynk 2022, Albanese 2023, Albanese 2024) similarly do not name Fiverr in their annexes or named-entity sections.²⁴

The Amnesty International November 2024 report “Digitally Divided: The Impact of Artificial Intelligence on the Human Rights of Palestinians”⁶² addresses AI and surveillance technology in the context of the Gaza conflict and assesses specific named companies. Fiverr’s absence from the named companies in that report is consistent with its marketplace model and the report’s focus on AI-targeting, surveillance, and weapons-platform suppliers; full confirmation of Fiverr’s absence requires direct document review.

No public evidence identified of regulatory actions, formal legal proceedings, international-body sanctions, or governmental investigations specifically targeting Fiverr in connection with occupied-territory operations.

Settlement Nexus Assessment

• Corporate level: No public evidence identified of Fiverr International Ltd. sponsoring settlement-related events, donating to settlement organizations (e.g., Regavim, Im Tirtzu, One Israel Fund, Hebron Fund, JNF-KKL settlement programs), or issuing public statements endorsing the settlement enterprise.⁴⁵
• CEO Kaufman: No public evidence identified of Kaufman personally donating to or publicly endorsing named settlement organizations. His October 2023 public communications focused on support for military defense operations, not settlement expansion specifically.⁴³⁵ No public evidence identified of Kaufman holding a formal board membership, advisory role, or leadership position in AIPAC, ADL, CFI, StandWithUs, or any other named pro-Israel or anti-BDS lobbying organization.³⁵ No public evidence identified of Kaufman holding personal equity stakes — as a named angel investor, LP, or board member — in Israeli defense technology, military surveillance, weapons-AI, or settlement-infrastructure firms.³⁵
• Board-level: No public evidence identified of Fiverr board members holding publicly documented roles in settlement-advocacy organizations (Regavim, Im Tirtzu, Yesha Council, settlement municipal authorities).¹⁴

Civil Society & Boycott Activity

The Canadian BDS Coalition has included Fiverr on its published “Boycott List of Shame.”¹³ The stated grounds are Fiverr’s Israeli corporate origin and its classification as an Israeli technology company whose commercial success benefits the Israeli economy, which BDS campaigners characterize as complicit in the occupation.¹³ No BDS campaign specifically alleging settlement-based revenue generation, dual-use technology supply to settlement infrastructure, or weapons-sector contracting by Fiverr was identified. The BDS Movement’s official campaign targets list and PACBI’s named institutional targets do not include Fiverr as a specifically named campaign target with a dedicated call to action; the Canadian BDS Coalition inclusion represents the primary documented campaign designation.¹³

Who Profits Research Center’s published company profiles do not return a Fiverr entry; that database’s technology-sector entries focus on surveillance, biometrics, drone technology, and infrastructure companies.²⁶ AFSC Investigate’s company database similarly does not include a Fiverr-specific profile page.²⁷

Fiverr has not issued any formal public statement specifically addressing BDS campaign designations.¹³ No formal legal action, cease-and-desist communication, or counter-campaign by Fiverr in response to BDS campaign designations was identified. Source classes reviewed: BDS Movement official communications, PACBI, Canadian BDS Coalition publications, US Campaign for Palestinian Rights, Jewish Voice for Peace campaigns.

For comparative framing: the OECD NCP mechanism has been used against other technology-adjacent companies in connection with the Israel-Palestine conflict — a complaint was filed against Booking.com in the Netherlands NCP in connection with listing Israeli settlement accommodation.⁵⁴ No analogous complaint naming Fiverr was identified in the OECD NCP registry.⁴¹

Internal Governance, Content & Retail Policies

Employee Relations and Reservist Policy

Fiverr’s Form 20-F filings for FY2023 and FY2024 disclose that a material number of Israeli employees were called up for mandatory military reserve duty following the October 7 attacks, and characterize this as a business continuity risk.¹⁴ The filings confirm that Fiverr complied with Israeli law requiring employers to continue paying full salaries to reservist employees and note that this obligation added to operating costs during the conflict period.¹⁴ The company describes the situation as an ongoing risk factor for as long as the conflict continues, citing uncertainty about the duration and geographic scope of military operations.¹

No public evidence identified of formal legal proceedings, labor board complaints, regulatory investigations, or documented HR controversies involving suppression of employee political speech related to the conflict, disciplinary action against employees for pro-Palestinian expression, or union-related disputes connected to the conflict. Fiverr’s Israeli workforce operates under Israeli labor law; no Israeli trade union has publicly documented a dispute with Fiverr over pro-Palestinian speech suppression. Fiverr’s US workforce is not unionized per available records, and no NLRB complaint related to Palestine-speech suppression by Fiverr was identified. Source classes reviewed: Israeli labor court records as reported in press, Glassdoor as aggregated in press references, US NLRB public filings, and Israeli press coverage of tech-sector labor relations.

