Vanguard ECONOMIC

Target: The Vanguard Group, Inc. Research date: 28 October 2026 Entity type: Investment management company. Scope: Direct operations, controlled subsidiaries, investment funds, Israeli securities, sovereign debt, settlement-related financial exposure and controlling principals.

Supply Chain & Sourcing Relationships

Direct supplier relationships

The Vanguard Group, Inc. describes its business as investment management, investment advice and retirement services, with assets managed for fund investors and other clients. Its documented principal commercial activity therefore differs from the physical-goods procurement and distribution activities of agricultural retailers. ¹

No public evidence identified of procurement contracts between The Vanguard Group, Inc. and Mehadrin, Hadiklaim, Galilee Export, Agrexco successors or other Israeli agricultural exporters.

Importer of record

No public evidence identified of a Vanguard-controlled importer of record, agricultural import subsidiary or joint venture established to import Israeli-origin produce.

Seasonal procurement

No public evidence identified of recurring December–April procurement of Israeli dates, avocados, citrus, herbs, potatoes or other agricultural goods.

Third-party sourcing and distribution

Vanguard identifies investment management and financial intermediation as central to its business and describes Vanguard Marketing Corporation as a broker-dealer associated with its investment products. ²

No public evidence identified of Israeli agricultural goods being distributed or sold by Vanguard through resellers, private-label arrangements or third-party importers.

Financial-sector intermediary distinction

Vanguard’s institutional investment disclosures and fund reports establish securities investment activity. They do not establish physical-goods supply contracts between Vanguard and the issuers of securities held by its investment funds. ^{3, 4}

Product Origin, Labeling & Regulatory Compliance

Settlement-origin products

No public evidence identified of physical goods sold by The Vanguard Group, Inc. and confirmed to originate from Israeli settlements in the occupied West Bank, including East Jerusalem, or the occupied Golan Heights.

Country-of-origin labeling

No public evidence identified of a UK DEFRA, customs, trading-standards or other regulatory enforcement action against Vanguard concerning mislabeling Israeli or settlement-origin agricultural goods.

Corporate labeling policy

No public evidence identified of a Vanguard corporate policy specifically governing the country-of-origin labeling of settlement-produced physical goods.

Financial product disclosure

Vanguard publishes investment-product disclosures and portfolio reporting that identify securities, including particular sovereign issuers and their reported market values. ⁴

A Vanguard fund portfolio disclosure dated 30 September 2025 separately identifies the State of Israel as the issuer of two sovereign bonds. This is securities-issuer identification and does not establish a country-of-origin policy for physical goods. ⁴

Settlement-related screening

The American Friends Service Committee’s Investigate database identifies several categories of business activity associated with Israeli settlement infrastructure and the occupation, including settlement industries, natural-resource exploitation, checkpoints and military equipment. Its methodology distinguishes companies involved in specific activities from companies merely conducting business in Israel. ⁵

No Vanguard-specific settlement-company finding was independently established from the opened AFSC methodology page.

No public evidence identified of a Vanguard fund policy expressly requiring exclusion of every company operating in Israeli settlements.

Investment, Capital & Financial Exposure

Corporate ownership and investment-management model

The Vanguard Group, Inc. is owned by the US-domiciled Vanguard funds it serves; those funds are owned by their investors. The company describes this as an investor-owned structure. ¹

Vanguard’s 2026 corporate disclosures distinguish the assets managed for customers from Vanguard’s ownership structure and identify the firm’s role as an investment manager serving more than 50 million investors. ⁶

The company’s reported securities positions must therefore be distinguished from acquisitions of controlled operating companies or direct investments made using the management company’s corporate capital. ^{1, 6}

Israeli sovereign debt

A Vanguard portfolio schedule dated 30 September 2025 identifies two State of Israel sovereign bonds. The first has a 5.000% coupon, matures on 30 October 2026 and was reported with a market value of $9.791 million; the second has a 1.500% coupon, matures on 18 January 2027 and was reported with a market value of $1.258 million. ⁴

The combined reported market value of these two holdings was $11.049 million on 30 September 2025, with the report presenting amounts in thousands of US dollars. ⁴

Act record: the acting investment vehicle was the Vanguard fund covered by the September 2025 portfolio report; the issuer and financial beneficiary was the State of Israel; the channel was ownership of sovereign debt disclosed through Vanguard’s own reporting domain, personal1.vanguard.com; the verified observation was 30 September 2025; the original purchase dates, counterparties, issuance channels and primary-versus-secondary purchase status were not established; continuation beyond the observation date is unknown. ⁴

The securities’ reported maturity dates establish contractual terms but do not establish that either position remained in the fund until maturity. ⁴

Elbit Systems Ltd.

