06-main-dossier.md - AXA Group

Key Findings

• Military: AXA Venture Partners held an 8.94% stake in Hub Security, an Israeli company with a confirmed Israeli Ministry of Defence contract for hardware-based cybersecurity modules.¹²³⁴
• Economic: AXA’s broader investment portfolio includes approximately $150 million in arms manufacturers with direct Israeli defence supply relationships.⁵⁶⁷
• Digital: AXA has deployed Verint Open Platform across its contact-centre operations; Verint is an Israeli intelligence-origin surveillance technology company with disclosed Israeli state contracts.⁸

Target Profile

Executive Summary

AXA Group is a Paris-headquartered insurance and financial services conglomerate. Its documented Israel/Palestine nexus is predominantly financial in character, operating through three distinct vectors: (1) venture-capital investment in Israeli technology firms, most materially through AXA Venture Partners’ (AVP) 8.94% equity stake in Hub Security - an Israeli cybersecurity company whose founders are alumni of IDF intelligence units 8200 and 81, and which holds an active Israeli Ministry of Defence contract confirmed as of September 2022; (2) defence-sector portfolio holdings of approximately $150 million in multinational arms manufacturers (Boeing, Lockheed Martin, RTX, BAE Systems, and others) whose weapons systems are documented as in use by the Israel Defense Forces, as of June 2024 with no confirmed post-divestment; and (3) infrastructure investment through AXA’s asset management arm in CAF, the Spanish rail manufacturer contracted to expand the Jerusalem Light Rail in ways that serve East Jerusalem settlement neighbourhoods.

These exposures are substantially offset by documented divestments: AXA Investment Managers fully divested from Elbit Systems by end-2019, divested from Israeli banks in stages through June 2024, and - following sustained campaign pressure - reduced its Israeli banking exposure to a residual approximately $130,000 position in Bank Leumi. The sale of AXA Investment Managers to BNP Paribas, completed in July 2025, transfers primary responsibility for ongoing defence portfolio management to a new entity under a long-term partnership arrangement.

What is not supported by evidence includes: any direct AXA Group contract with the Israeli Ministry of Defence or IDF; any provision of surveillance or digital technology by AXA to Israeli state or military bodies; any AXA-branded physical R&D infrastructure in Israel; any Israeli sovereign bond holdings confirmed in public disclosures; and any AXA corporate statement of condemnation or investment halt directed to the Gaza conflict of the kind AXA issued following Russia’s 2022 invasion of Ukraine. The Digital domain finds a confirmed customer relationship with Israeli-R&D-based Verint Systems for contact-centre analytics - a commercial SaaS deployment - but no evidence that this deployment serves any military, intelligence, or surveillance end-use.

The resulting BRS score of 363 places AXA in Tier D (Moderate), driven primarily by the Economic domain (V=4.74), where the scale and proximity of defence-sector portfolio holdings constitute the strongest documented vector. The Military domain (V=2.30) captures the AVP/Hub Security nexus, which involves a venture-capital stake in a company with active IMOD contracts and documented wartime “digital defence” engagement. The Political domain (V=2.48) reflects AXA’s failure to issue a named condemnation of the Gaza conflict or to respond publicly to the ICJ Advisory Opinion and ICC arrest warrants, set against a prior record of named condemnation and active sanctions enforcement following Russia’s invasion of Ukraine.

Timeline of Relevant Events

Corporate Overview

AXA S.A. is a publicly traded French société anonyme (Euronext Paris: CS) whose stated corporate mission - registered under France’s 2019 Loi Pacte framework - is “Act for human progress by protecting what matters.”³⁴ The group operates across insurance, reinsurance, and asset management, with operations in more than 50 countries. As of 31 December 2024, free float represented approximately 78.6% of share capital, with the Mutuelles AXA mutual holding entities holding approximately 15.4% and employees and agents holding approximately 4.3%.⁹