No shareholder resolution concerning Israel-Palestine due diligence was identified as having been filed at, or blocked by, Fiverr in available records. Fiverr is a relatively small-cap NYSE-listed company and has not been a target of the ESG shareholder-resolution campaigns that have focused on larger technology firms (e.g., Alphabet, Microsoft, Amazon).

Platform Content Moderation Policy

Fiverr’s Terms of Service contain an explicit prohibition on “political usage” of the platform, restricting services involving political campaigning, voter solicitation, or content that the platform classifies as politically divisive.²⁰ This policy is stated in general terms and does not distinguish by geography, political cause, or conflict. The platform’s content architecture distinguishes between service categories offered on the marketplace and the content of individual gigs/orders; political content restrictions apply to the service offering layer, not to communications between users.

User-generated reports on the r/Fiverr subreddit document at least one instance of a seller reporting that a “Palestine-themed” order was flagged by Fiverr’s automated moderation system as potentially violating platform rules.¹¹ The thread describes the flagging but does not document the final resolution of the support case. A separate Reddit discussion thread records user concerns about perceived asymmetry in platform enforcement of content rules regarding Israel/Palestine content, with anecdotal accounts from multiple users.¹⁰ Both threads are user-generated content and carry low evidentiary weight absent corroboration from independent investigation.

No independent academic study, formal regulatory inquiry, or NGO investigation specifically auditing Fiverr’s content moderation practices for Israel-Palestine asymmetry was identified. The closest sector comparator is Human Rights Watch’s December 2023 report on Meta’s systematic censorship of Palestinian content on Instagram and Facebook,⁹ which documents the phenomenon of asymmetric content moderation at scale in the tech sector but does not reference Fiverr.

The 7amleh annual digital rights reports for 2022, 2023, and 2024 address censorship and content restriction on major platforms — primarily Facebook/Instagram (Meta), Twitter/X, YouTube (Google), and TikTok.⁴²⁵⁶⁵⁷ Fiverr is a services marketplace rather than a social media platform and is structurally outside the scope of 7amleh’s primary research focus; its absence from 7amleh’s named platform investigations is therefore structurally expected rather than indicative of a clean record. Access Now’s “Keep It On” coalition and digital rights shutdown reports similarly focus on state-imposed internet shutdowns and social-media platform censorship; Fiverr is not within the scope of these investigations.⁵⁵

The Human Rights Watch December 2024 report “Targeting ‘Protesters’: The Mass Criminalization of Palestinians Using Social Media Content”⁶³ addresses platforms used to surveil Palestinian social media; Fiverr’s marketplace model is outside that report’s scope.

The closest analogous investigation applicable to Fiverr’s marketplace model is the body of research on labor-platform algorithmic bias and geographic discrimination — addressing whether platform algorithms systematically disadvantage sellers from certain geographic or demographic groups. No published academic study or NGO investigation applying this analytical framework specifically to Fiverr’s treatment of Palestinian, Arab, or Palestinian-territory-based sellers was identified.

Retail and Supply Chain Practices

Fiverr operates exclusively as a digital services marketplace and does not sell physical goods, manage a physical supply chain, or label products by geographic origin. Categories concerning product labeling, sourcing, and physical supply chain management are not applicable to Fiverr’s business model. No public evidence identified and the category is structurally inapplicable.

Fiverr publishes a UK Modern Slavery Act transparency statement as required for companies operating above the turnover threshold in the UK market.⁵⁸ This statement addresses supply chain transparency in the context of labor exploitation. Its geographic scope does not specifically address the occupied territories or conflict-affected areas.