A Form 13F holding-history extract for The Vanguard Group, Inc. reports 998,267 shares of Elbit Systems Ltd. at 31 December 2025, with a reported market value of $573,131,040. ⁷

The reported share count increased by 13,406 from 984,861 shares in the preceding quarter. The same source reports 874,352 shares at 31 December 2024. ⁷

Vanguard’s SEC Form 13F cover page separately identifies The Vanguard Group, Inc. as the reporting institutional investment manager for the quarter ended 31 December 2025. ³

Act record: the reporting entity was The Vanguard Group, Inc.; the securities issuer was Elbit Systems Ltd.; the disclosed channel was institutional securities holdings reported under Form 13F; the underlying investment activity was reported through SEC filings and presented on filingexplorer.com; the opened holding history provides quarterly observations from 2021 through December 2025; the position was present at the latest independently examined reporting date of 31 December 2025; subsequent continuation, the identity of every beneficial fund holder and the original acquisition counterparties were not independently established. ^{3, 7}

These reported holdings establish financial exposure to Elbit Systems Ltd.; the disclosures examined do not establish that Vanguard controls Elbit’s manufacturing operations or directs the use of particular products. ^{3, 7}

Constructive-notice chronology

The Elbit holding history records positions at 30 September 2024, 31 December 2024 and each quarter of 2025, establishing reported positions both after 19 July 2024 and after November 2024. ⁷

The Israeli sovereign bonds were held at the 30 September 2025 reporting date, also after both specified international-law milestones. ⁴

These dated disclosures establish persistence of reported securities exposure during the relevant periods; they do not independently establish the date of the original purchase of each security. ^{4, 7}

Sovereign underwriting and Israel Bonds

No public evidence identified of The Vanguard Group, Inc. acting as a named lead underwriter, bookrunner or syndicate arranger for an Israeli sovereign debt issuance.

No public evidence identified of The Vanguard Group, Inc. acting as an authorised distributor of Development Corporation for Israel bonds.

No public evidence identified of direct lending or trade-finance facilities provided by Vanguard’s operating subsidiaries to Israeli defence manufacturers or settlement businesses.

Israeli equities and portfolio investments

The verified Elbit position establishes an identifiable Israeli corporate equity exposure reported by Vanguard. ⁷

No independently retrieved primary fund-level schedule was established during this audit for current holdings in Bank Leumi Le-Israel BM, Bank Hapoalim BM, Mizrahi Tefahot Bank Ltd., Israel Discount Bank Ltd., Teva Pharmaceutical Industries Ltd., NICE Ltd., Azrieli Group Ltd. or Bezeq The Israeli Telecommunication Corp., Ltd.

No public evidence identified sufficient to quantify Vanguard’s current aggregate exposure to Israeli-domiciled equities across all managed funds.

Acquired Israeli operating companies

No public evidence identified of The Vanguard Group, Inc. acquiring a controlling interest in an Israeli manufacturing, pharmaceutical, defence, technology, agricultural or infrastructure operating company.

No public evidence identified of an Israeli operating acquisition for which Vanguard can be shown to exercise majority voting control, appoint operational management or consolidate the acquired company’s manufacturing activities.

Accordingly, no verified Israeli operating acquisition was identified for which acquisition price, ownership percentage, manufacturing location, local workforce or operating revenue can be reported.

R&D and innovation

No public evidence identified of a Vanguard-owned Israeli research laboratory, engineering centre, defence-development facility or technology accelerator.

Insurance underwriting

Vanguard identifies investment management, advice and retirement services as its business activities and separately identifies investment-advisory, trust and brokerage functions within its operating structure. ²

No public evidence identified of Vanguard itself underwriting insurance policies for Israeli military, settlement or state infrastructure operations.