AXA Venture Partners (AVP) is AXA Group’s venture capital arm, established under AXA sponsorship and explicitly listing Israel as a core operating geography alongside Europe and North America.³⁵³⁶ AVP raised a US $150 million second Early Stage fund in 2021.³⁵ AVP was reported to be pursuing management independence via a management buyout in 2024–2025; whether AXA Group retains limited partner (LP) interest in existing AVP fund vehicles after this process is not confirmed in public filings.³⁷ As of the knowledge cutoff, Hub Security remained listed on AVP’s active portfolio page.³⁸

AXA Investment Managers (AXA IM) - formerly the asset management subsidiary holding the Israeli bank, Elbit Systems, and arms manufacturer equity and bond positions documented in this dossier - was sold by AXA Group to BNP Paribas Cardif. The acquisition completed on 1 July 2025 for €5.1 billion, under a long-term partnership in which BNP Paribas provides investment management services to AXA while AXA retains authority over product design, asset allocation, and asset-liability decisions.³⁹⁴⁰ Integration into BNP Paribas’s asset management platform was reported completed on 31 December 2025.³⁹ The transfer of the arms manufacturer portfolio to BNP Paribas is a material structural change with implications for ongoing attribution.

Kamet Ventures is AXA Group’s insurtech incubator/fund, founded 2016 with approximately €200 million committed (predominantly from AXA). Kamet held Israeli startups in its portfolio including Ibex Medical Analytics Ltd, a Tel Aviv-based AI computational pathology company.⁴¹⁴²

AXA Strategic Ventures (AVP’s predecessor entity) led the $11 million Series A investment in Neura in 2016. Neura was acquired by Twilio in 2019, concluding the AXA investment relationship.⁴³⁴⁴

Named Israeli franchise/joint-venture entities: No AXA-branded subsidiary, branch, or joint venture with Israeli state-owned or state-adjacent entities has been identified in the audit evidence base. The 2016 InsurTech Israel competition involved collaboration with Jerusalem Venture Partners (JVP) and Start-Up Nation Central - private ecosystem organisations rather than government entities.⁴⁵⁴⁶

Domain Summaries

Military: Military

Mechanism of Involvement

The Military mechanism of involvement for AXA is indirect financial investment through two documented vectors:

Vector 1 - AXA Venture Partners / Hub Security:

AXA Venture Partners led a $5 million Series A funding round for Hub Security (now HUB Cyber Security Ltd., NASDAQ: HUBC) in May 2020.⁴⁷⁴⁸ 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 direct lineage from Israeli military intelligence infrastructure.⁴⁷⁴⁸ A co-investor in that round was OurCrowd.⁴⁸

In September 2022, Hub Security was awarded a tender by the Israeli Ministry of Defence valued at NIS 4.2 million (approximately $1.2 million USD), covering Hub’s hardware and software products and services over a three-year period from 2022 through 2025.⁴⁹ This contract was 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.”⁵⁰

SEC filings dated 30 September 2023 list AVP Early Stage II S.L.P. as beneficial owner of 8,785,035 shares of HUB Cyber Security, representing 8.94% of outstanding shares at that date.⁵¹ 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.

The temporal overlap between AVP’s confirmed equity ownership and the active IMOD contract performance period is complete and unbroken from the contract award date (September 2022) through at least 30 September 2023, and likely further into 2024 under the original three-year contract term.

A subsequent procurement event is documented in late 2024 / early 2025, when Hub Security announced 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.”⁵²⁵³ The precise execution date and any relationship to potential AVP divestment is not confirmed from a primary source.

AVP stake status: No confirmed public announcement of AVP’s divestment from Hub Security has been identified. AVP’s portfolio page did not remove Hub Security from the active portfolio as of the knowledge cutoff.³⁸ The AVP stake should be treated as likely still extant or in wind-down absent a primary filing confirming divestment.