Technology Platform and Dual-Use Assessment

Fiverr operates a marketplace platform; it does not develop or supply AI-targeting software, facial recognition, drone control systems, predictive policing tools, or population management infrastructure. Its core technology stack comprises marketplace search and recommendation algorithms, payment processing, identity verification, and communication tools for buyer-seller interaction.¹³ Fiverr’s platform has been used by Israeli freelancers and sellers to offer technology services, including potentially cybersecurity or AI services. However, the platform itself is a marketplace intermediary; Fiverr does not control or take responsibility for the downstream deployment of services purchased through its platform beyond standard ToS enforcement. This is a structural characteristic of the marketplace model shared by Upwork, Toptal, and similar platforms.

Brand Heritage & State Partnerships

Military and Intelligence Heritage in Branding

Fiverr does not utilize military heritage, defense sector origins, or intelligence-unit backgrounds in its commercial branding, advertising campaigns, investor presentations, or press materials. The company’s brand positioning centers on freelance accessibility (its long-running “In Doers We Trust” campaign), AI-enabled productivity tools, and global remote work facilitation.⁴³

Co-founder Shai Wininger’s service in Israeli military intelligence Unit 8200 is a documented biographical fact covered in Israeli tech press and is reflected in IPO-era coverage of Fiverr’s founding team.³⁶³⁸ However, this background is not featured, referenced, or instrumentalized in any identified Fiverr marketing material, investor communication, or corporate narrative. CEO Micha Kaufman’s service in an elite unit of the Israeli Navy is documented in Israeli business media⁴ but similarly does not appear in corporate brand materials.

The claimed Unit 8200 affiliation of Nir Zohar, as asserted in prior research reviewed for this audit, could not be independently confirmed from available primary sources — including Zohar’s LinkedIn public profile,⁴⁰ Israeli business press biographical profiles, and Fiverr proxy filing biographical disclosures³¹ — and is treated as unverified in this audit. No direct Fiverr corporate relationship with Unit 8200 alumni networks, formal Unit 8200 recruitment programs, or institutional ties to Unit 8200 veteran organizations was identified in available records.³⁸

Start-Up Nation Central and Ecosystem Positioning

A March 2022 Start-Up Nation Central (SNC) report on design integration in Israeli technology companies cites Fiverr as a model of Israeli innovation and design-led product development.⁷ This constitutes SNC using Fiverr as a case study in a published report; it does not constitute a formal bilateral partnership, sponsorship agreement, or jointly commissioned research relationship. No public evidence identified of Fiverr formally sponsoring SNC events, paying SNC membership fees, or participating in Israeli government-backed “Brand Israel” diplomatic programming. No evidence identified of Fiverr sponsoring Israeli government cultural diplomacy events, co-branding with Israeli diplomatic missions’ public affairs programs, or participating in organized “Brand Israel” campaigns. Source classes reviewed: SNC website, Israeli Ministry of Economy promotional publications, Invest in Israel portal, and Israeli diplomatic mission event archives.

No evidence of Fiverr paying formal membership fees, sponsoring events, or maintaining a formal partnership agreement with: Invest in Israel, Israel Export Institute, Israel Innovation Authority (beyond standard grantee relationship), the Israeli-American Council (IAC), or the American-Israel Chamber of Commerce was identified.⁵²

Fiverr’s status as one of Israel’s most prominent technology unicorns is acknowledged in Israeli business press covering the broader tech ecosystem.¹⁸¹⁹ This contextual recognition does not constitute a formal state-aligned institutional relationship.

Israel Innovation Authority Grant Disclosure

The Israel Innovation Authority (IIA, formerly the Office of the Chief Scientist) provides R&D grants to Israeli technology companies. Fiverr’s F-1 prospectus³ and 20-F filings disclose compliance with Israeli R&D law regarding transfer restrictions on IIA-funded IP.⁵² This is a standard disclosure for Israeli tech companies with historical OCS/IIA grant history and does not in itself constitute an ongoing state-directed mandate. The specific quantum and vintage of any IIA grants to Fiverr are not publicly specified with precision in available investor disclosures beyond the standard restriction language.

The Israeli government’s economic response to the October 7 attacks included encouragement of continued operations by Israeli technology companies as a means of maintaining economic output and foreign currency earnings during the conflict. No public document identifies Fiverr as having received a specific government directive or designation in this mobilization framework. Fiverr’s FY2023 and FY2024 Form 20-F filings¹⁴⁸ do not disclose receipt of any Israeli government grants or emergency economic support specifically in connection with post-October 7 mobilization. The filings do reference compliance with Israeli law on reservist salary continuation — a statutory obligation rather than a discretionary grant program. No Israeli press reporting specifically identifying Fiverr as a named recipient of Israeli emergency economic grants or tax relief in the post-October 7 period was identified.