Investment stewardship and voting authority

Vanguard states that some two dozen internal and external investment managers exercise proxy voting responsibilities across more than 400 funds worldwide, with voting performed according to the policies and objectives of the relevant funds. ⁸

Vanguard introduced two separate investment stewardship teams in 2026, with Vanguard Capital Management Investment Stewardship covering global index strategies and Vanguard Portfolio Management Investment Stewardship covering specified US sector, style-box and quantitative strategies. ^{9, 10}

Act record: Vanguard Capital Management Investment Stewardship and Vanguard Portfolio Management Investment Stewardship administer shareholder governance activity through Vanguard’s disclosed investment-management arrangements; the recipients are portfolio-company shareholder meetings; the public reporting channel is corporate.vanguard.com; the relevant structures are documented during 2026; their continuation was confirmed in Vanguard’s published 2026 descriptions; no issuer-specific Israeli voting decision was established from these pages. ^{9, 10}

Vanguard Investor Choice permits eligible fund investors to direct the voting policy applied to their proportionate shares of participating equity index funds, with the programme having begun as a pilot in 2023. ¹¹

No public evidence identified of a specific Vanguard vote on an Israeli company’s military procurement, settlement financing or occupation-related shareholder proposal.

2026 investment-management reorganisation and Elbit reporting entities

On 12 January 2026, The Vanguard Group, Inc. reorganised portfolio-management and proxy-voting administration functions into two newly established wholly owned subsidiaries, Vanguard Capital Management, LLC (VCM) and Vanguard Portfolio Management, LLC (VPM). The SEC-filed fund supplement confirms that investment-management responsibilities were delegated to these entities while the underlying funds retained their investment objectives and strategies. This organisational change is material when comparing securities disclosures before and after January 2026 because the reporting investment managers changed. ¹²

Vanguard Capital Management, LLC (CIK 0002100119; Form 13F file 028-26876) filed its Form 13F-HR on 13 August 2026 for the quarter ending 30 June 2026. Its SEC information table confirms 759,204 ordinary shares of Elbit Systems Ltd. (CUSIP M3760D101), valued at $577,278,982. The position is classified as investment discretion DFND, with voting authority reported as zero sole, zero shared and 759,204 none. The filing identifies VCM as the institutional investment manager and reports no other included managers. ^{13, 14}

The existing audit’s 31 December 2025 observation attributes 998,267 Elbit shares, valued at $573,131,040, to The Vanguard Group, Inc. Comparing that historical observation with VCM’s June 2026 filing produces a numerical difference of 239,063 fewer shares, or approximately 23.95%, while reported market value is approximately $4.15 million higher. This comparison crosses a change in reporting entity following the January 2026 reorganisation. Consequently, the difference cannot independently establish that Vanguard sold 239,063 shares. The two reported positions also reflect different security valuation dates. ^{12, 13, 14, 7}

Vanguard Fiduciary Trust Company (VFTC; CIK 0000933478; Form 13F file 028-11554) separately filed Form 13F-HR on 13 August 2026 for the same 30 June 2026 reporting period. Its SEC information table confirms 243,554 ordinary shares of Elbit Systems Ltd. (CUSIP M3760D101), valued at $185,192,129. VFTC reports investment discretion DFND and sole voting authority over all 243,554 shares, with zero shared voting authority and zero shares classified as having no voting authority. Its filing identifies no other included managers. ^{15, 16}

The VCM and VFTC June 2026 filings therefore disclose two separately reported Elbit positions totalling 1,002,758 shares and $762,471,111 in reported market value. This arithmetic total exceeds the existing December 2025 Vanguard Group observation by 4,491 shares, approximately 0.45%. However, separate Form 13F reporting does not independently establish separate ultimate beneficial ownership. The SEC information tables disclose distinct investment managers and different voting-authority classifications, but do not identify every underlying client account or conclusively exclude overlapping beneficial interests. The combined figure should therefore be described as the sum of reported manager positions, subject to that qualification, rather than a verified consolidated beneficial-ownership total. ^{13, 14, 15, 16}

2026 Israeli sovereign-debt exposure

A publicly accessible compilation of SEC Form N-PORT holdings identifies approximately $416.2 million in Israeli government and government-related bonds held by Vanguard Total Bond Market Index Fund (BND) at 30 June 2026. It reports 18 securities with an aggregate face value of approximately $447.4 million and a reported market value equivalent to approximately 0.10% of fund net assets. The compilation attributes these figures to the fund’s N-PORT disclosures. The underlying SEC filing’s complete security-level Israel schedule was not independently reconciled during this search, so the aggregate remains a secondary-source finding. ¹⁷