Vector 2 - CAF / Jerusalem Light Rail:

AXA’s asset management arm’s investment in CAF (Construcciones y Auxiliar de Ferrocarriles), the Spanish rail manufacturer, connects AXA to settlement-adjacent infrastructure. CAF leads the TransJerusalem J-Net consortium (alongside Shapir Engineering)⁵⁴ contracted to expand the Jerusalem Light Rail (JLR) Red Line and construct the Green Line.⁵⁵⁵⁶ This infrastructure links 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.⁵⁷⁵⁸ The Green Line’s route connects East Jerusalem settlement neighbourhoods with central Jerusalem; both routes traverse or terminate in areas designated as occupied territory under international law.⁵⁹

Construction and civil works on the Green Line continued through 2023–2025. The project was not suspended or cancelled following the October 2023 conflict outbreak. The DBIO V report (November 2025) - the most recent iteration - confirms continuation of this documentation into the most recent reporting period, post-dating both the ICJ Advisory Opinion (19 July 2024) and ICC arrest warrants (November 2024).⁵⁷ AXA IM’s holdings in CAF, if retained, therefore represent ongoing financial exposure to settlement-connectivity infrastructure in the post-Advisory Opinion period.

No public evidence has been identified of AXA Group appearing in SIBAT (Israel’s Defence Export & Defence Cooperation Directorate) listings, Israeli defence exhibition catalogues, 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.

Counter-Arguments and Evidence Limits

AVP independence and wind-down: AVP was reported to be pursuing management independence via a management buyout in 2024–2025.³⁷ If completed, this structural separation would substantially limit AXA Group’s ongoing financial exposure to AVP’s portfolio companies, including Hub Security. Whether AXA retains LP interest in existing AVP fund vehicles is not confirmed in public filings - this represents a material structural intelligence gap, but also a potential exculpatory argument.

Passive index-tracking: The residual Bank Leumi position retained after June 2024 (approximately 16,000 shares, ~US $130,000) was attributed by Profundo and Ekō to passive index-tracking tail positions rather than active strategic investment intent.⁶⁰⁶¹⁶² The same argument could potentially be extended to CAF holdings if AXA’s position is demonstrably passive and non-executive. No confirmation of this argument from primary AXA disclosures has been identified.

CAF: project contractor vs. AXA as investor: AXA’s exposure to CAF is as a financial investor/shareholder, not as a direct party to the JLR contract. As a minority investor, AXA has no operational role in the infrastructure construction and no direct involvement in settlement-adjacent activity. The connection is indirect and financial in character.

Hub Security: COTS products, not bespoke military systems: Hub Security’s HSM and Confidential Computing products are commercial-off-the-shelf (COTS) security infrastructure with documented civilian enterprise applications. No separate “tactical variant” manufacturing process has been identified; the products are sold commercially and supplied under the IMOD contract using the same technical platforms.⁴⁷⁴⁸⁴⁹ The dual-use argument is technically valid but does not resolve the confirmed IMOD end-use.

Divestment track record: AXA has demonstrated a willingness to divest when under sustained campaign pressure - completing full divestment from Elbit Systems (2019), divesting from Israeli banks in stages (2022–2024), and selling AXA IM to BNP Paribas (2025). This track record could be presented as evidence of good-faith engagement and responsiveness to stakeholder concerns, rather than as a pattern of resistance.

Temporal distance of some investments: The Neura investment (2016) was concluded when Neura was acquired by Twilio in 2019. This predates the current escalation and represents a closed, historical exposure rather than an active one.

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

The Digital mechanism of involvement for AXA is procurement of Israeli-origin enterprise technology and venture investment in Israeli technology firms. The directionally serious case - provision of surveillance, digital, or cyber technology to the Israeli state, military, or security services - was not substantiated in the audit evidence base.