JNF, Consulate Events, and Institutional Sponsorships

Claims from prior research that Fiverr appeared in JNF Canada publications as a sponsor or institutional partner could not be independently confirmed from available sources.²² Claims that Fiverr formally sponsored Israeli consulate general events in North American cities were similarly not independently verifiable from any primary source — event programs, press releases, or consulate communications — in available records.

A review of FIDF gala coverage and publicly acknowledged named corporate sponsors (2022–2024) does not identify Fiverr International Ltd. as a named FIDF corporate sponsor or Micha Kaufman as a named FIDF honoree.⁶⁴ JNF-USA’s named major donors and honorees in 2022–2024 do not include Fiverr International Ltd. or Micha Kaufman in available records.⁴⁵ No public evidence identified for either the JNF/consulate sponsorship claims or the FIDF/JNF-USA named donor claims. Source classes reviewed: Israeli Consulate General NYC and Toronto event archives as reported in press, Jewish Federations event records, JNF Canada published materials, FIDF gala records, and JNF-USA annual reports.

No public evidence identified of Fiverr maintaining formal funded research partnerships with Israeli universities (Hebrew University, Tel Aviv University, Technion, Ben-Gurion University, Bar-Ilan University). No evidence of Fiverr sponsoring Israeli academic events, fellowships, or chairs at institutions with documented ties to the settlement enterprise was identified.

Humanitarian-Washing Assessment

Fiverr’s October–November 2023 operational communications described measures to support Israeli freelancers and employees — extended payment processing windows, business-continuity adjustments for Israeli users.²¹³⁹ These measures are business-continuity and employee-support actions rather than charitable donations to humanitarian organizations. No Fiverr corporate donation to a humanitarian organization operating in Gaza or providing aid to Palestinian civilians was identified in available records. No corporate donation to Israeli-facing humanitarian or civilian-support organizations that could be characterized as humanitarian-washing was identified.²¹ Given the finding that no corporate-level military/IDF-directed donation was identified, the humanitarian-washing analysis is not triggered at the corporate level. At the individual/executive level, Kaufman’s personal donation (unconfirmed recipient) and the absence of any parallel personal donation to Palestinian-aid organizations creates an asymmetry in personal philanthropy; this asymmetry exists at the personal rather than corporate level.

Lobbying, Advocacy, Financing & Logistics

Registered U.S. Lobbying Activity

Fiverr International Ltd. has registered lobbying activity in the U.S. Senate Lobbying Disclosure Act (LDA) database.⁸ Based on available records, Fiverr’s disclosed lobbying focus is concentrated on gig economy labor classification legislation — specifically issues related to independent contractor status and the federal policy debate analogous to California’s AB5 — and tax policy affecting digital marketplace operators.⁸³⁷ Specifically, Fiverr has lobbied on the WORK Act and related federal independent-contractor classification legislation, and on Section 1099-K tax reporting threshold legislation affecting freelance platform operators.³⁷

No evidence identified of Fiverr lobbying on: the Israel Anti-Boycott Act, the Combating BDS Act, any foreign aid authorization specifically mentioning Israel or Palestine, the Taylor Force Act, or any legislation related to ICC/ICJ jurisdiction and Israel.⁸³⁷ The Israeli government and major Israeli business associations have coordinated advocacy against BDS legislation in the US and Europe; no evidence of Fiverr’s formal participation in these coordinated advocacy campaigns was identified. This finding reflects the available record; it does not preclude the existence of filings not reviewed in this audit. Source classes reviewed: LDA Senate database, OpenSecrets.org lobbying disclosure data.

Corporate Political Contributions

No public evidence identified of corporate-level financial donations by Fiverr International Ltd. to the Friends of the IDF (FIDF), the Jewish National Fund (JNF), settlement-linked organizations, or military welfare organizations.⁴⁴⁴⁵ Source classes reviewed: FIDF publicly acknowledged major donor records as covered in press, JNF annual reports, Guidestar/Candid IRS Form 990 data for U.S.-registered counterparts.