The same compilation identifies approximately $572.9 million in Israeli government and government-related bonds held by Vanguard Total International Bond Index Fund (BNDX) at 31 July 2026. It reports 17 securities representing approximately 0.47% of fund net assets. The compilation also separately identifies Vanguard Total International Bond II Index Fund with approximately $687.6 million and Vanguard Total Bond Market II Index Fund with approximately $408.6 million in comparable exposure. These are distinct fund series, and their reported positions should not automatically be aggregated because underlying portfolio relationships and potential duplication require examination. ¹⁷

June–July 2026 - no public evidence identified sufficient to independently reproduce the complete 18-security BND and 17-security BNDX Israeli sovereign-bond schedules, including each security’s identifier, coupon, maturity and individual USD valuation. Searches covered SEC Form N-PORT records, Vanguard fund-series identifiers, SEC filing indexes and the publicly accessible InsiderStreet holdings compilation. The compilation establishes the claimed aggregate figures and valuation dates, but primary-document security-by-security reconciliation remains outstanding. Filing.fyi independently identifies the Vanguard Total Bond Market Index Fund’s June 2026 N-PORT holdings report and August 2026 filing date, but its publicly displayed fund summary does not reproduce the complete Israel-specific security-level schedule. ^{17, 18}

Vanguard’s SEC-filed January 2026 investment-advisory supplement explicitly identifies both Vanguard Total Bond Market Index Fund and Vanguard Total International Bond Index Fund among the funds assigned to Vanguard Capital Management. This establishes the investment-management relationship relevant to the reported sovereign-debt exposure. It does not establish that the management company’s own corporate balance sheet owns the bonds or that the reported securities were acquired directly from the State of Israel in primary-market issuance. ¹²

Operational Presence & Market Activity

Global operating footprint

Vanguard identifies its headquarters as Valley Forge, Pennsylvania, United States, and reports approximately 20,000 employees worldwide and global assets under management of approximately $12 trillion as of 30 November 2025. ¹⁹

The firm’s corporate facts and figures report approximately 20,000 employees as of 31 December 2025 and 487 funds offered worldwide as of 30 June 2026. ²⁰

Vanguard’s historical account identifies Australia as the location of its first international office, established in 1996, following the company’s US founding in 1975. ²¹

Israeli offices, employees and tax registration

No public evidence identified of an office, branch, warehouse, call centre, research centre or separately identified legal headquarters operated directly by The Vanguard Group, Inc. in Israel.

No public evidence identified of Vanguard’s Israel-specific employee headcount.

No public evidence identified of an Israeli corporate tax-residency determination, Israeli Preferred Technology Enterprise status or Israeli tax assessment for The Vanguard Group, Inc.

No public evidence identified of a Vanguard-operated site within the occupied West Bank, East Jerusalem or Golan Heights.

Market positioning

Vanguard describes itself as a global investment-management provider and states that it serves customers through direct channels, workplace plans and financial intermediaries. ⁶

No public evidence identified of a Vanguard corporate disclosure designating Israel as a strategic regional headquarters, principal domestic market or substantial operational revenue centre.

Investment exposure versus operational presence

Vanguard’s December 2025 Elbit securities reporting and September 2025 sovereign-bond disclosure establish investment exposure to Israeli issuers without separately establishing offices, workforce or direct operating facilities in Israel. ^{4, 7}

Government contracts and critical infrastructure

No public evidence identified of a direct Vanguard operational contract with the Israel Ministry of Defence, Israel Defense Forces or another Israeli defence procurement authority.

No public evidence identified of Vanguard’s designation as critical Israeli national infrastructure.

No public evidence identified of Israeli government ownership or Israeli government-appointed directors at The Vanguard Group, Inc.

Military leave and employee benefits

No public evidence identified of an Israeli Vanguard employee reservist-pay subsidy or Israel-specific military-leave reimbursement policy.

Charitable donations and matching

No public evidence identified of a verified direct Vanguard corporate donation or employee-matching transaction benefiting the Friends of the Israel Defense Forces or an Israeli settlement organisation.

Corporate Structure & Foundational Ties

Founding and legal identity

The Vanguard Group, Inc. commenced operations in the United States on 1 May 1975 and was founded by John C. Bogle. ²¹

The company’s principal headquarters is in Valley Forge, Pennsylvania. ¹⁹

Vanguard’s US management company is owned by its member funds, which are in turn owned by their investors. ¹

The company’s US institutional investment-manager registration identifies The Vanguard Group, Inc. as the reporting entity, with SEC file number 801-11953 and Form 13F file number 028-06408. ³

Israeli-nexus factors

Founded in Israel: no public evidence identified; Vanguard’s own history identifies its founding in the United States in 1975. ²¹

Headquarters or principal management in Israel: no public evidence identified; Vanguard identifies its headquarters in Pennsylvania. ¹⁹

Israeli corporate tax residence or Preferred Technology Enterprise status: no public evidence identified.