Confirmed vector - Verint Systems (AXA as customer):

Verint Systems (Nasdaq: VRNT, acquired by Thoma Bravo August 2025) publishes a named case study describing AXA’s UK Retail division migrating to the cloud-hosted Verint Open Platform and deploying Verint Da Vinci AI-powered Speech Analytics, Verint Desktop and Process Analytics, and Verint Performance and Compliance Scoring Bots.⁸ Documented outcomes include: a Wrap-Up Bot reducing average handle time by approximately 30 seconds per call across 1,700 agents; speech-analytics transcription accuracy reaching 95%; first-contact resolution rising from 87% to 93%; and supplier call volume falling 34%.⁸ A separate case study documents AXA Health using the same platform.⁶⁴

The direction is AXA as the customer procuring a commercial customer-engagement SaaS product. Verint originated from Comverse Technology / Comverse Infosys, which developed lawful-interception technology, and retains significant R&D operations in Israel.⁶⁵ In February 2021 Verint completed the spin-off of its cyber-intelligence (government surveillance/OSINT) business as Cognyte Software Ltd, leaving the remaining Verint Systems entity - the one AXA uses - focused on enterprise customer engagement.⁶⁵⁶⁶ No public evidence was identified that AXA’s Verint deployment serves or has served any military, intelligence, or law-enforcement surveillance purpose; the documented use case is contact-centre quality management.⁸

Engagement with Wiz (scope unconfirmed):

Both AXA and Wiz appeared in the published agenda of the 2025 UK & Ireland CISO Community Executive Summit (Evanta/Gartner, 10 June 2025): Shaun Crawford (Business Security Partner, AXA) in a session on third-party risk, and Julia Weimer (Head of Solutions Engineering UK&I, Wiz) in a separate Wiz-hosted session.⁶⁷ The two appear in separate sessions; no joint AXA-Wiz session is listed, and no AXA-named Wiz customer case study or press release was independently located.⁶⁷ Wiz’s four co-founders served in IDF Unit 8200;⁶⁸ Google completed its approximately $32 billion acquisition of Wiz in March 2026.⁶⁸ The scope of any AXA-Wiz deployment is not disclosed in any verified public source.

Kamet Ventures / Ibex Medical Analytics:

Kamet Ventures (AXA’s insurtech incubator) held Israeli startup Ibex Medical Analytics Ltd in its portfolio, including co-investing in Ibex’s $11 million Series A.⁴¹⁴² Ibex is a Tel Aviv-based AI computational pathology cancer-diagnostics company. This is a medical-diagnostics and insurtech investment, not a surveillance technology relationship.

AXA’s own AI deployments:

AXA built AXA Secure GPT - an internal generative-AI service - on Microsoft Azure OpenAI Service, rolled out from an initial 1,000 AXA Group Operations users toward all approximately 140,000 AXA employees globally.⁶⁹⁷⁰ AXA and Amazon Web Services (AWS) announced joint development of the AXA Digital Commercial Platform (DCP) using Amazon Bedrock foundation models.⁷¹ Both are US-entity relationships; neither is an Israeli-origin vendor relationship.

No public evidence identified of: AXA deploying facial recognition, biometric identification, or comparable technologies from any Israeli-origin vendor; AXA operating or leasing data-centre infrastructure within Israel; AXA participating in Project Nimbus or any Israeli government cloud initiative; AXA providing surveillance technology, data, software, or digital services to the Israeli state, military, or security services; or AXA’s commercially deployed technology being repurposed for military or surveillance purposes in Israel or the OPT.

AXA was itself the victim of a major ransomware attack in May 2021 by the Avaddon group, striking AXA’s Asia Assistance division across Thailand, Malaysia, Hong Kong, and the Philippines.⁷²⁷³ This incident was committed against AXA and has no nexus to the provision of technology to Israel.

Counter-Arguments and Evidence Limits

Post-spin-off Verint entity: The February 2021 Cognyte spin-off separates the government-surveillance business from the enterprise customer-engagement business that AXA procures. AXA’s Verint deployment is with the post-spin-off entity focused exclusively on commercial customer-experience applications.⁶⁵⁶⁶ This structural separation substantially limits the adverse inference from Verint’s historical lawful-interception origins.

US hyperscaler stack: AXA’s primary AI and cloud infrastructure rests on Microsoft Azure and AWS - US-headquartered companies subject to US jurisdiction. This is not an Israeli-origin technology relationship.