A claim in the prior research concerning a $211 “transcription services” PAC filing attributed to Fiverr was not independently verifiable from available sources; the description itself suggests a routine vendor payment rather than a politically directed contribution. This claim was discarded as unverified and does not appear as a finding in this audit.

Executive Personal Philanthropy

CEO Micha Kaufman publicly stated in October 2023 Twitter/X posts that he had made a personal financial contribution in support of Israeli defense and military efforts following the October 7 attacks.⁴³⁵ This is documented as a personal donation, not a corporate contribution by Fiverr International Ltd. The specific recipient organization — which could include the FIDF, an IDF welfare fund, emergency civilian relief, or another entity — was not confirmed with precision in available primary sources. Emergency voluntary welfare organizations such as Lev Echad (לב אחד — “One Heart”), which supported soldiers and bereaved families and received significant donations from Israeli tech founders in October–November 2023, are consistent in character and timing with the type of organization Kaufman may have supported; however, Lev Echad as the specific named recipient remains inferential and unconfirmed from primary sources and is not stated as fact.³⁵ No secondary source attributed the donation to Fiverr International Ltd. as a corporate act.⁴

No public evidence identified of other Fiverr board members making publicly disclosed personal donations to FIDF, JNF, or settlement organizations in connection with the 2023–2024 conflict. Source classes reviewed: FIDF gala donor lists as covered in press, JNF honoree records, and Israeli philanthropic press.⁴⁴⁴⁵

Corporate Resource Mobilization During Conflict

Fiverr published operational communications in October–November 2023 describing accommodations for Israeli freelancers and employees affected by the conflict, including extended payment processing windows and business-continuity adjustments for Israeli users.²¹³⁹ No public evidence identified of Fiverr donating cloud computing credits, data infrastructure, logistics assets, or other corporate resources to the IDF, Israeli government ministries, or state-aligned NGOs during the October 2023–2024 conflict period. The FY2024 Form 20-F describes the company’s response to the October 7 attacks as including “operational adjustments to support affected employees and freelancers” — consistent with business-continuity framing throughout the available record.¹ Source classes reviewed: Fiverr press releases, Israeli Ministry of Defense procurement notices as covered in press, and corporate philanthropy tracking databases.

Corporate Structure & Primary Mission

Legal Structure and Incorporation

Fiverr International Ltd. is incorporated in the Cayman Islands as the publicly listed holding company, with its principal operating subsidiary, Fiverr Ltd., domiciled in Israel and additional entities in the United States.³⁴ This structure is a standard configuration for Israeli technology companies seeking access to U.S. capital markets and is not specific to Fiverr. The company completed its initial public offering on the New York Stock Exchange in June 2019 at a valuation exceeding $1 billion.⁶³

There is no parent company above Fiverr International Ltd. The company has no publicly traded parent or controlling corporate shareholder. No single shareholder holds ≥10% of Fiverr International Ltd. shares based on available proxy records.³¹ The largest institutional shareholders are below this threshold. Institutional shareholders as of the most recent proxy records include standard institutional investors (Vanguard, BlackRock, ARK Invest, Bessemer Venture Partners) — none of which are specifically implicated in the settlement economy by the authoritative sources reviewed.³¹³⁴ Fiverr’s subsidiaries are operational entities (marketplace operations, payment processing, legal entities for US and European market compliance); no subsidiary operates in the occupied territories or has a documented settlement-specific mandate.³

Micha Kaufman as founder-CEO holds a meaningful equity stake disclosed in proxy filings, but the quantum has declined below majority levels following post-IPO dilution. Fiverr’s capital structure is a single-class ordinary share structure; no founder-control mechanism via dual-class voting shares has been identified in available proxy records, though direct proxy verification is recommended for definitive confirmation.³¹

Foundational Mandate and Mission

Fiverr’s F-1 prospectus and subsequent 20-F filings uniformly describe its mission as operating “a global online marketplace for digital services,” connecting buyers and sellers of freelance work across more than 500 service categories.³¹ There is no language in founding documents, the corporate charter, or any SEC filing positioning the company as a national champion, assigning it a state-directed mandate, or instrumentalizing its identity in service of Israeli state goals.