Control by Israeli capital: no public evidence identified; Vanguard’s published ownership structure attributes company ownership to its member funds and ultimately fund investors. ¹

Parent company and significant shareholders

Vanguard identifies its member funds as its owners, rather than identifying a conventional publicly traded parent company or private-equity sponsor. ¹

No individually named shareholder holding 10% or more of The Vanguard Group, Inc.’s corporate equity was established from the reviewed disclosures.

The absence of a conventional public-company shareholder register does not establish the identity or geographical distribution of every underlying fund investor. ¹

Leadership and controlling principals

Vanguard’s published leadership roster identifies Salim Ramji as chief executive officer and Greg Davis as president and chief investment officer. ²²

Mark Loughridge has chaired Vanguard’s board since 2024, having joined the board in 2012. ²²

On 24 July 2026, Vanguard announced that Kenneth Jacobs would succeed Mark Loughridge as nonexecutive chairman following Loughridge’s retirement effective 31 December 2026. John Murphy was elected lead independent director. ²³

The announced transition had not yet reached its effective retirement date at the research date of 28 October 2026. ²³

Vanguard announced on 11 February 2026 that David Hunt and Kenneth Jacobs would join the board effective 24 February 2026. ²⁴

Vanguard announced on 30 June 2026 that André Perold retired from the board and that Oliver Zipse would join effective 23 February 2027. The latter date was prospective at the research date. ²⁵

Named-principal investigation record

John C. Bogle - Founder; US founding and historical corporate identity established. No public evidence identified of a verified personal Israeli operating investment. ²¹

Salim Ramji - CEO and director since 2024; leadership established. No public evidence identified of a material personal or family-office Israeli investment. ²²

Greg Davis - President, CIO and director; investment-management responsibilities established. No public evidence identified of a material personal Israeli investment. ²²

Mark Loughridge - Current chairman; retirement scheduled for December 2026. No public evidence identified of a material personal Israeli investment. ²³

Kenneth Jacobs - Director and chairman-designate, formerly chairman and CEO of Lazard. No public evidence identified of a material personal Israeli investment attributable to Vanguard. ^{23, 24}

John Murphy - Director and lead independent director, also president and CFO of The Coca-Cola Company. No public evidence identified of a material personal Israeli investment attributable to Vanguard. ²³

David Hunt - Director and former PGIM president and CEO. No public evidence identified of a material personal Israeli investment. ²⁴

Tara Bunch - Director and former Airbnb executive. No public evidence identified of a personal Israeli investment or Vanguard-authorised settlement operation attributable to her board role. ²²

Scott Malpass - Director and former University of Notre Dame chief investment officer. No public evidence identified of a material personal Israeli investment. ²²

Lubos Pastor - Director and University of Chicago finance professor. No public evidence identified of a material personal Israeli investment. ²²

Rebecca Patterson - Director and former Bridgewater Associates chief investment strategist. No public evidence identified of a material personal Israeli investment. ²²

Sarah Bloom Raskin - Director and former Federal Reserve governor. No public evidence identified of a material personal Israeli investment. ²²

Grant Reid - Director identified in Vanguard’s fund trustee election disclosure. No public evidence identified of a material personal Israeli investment. ²⁶

David Thomas - Director identified in Vanguard’s fund trustee election disclosure. No public evidence identified of a material personal Israeli investment. ²⁶

Barbara Venneman - Director and former Deloitte Digital executive. No public evidence identified of a material personal Israeli investment. ²²

Peter Volanakis - Director and former Corning executive. No public evidence identified of a material personal Israeli investment. ²²

André Perold - Former director whose retirement became effective in June 2026. No public evidence identified of a material personal Israeli investment. ²⁵

Oliver Zipse - Announced future director with an appointment date of February 2027. No public evidence identified of an Israeli investment attributable to an existing Vanguard directorship. ²⁵

Named group entities

Vanguard Marketing Corporation - Vanguard-associated broker-dealer identified in company disclosures; no independently established Israeli operating subsidiary or direct Israeli investment. ²

Vanguard Advisers, Inc. - Vanguard-associated registered investment adviser; no independently established Israeli operating subsidiary or direct Israeli investment. ²⁰