Wiz: co-presence, not a contract: The Evanta/Gartner summit agenda shows AXA and Wiz personnel attending the same event in separate sessions. This is co-presence at an industry conference, not evidence of a procurement relationship. The scope of any AXA-Wiz deployment remains unconfirmed in any public source.⁶⁷

Data-residency gap is not evidence of misuse: Whether AXA contact-centre data processed by Verint Da Vinci AI is accessible to Verint’s Israeli R&D teams is not resolvable from public sources; a data-processing agreement review would be required.⁸ The absence of evidence is not evidence of absence, but the audit found no public source confirming any such access.

Kamet/Ibex: medical diagnostics, not surveillance: Ibex Medical Analytics develops AI tools for cancer pathology detection in clinical settings. This is a medical-insurance-adjacent technology with no documented surveillance application.

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

The Economic mechanism of involvement for AXA is financial investment in Israeli banks, settlement-financing institutions, and global arms manufacturers. This is the domain with the highest documented V-domain score (V=4.74) and constitutes the primary driver of AXA’s BRS score.

Vector 1 - Israeli banking sector holdings (substantially divested):

AXA IM held equity positions across multiple Israeli financial institutions through at least 2023. The divestment record is as follows:

• Elbit Systems: Fully divested by end-2019 following sustained BDS campaign pressure.^74757677
• Mizrahi Tefahot and First International Bank of Israel: Divested by end-2022.⁷⁶⁷⁷
• Bank Hapoalim, Bank Leumi, Israel Discount Bank: AXA held approximately US $20.4 million across these three banks as of 30 September 2023.⁷⁸⁶² Divested from Bank Hapoalim and Israel Discount Bank by 24 June 2024.^60616278 A residual approximately 16,000 shares in Bank Leumi, valued at approximately US $130,000, remained at this date, attributed to passive index-tracking.⁶⁰⁶¹⁶²

The three banks are documented by Who Profits, DBIO 2024, and Al-Haq as providing financial services including mortgage lending and project finance to Israeli settlements in the West Bank and East Jerusalem.⁷⁹⁸⁰ Whether the Bank Leumi residual position has been fully wound down between H2 2024 and early 2026 is not confirmed in publicly available sources.⁷⁸

Vector 2 - Defence industrial holdings (ongoing as of mid-2024):

As of 30 June 2024, AXA IM held an aggregate estimated US $150.43 million in equity and debt instruments of multinational defence contractors whose weapons systems are documented as in use by the Israel Defense Forces.⁸¹⁸²⁸³ This figure is sourced from Profundo financial research commissioned in connection with BDS Movement campaign activities.⁸³⁸⁴

Confirmed named holdings include: Boeing, General Dynamics, Lockheed Martin, RTX (Raytheon Technologies), Northrop Grumman, BAE Systems, Rolls-Royce, and L3Harris Technologies.⁸¹⁸²⁸³ The debt component is estimated at approximately US $71.56 million of the total; individual instrument vintage and issuance dates are not disclosed in public-facing data, making it impossible to determine from available sources whether bond subscriptions predate or postdate October 7, 2023.⁸³

The PAX for Peace report “Companies Arming Israel and Their Financiers” (June 2024) independently identifies AXA IM in its financier matrix as a holder of shares and/or bonds in multiple companies on PAX’s list of 30 arms suppliers.⁸⁵ The PAX report uses LSEG/Refinitiv shareholding data and Bloomberg bond data; its methodology is consistent with Profundo’s.⁸⁵⁸⁴

Post-ICJ Advisory Opinion status: The ICJ’s Advisory Opinion of 19 July 2024 found that Israel’s continued presence in the OPT is unlawful and that third states and international organisations have obligations not to render aid or assistance in maintaining that unlawful presence.⁸⁶ The Profundo data point is dated 30 June 2024 - immediately prior to the ICJ Advisory Opinion. No divestment of the defence portfolio has been announced post-July 19, 2024; holdings therefore appear to have continued post-ICJ Advisory Opinion without a documented policy change.^81828487 No AXA Group announcement of a policy change in response to the ICC arrest warrants (November 21, 2024) has been identified.⁸⁸⁸⁷