The State of Israel does not hold a “golden share,” equity stake, board appointment right, or other form of special interest in Fiverr International Ltd.³ Fiverr is a privately founded, venture-capital-backed company with no formal state partnership agreement, government development contract, or co-development arrangement identified in available records.³⁴

The company’s primary commercial mission is the monetization of freelance service transactions through commission and subscription fees on the marketplace.¹⁴ Its strategic communications, investor presentations, and product roadmap center on marketplace growth, AI-enabled service delivery, and freelancer ecosystem expansion.¹⁴³

Code of Conduct and Governance Documents

Fiverr maintains a publicly accessible Code of Business Conduct and Ethics on its investor relations site.¹⁵ Its corporate governance documents, including board committee charters, are similarly accessible.¹⁴¹⁵ These documents reflect standard NYSE-listed company governance requirements and do not contain geopolitically distinctive provisions.

Executive & Leadership Footprint

CEO: Micha Kaufman

Kaufman co-founded Fiverr in 2010 and has served as CEO since inception. He is a veteran of the Israeli Navy, including service in an elite naval unit, a biographical detail documented in Israeli business press.⁴ His public posture in 2023 can be divided into two distinct phases: vocal opposition to the Netanyahu government’s judicial overhaul in the first half of the year,⁴ followed by a sharp pivot to unconditional public solidarity with the Israeli military response after October 7,⁴³⁵³⁶ including a publicly stated personal financial contribution to Israeli defense efforts.⁴ The specific recipient organization of that personal donation was not confirmed in available sources. No claim that this donation was made using corporate funds or corporate identity is supported by available evidence.

Kaufman’s documented personal investment activity, to the extent disclosed in Israeli business press, is in consumer technology and platform businesses consistent with his Fiverr background. No named defense-sector investment was identified. No public evidence identified of Kaufman holding a formal board membership, advisory role, or leadership position in AIPAC, ADL, CFI, USISTF, StandWithUs, Campus Antisemitism Network, or any other named pro-Israel or anti-BDS lobbying organization.³⁵ Kaufman’s documented organizational memberships are consistent with the Israeli tech CEO peer group: informal membership in tech-sector policy advocacy (gig economy, AI regulation) rather than geopolitical advocacy organizations.

Co-Founder: Shai Wininger

Wininger co-founded Fiverr and departed approximately 2016 to co-found Lemonade Insurance (NYSE: LMND), where he served as President and CTO.⁴⁹ He departed Lemonade’s day-to-day operational role in approximately 2022–2023, though precise departure dates require direct verification. His service in Israeli military intelligence Unit 8200 is a confirmed biographical fact documented in Israeli tech press, IPO-era coverage, and the broader ecosystem literature on Unit 8200’s role as a tech talent pipeline.³⁶³⁸ This background is a historical fact, not a current operational relationship with Israeli military or intelligence institutions, and is not instrumentalized in Fiverr’s current corporate identity.

Wininger holds no current executive, board, or named advisory role at Fiverr based on available proxy records.³¹ His personal conduct post-departure from Fiverr’s governance structure is therefore relevant as a founding-principal background fact but does not constitute a current corporate act for Fiverr International Ltd. No post-October 7 public statements by Wininger specifically in connection with the Israel-Gaza conflict were identified as prominent in available records. No public evidence identified of Wininger making personal donations to FIDF, JNF, settlement organizations, or military-welfare funds in named press sources for the 2023–2024 period. No evidence identified of Wininger holding current formal roles in geopolitical advocacy organizations, pro-Israel lobbying groups, or anti-BDS organizations.⁴⁹

President and COO: Nir Zohar

Zohar has served as Fiverr’s President since 2012 and as COO. Prior research reviewed for this audit attributed Unit 8200 service to Zohar; extended review of available records — including his LinkedIn public profile,⁴⁰ Israeli business press biographical profiles, and Fiverr proxy filing biographical disclosures³¹ — does not confirm Unit 8200 service for Zohar. His documented career background focuses on commercial roles in Israel’s tech sector prior to joining Fiverr in 2012. This claim is treated as unverified in this audit and is not stated as fact. No public statements on the conflict beyond standard corporate communications were identified for Zohar.¹⁴⁴⁰

Board of Directors

• Jonathan Kolber: Board member. Kolber is documented as a former CEO of Koor Industries, one of Israel’s historically significant industrial conglomerates with defense electronics subsidiaries (Tadiran, Telrad) in prior decades.¹⁴⁴⁷ Following his Koor Industries tenure, Kolber has been associated with the Bronfman family investment office (Claridge Israel) in an advisory or partnership capacity, as documented in Israeli business press covering private equity activity in Israel.⁴⁶ Claridge Israel is a private investment entity, not a geopolitical advocacy organization. A prior research claim connecting Kolber to AIPAC leadership remains not independently confirmed in available records and is not stated as a finding.⁴⁶ No public evidence identified of Kolber making personal donations to FIDF, JNF, settlement organizations, or military-welfare funds that are specifically documented in named press sources.