Vanguard National Trust Company - Vanguard-associated trust company; no independently established Israeli operating subsidiary or direct Israeli investment. ²⁰

Vanguard Capital Management - Vanguard investment-management entity; stewardship responsibilities identified through its Vanguard Capital Management Investment Stewardship function. No independently established Israeli-controlled operating acquisition. ⁹

Vanguard Portfolio Management Investment Stewardship - Internal investment stewardship function established in 2026; no separately established Israeli incorporation or operating acquisition. ¹⁰

Vanguard Market Liquidity Fund - Affiliated investment vehicle appearing in Vanguard’s September 2025 fund reporting; no independently established Israeli operating subsidiary. ⁴

Vanguard’s US-domiciled funds and ETFs - Member-fund owners of The Vanguard Group, Inc.; ownership and management relationship established. No individually verified Israeli operating acquisition by the management company. ¹

Governance mechanisms and state connections

Vanguard’s ownership model, director elections and investment stewardship disclosures describe fund-shareholder ownership, trustee oversight and governance responsibilities. ^{1, 26}

No public evidence identified of Israeli government golden shares, founder veto rights, charter restrictions or Israeli state-appointed governance positions within The Vanguard Group, Inc.

No public evidence identified of a corporate charter provision binding Vanguard’s mission or management to Israeli government policy.

Profit Repatriation & Economic Contribution

Israel-specific revenue

Vanguard reports global assets under management of approximately $12 trillion as of 30 November 2025 and identifies investment management, advice and retirement services as its business lines. ¹⁹

No public evidence identified of separately disclosed revenue, operating profit, tax expense or management-fee income attributable specifically to customers located in Israel.

Securities investment and issuer exposure

Vanguard’s September 2025 portfolio report establishes $11.049 million in reported market value for two State of Israel sovereign securities. ⁴

The December 2025 Form 13F holding extract establishes a reported $573.131 million position in Elbit Systems Ltd. ⁷

These values are reported market values of securities at specified dates and are not equivalent to Vanguard’s operating revenue, fees, profit, tax payments or direct corporate capital expenditure. ^{4, 7}

Potential financial-flow channels

The Vanguard portfolio report identifies State of Israel debt instruments held as investment securities, creating a contractual relationship between the security holder and sovereign issuer. ⁴

The available disclosure does not identify whether the fund purchased either bond from the issuer or from another investor, nor does it identify the date or price of acquisition. ⁴

Vanguard’s ownership disclosure confirms that the firm’s investment-management structure serves fund shareholders, and its 2026 explanation identifies managed assets as belonging to investors. ^{1, 6}

No public evidence identified of profits earned from Vanguard’s global management business being systematically repatriated to an Israeli-domiciled parent company.

No public evidence identified of Israel-specific operating profits remitted by an Israeli Vanguard subsidiary to the United States.

Corporate ownership versus investment returns

Vanguard’s published ownership structure links the management company to its US member funds and the investors in those funds. ¹

The identified Israeli equity and sovereign debt positions form part of securities-investment activities rather than documented ownership of an Israeli operational headquarters or manufacturing subsidiary. ^{3, 4, 7}

Economic ecosystem role

Vanguard’s reported scale encompasses approximately 20,000 employees and hundreds of funds worldwide. ²⁰

Its disclosed securities positions establish participation in capital markets that include Israeli sovereign and corporate issuers. ^{4, 7}

No public evidence identified of a government or regulator designation characterising The Vanguard Group, Inc. as a critical employer, nationally significant operating infrastructure provider or strategic domestic financial institution within Israel.

Status and temporal coverage

The Elbit holding record establishes quarterly observations through 31 December 2025 and includes positions reported after 19 July 2024 and November 2024. Its status after December 2025 was not independently verified. ⁷

The Israeli sovereign-debt positions were verified as portfolio holdings on 30 September 2025. Their status at 28 October 2026 was not independently verified. ⁴

The Vanguard corporate ownership structure and investment-management activities were described in company materials accessible during October 2026. ^{1, 6}

Source boundaries

No public evidence identified sufficient to quantify the total net economic contribution of all Vanguard-managed portfolios to the Israeli economy.

No public evidence identified sufficient to distinguish aggregate primary-market capital provision from secondary-market purchases across Vanguard’s Israeli investments.

No public evidence identified sufficient to determine the precise destination or subsequent expenditure of proceeds from securities previously issued by the State of Israel or Israeli corporations.