AXA IM exclusion policy: AXA IM’s exclusion policy prohibits investment in manufacturers of cluster munitions, anti-personnel mines, biological and chemical weapons, and nuclear weapons outside recognised nuclear-armed states, but does not categorically exclude conventional defence manufacturers such as those named above.⁸⁹⁹⁰⁹¹ The 2024 updated exclusion policy did not, based on available evidence, add Israeli sovereign bonds or Israeli financial institutions as categorical exclusions, and did not introduce a conflict-zone exclusion specific to Israel/Palestine.⁹¹

Vector 3 - Venture capital and Israeli technology sector:

AXA Venture Partners explicitly lists Israel as a core operating geography.³⁵³⁶ AVP raised a US $150 million second Early Stage fund in 2021.³⁵ The Hub Security investment (documented in Military) and the historical Neura investment (documented in Military and Digital) represent venture-capital exposure to Israeli technology firms with varying degrees of military intelligence lineage.

CAF investment: Documented in Military above. AXA IM’s holding in CAF - if retained - constitutes financial exposure to settlement-connectivity infrastructure in the post-Advisory Opinion period.

No public evidence identified of: AXA functioning as a buyer, importer, or supply chain participant for goods originating from Israel or the occupied territories; AXA-branded R&D or innovation infrastructure physically located in Israel; or AXA IM holding Israeli sovereign bonds as a disclosed line item.

Counter-Arguments and Evidence Limits

Substantial divestment record: AXA has executed a documented programme of divestment from Israeli bank holdings and Elbit Systems under sustained campaign pressure. Campaign groups Ekō and IPSC Ireland characterised the June 2024 divestment milestone as a “near-complete” victory;⁶¹⁷⁴ BDS Ireland publicly declared it a “huge victory.”⁷⁴ This track record demonstrates responsiveness to stakeholder concerns and distinguishes AXA from companies that have maintained Israeli financial exposure without engagement.

AXA IM sale to BNP Paribas: The sale of AXA Investment Managers to BNP Paribas (completed July 2025) transfers primary responsibility for the ongoing defence portfolio to a new entity under a long-term partnership arrangement.³⁹⁴⁰ While AXA retains authority over product design, asset allocation, and asset-liability decisions under the partnership, the structural separation creates a degree of arm’s-length distance between AXA Group and the management of these holdings. This is a meaningful exculpatory argument, though its force depends on the specific terms of the partnership agreement.

Defence holdings: conventional weapons, not prohibited categories: AXA IM’s exclusion policy covers cluster munitions, anti-personnel mines, biological and chemical weapons, and nuclear weapons outside recognised nuclear-armed states.⁸⁹⁹⁰⁹¹ The arms manufacturers in which AXA IM holds positions - Boeing, Lockheed Martin, RTX, BAE Systems, and others - are conventional defence contractors supplying mainstream military equipment to many governments, including NATO members and US allies. Their weapons systems are in documented use by the IDF, but the companies themselves are not classified as prohibited actors under AXA’s stated exclusion framework.

Passive index-tracking: The residual Bank Leumi position (~16,000 shares, ~$130,000) was attributed to passive index-tracking rather than active strategic investment intent.⁶⁰⁶¹⁶² The same argument may apply to some defence holdings if they are held as part of broad market index funds. No primary confirmation of this argument from AXA disclosures has been identified.

No Israeli sovereign bond exposure confirmed: AXA IM’s exclusion policy does not categorically exclude Israeli sovereign debt instruments, and the full fixed income portfolio is not publicly itemised at country-of-issuance level.⁹¹ However, no public evidence has been identified confirming actual Israeli sovereign bond holdings as a disclosed line item.

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

The Political mechanism of involvement for AXA is corporate communications silence and differential responsiveness on the Gaza conflict, contrasted with named condemnation and active sanctions enforcement following Russia’s 2022 invasion of Ukraine.