• Adam Fisher (Bessemer Venture Partners): Fisher manages Bessemer’s Israel office and holds a board observer or investor representative role at Fiverr.¹⁷⁵⁹ He is a publicly vocal advocate for Israeli tech ecosystem development and has made documented public statements opposing talent emigration (“brain drain”) from Israel, including in the post-October 7 period.¹⁷ These statements advocate for maintaining Israel’s technology sector and are made in Fisher’s capacity as an investor, not as a Fiverr board member specifically. No statement by Fisher specifically addressing Palestinian civilian harm, humanitarian access, or the ICJ/ICC determinations was identified. BVP’s Israel portfolio focuses on commercial technology investments and is not listed in any of the authoritative sources reviewed (Who Profits, AFSC Investigate, UN database, Albanese reports) as implicated in settlement activity or military technology supply.³⁴ BVP’s Israel portfolio does not include named Israeli defense prime contractors, weapons developers, or surveillance-technology suppliers to the IDF based on available records. No evidence identified that Fisher holds a formal leadership role in a geopolitical lobbying organization beyond his investment activities.¹⁷⁵⁹

• Yael Garten: Independent director. Prior research attributed an Apple affiliation to Garten; this attribution is an error, likely a confusion with another tech executive. Available proxy filing records confirm her primary documented career background as Director of Data Science at LinkedIn.³¹ The current DEF 14A (FY2024, filed ~April 2025) should be reviewed directly against the EDGAR filing for definitive confirmation.³¹

• Ron Gutler: Board member with confirmed board roles at Cato Networks¹⁶ and CyberArk (CYBR, NYSE).⁵⁰ CyberArk is a privileged access management and identity security company; Cato Networks is a cloud-native secure access service edge (SASE) provider. Neither is listed in the UN OHCHR settlement database, Who Profits, AFSC Investigate, or any Albanese report as a named entity with settlement-linked military technology supply. No evidence identified of Gutler holding formal leadership roles in AIPAC, ADL, CFI, FIDF, JNF, or anti-BDS organizations. No evidence identified of Gutler making public statements on the Israel-Gaza conflict in his capacity as a Fiverr board member.¹⁶⁵⁰

• Eyal Shachar: Board member, present in Fiverr’s proxy filings in the post-IPO period (2019–2020 onwards) with continued presence confirmed in the most recent available DEF 14A (FY2024, filed ~April 2025).³¹ Shachar is associated with the Israeli venture capital and technology investment ecosystem and is documented as a Managing Partner at OurCrowd, the Israeli equity crowdfunding and venture platform headquartered in Jerusalem.⁵¹ OurCrowd is not listed in the UN OHCHR settlement database, Who Profits, AFSC Investigate, or any Albanese report as a named entity with settlement-linked activity; its portfolio is concentrated in commercial technology, medical technology, and agri-technology.⁵¹ No public evidence identified of Shachar making personal donations to FIDF, JNF, Im Tirtzu, Regavim, or other military-welfare or settlement-advocacy organizations in named press sources. Precise board tenure start date requires direct EDGAR DEF 14A verification.³¹

Unit 8200 Network

The Israeli military intelligence Unit 8200 is widely recognized as a significant talent pipeline for the Israeli technology sector and is documented in that context in multiple published ecosystem analyses.³⁸¹⁹ Co-founder Shai Wininger’s Unit 8200 service is a confirmed biographical fact.³⁶³⁸ The claimed Unit 8200 affiliation of Nir Zohar, as asserted in prior research reviewed for this audit, could not be independently confirmed from available primary sources and is treated as unverified.⁴⁰³¹ No direct Fiverr corporate relationship with Unit 8200 alumni networks, formal Unit 8200 recruitment programs, or institutional ties to Unit 8200 veteran organizations was identified in available records.

End Notes