Corporate communications gap:

AXA Chief Executive Thomas Buberl stated at the April 2024 AGM that “Axa does not take a position on this serious geopolitical crisis,” adding “Our thoughts are with the civilian victims.”⁹³ No AXA corporate press release naming Hamas, Israel, or Gaza in a morally attributed manner has been identified in the company’s newsroom.⁹⁴ No AXA corporate statement acknowledging or responding to the ICJ’s July 2024 Advisory Opinion or the ICC arrest-warrant proceedings has been identified.⁹⁴

Contrast with Ukraine response:

On the 2022 Russian invasion of Ukraine, AXA issued a named corporate response: the company “condemned the invasion of Ukraine and its devastating human consequences,” fully enforced international sanctions, halted new underwriting and renewals for Russian-owned assets, ceased new reinsurance underwriting of Russian insurers, discontinued all new investments in Russian assets, and removed its directors from the board of its Russian minority holding Reso Garantia.⁹⁵ AXA pledged a €6 million donation to NGOs supporting Ukraine, distributed in tranches to UNICEF, UNHCR, and French NGOs.⁹⁵

No comparable AXA corporate statement of condemnation, declared investment halt, or humanitarian pledge of equivalent scale specifically directed to Gaza relief has been identified in the public record relating to the October 2023 Gaza war.⁹³⁹⁴ Civil-society groups publicly characterised AXA’s quiet divestment from Israeli banks (without ethical framing) as a “silent boycott”; the characterisation was advanced by campaign groups Ekō and the BDS movement and was also cited by UK parliamentarians.⁹³

“Zero investments in Israeli banks” statement:

At the April 2024 AGM, Buberl stated that AXA holds “zero investments in Israeli banks, direct or indirect.”⁹⁶⁷⁶ This statement was made in response to a shareholder question raised through Ekō concerning AXA’s documented holdings in Bank Hapoalim. AXA framed the divestment as a portfolio matter rather than as a stated human-rights or ethical decision.⁹⁶⁹⁷ As documented in Economic, a residual Bank Leumi position of approximately 16,000 shares remained at this date;⁶⁰⁶¹⁶² whether this position was subsequently wound down is not confirmed in public sources.

Buberl condemnation of boycott protests:

Buberl publicly condemned protests and direct actions targeting AXA, stating: “I would like to strongly condemn the physical attacks suffered by our agents and employees in some countries by the group supporting the boycott of Israel. These acts of vandalism are unjustifiable and unjustified.”⁹⁸⁹³

Human rights governance:

AXA publishes a vigilance plan under France’s Devoir de vigilance (Loi de Vigilance) and states it is “committed to respecting internationally recognised human rights principles as defined by the United Nations Universal Declaration of Human Rights.”⁹⁹ AXA’s human-rights and vigilance-plan disclosure page contains no mention of Israel, Palestine, the occupied territories, or the Gaza conflict.⁹⁹

No public evidence identified of: AXA registering any lobbying activity specifically on Israel-Palestine policy, BDS legislation, or related trade issues;⁹⁴ AXA directing corporate donations, grants, or sponsorships to parastatal Israeli organisations, settlement bodies, or military-welfare funds;⁹³⁹⁴ AXA directing corporate logistics, free services, infrastructure, or physical assets to Israeli state, military, or state-aligned efforts during or after October 2023;⁹³⁹⁴ or any current named AXA director holding a board seat in an Israeli state-affiliated institution or geopolitical advocacy body.¹⁰⁰

Counter-Arguments and Evidence Limits

Legitimate neutrality position: AXA is a global financial services company with operations in more than 50 countries, including Israel. A company may legitimately decline to take positions on geopolitical conflicts, particularly where doing so could expose employees, agents, or operations in conflict zones to harm. The “does not take a position” framing is a defensible corporate neutrality position, not evidence of active support for either party.

Divestment as implicit response: AXA’s divestment from Israeli banks - substantially completed by June 2024 - could be characterised as a substantive policy response to campaign concerns, even if not framed in ethical or human-rights terms. The framing difference (portfolio management vs. human-rights decision) may reflect legal, regulatory, or commercial considerations rather than indifference.

Ukraine comparison has limits: The Russia-Ukraine context differs materially from Israel/Palestine in ways that may justify differential corporate responses. Russia’s invasion of Ukraine triggered an unprecedented coordinated sanctions regime, creating immediate legal compliance obligations that the Gaza conflict has not generated in equivalent form. AXA’s Ukraine response was partly a sanctions-enforcement response, which has a different legal character than a voluntary ethical divestment from Israeli financial institutions.

Active stewardship: AXA IM publishes a Stewardship & Active Ownership Report covering engagement and voting activities.¹⁰¹ While no AXA IM stewardship engagement specifically targeting Israeli companies or operations in the occupied territories has been publicly documented as a named engagement case in the 2024 report,¹⁰¹ active ownership through engagement rather than divestment is a legitimate and potentially more sustainable approach to responsible investment.

Governance separation - AXA IM sale: The sale of AXA Investment Managers to BNP Paribas (completed July 2025) creates structural distance between AXA Group and the management of the ongoing defence portfolio.³⁹⁴⁰ This structural change may limit the ongoing relevance of the Political assessment for AXA Group as a distinct corporate entity.

Named Entities and Evidence Map

BDS-1000 Score (V4)

• V_MAX: 4.74 Sum_OTHERS: 5.32
• BRS Score: 363 Tier: D (Moderate)

The BRS score of 363 reflects a company whose primary documented Israel/Palestine nexus is economic and financial rather than operational or direct. The Economic domain (V=4.74) drives V_MAX, driven by the scale (~$150M in arms manufacturer holdings) and proximity (ongoing post-ICJ Advisory Opinion, no confirmed divestment) of AXA IM’s defence-sector portfolio investments, combined with the CAF infrastructure investment serving occupied East Jerusalem. The Military domain (V=2.30) captures the AVP/Hub Security nexus - a venture-capital stake in a company with active IMOD contracts and documented wartime digital defence engagement, with no confirmed divestment. The Political domain (V=2.48) reflects the communications gap: named condemnation and active sanctions enforcement for Ukraine, contrasted with silence and portfolio-management framing for Gaza. The Digital domain (V=0.54) is the lowest-scoring vector, finding a confirmed commercial customer relationship with Israeli-R&D-based Verint for contact-centre analytics but no evidence of military or surveillance end-use.

Method: Scale-free Impact × Magnitude / Proximity, evidence-only, human-vetted. Each domain score (V) is computed as I × M × P / 9, capped at the stated maximum. The BRS is the sum of all domain scores scaled to 1,000. Scores reflect only audit-documented evidence; allegations that did not withstand verification were rejected or reduced during human vetting.

Methodology Note

• Evidence-only basis: All substantive findings trace exclusively to the four domain audits (Military, Digital, Economic, Political). Claims marked as unverified, partially verified, or discarded in the audits are excluded from substantive findings. Evidence gaps are noted where relevant.
• Scale-free scoring: Impact (I) measures activity type severity; Magnitude (M) measures scale; Proximity (P) measures directness. Each V-domain score = I × M × P / 9, producing a scale-free metric.
• Temporal rule: Divested or exited operations are discounted; historical closed exposures (e.g., Neura 2016–2019) are noted as closed. Ongoing holdings at the time of escalation or post-ICJ Advisory Opinion carry higher proximity scores.
• Entity attribution: No transitive guilt is imputed. Israeli-origin vendors’ other clients, founders’ military backgrounds, or parent groups’ separate activities are not attributed to AXA. AXA’s financial/investment exposure to Israeli banks and arms manufacturers is the subject of Economic, not Digital.
• Settlement operation dual-counting: CAF’s Jerusalem Light Rail construction serves both Economic (financial investment in settlement-adjacent infrastructure) and Political (settlement consolidation in occupied territory). Both domains capture the same underlying activity from different analytical angles.
• “No public evidence identified”: This formulation is used wherever audit checks found nothing, including for direct defence contracts, Israeli sovereign bonds, physical goods supply chains, AXA-branded Israeli R&D infrastructure, and AXA’s provision of technology to Israeli state or military bodies.

End Notes