BDS-1000 Dossier - Ryanair Holdings plc

Key Findings

• Operations: Ryanair operated scheduled services to Tel Aviv and Ramon Airport and described a “strong working relationship” with Israeli Ministries of Tourism and Transport in October 2022; routes were suspended following the October 2023 outbreak of war.¹²
• Political: A cabin crew member on flight FR3794 announced landing in “Tel Aviv in occupied Palestine” in June 2023; Ryanair apologised and issued a formal warning to the crew member.³
• Not found: No military or digital nexus identified; Military and Digital both score 0.00.

Target Profile

Key Facts: Fleet of Boeing 737-800 and 737 MAX 8/10, exclusively commercial passenger configuration. Primary subsidiaries: Ryanair DAC (Irish AOC), Ryanair UK (CAA), Buzz (Polish AOC), Lauda Europe (Austrian AOC).

Executive Summary

Ryanair Holdings plc is Ireland’s largest airline and one of Europe’s dominant low-cost carriers, operating scheduled passenger services across 40+ countries on an exclusively commercial business model. Its fleet, corporate structure, supply chain, and regulatory profile are entirely within the civil aviation mainstream: an all-Boeing commercial passenger fleet, no defence contracts, no weapons or dual-use technology involvement, and no identified beneficial ownership by state actors or sanctioned entities.

The airline’s documented Israel/Palestine nexus is narrow and operational in character. Ryanair operated scheduled services to Tel Aviv Ben Gurion Airport and Ramon Airport near Eilat prior to October 2023, suspended those routes following the outbreak of war (communicated as a safety/commercial matter), and has not publicly expressed political solidarity with or criticism of either party to the conflict. CEO Michael O’Leary’s identified public commentary on Israel has framed the airline’s return prospects in commercial terms directed at the Israel Airports Authority, not in terms of the conflict’s politics. The airline has been subject to two documented crew-conduct incidents involving political insignia, both of which Ryanair addressed through its stated policy against staff wearing political symbols.

The Military and Digital domains are entirely zero: no defence contracts, dual-use involvement, weapons activity, digital-military infrastructure, or defence-adjacent technology relationships have been identified. The Economic score is minimal (0.37), driven by a commercial Boeing fleet procurement relationship and the airline’s former multi-subsidiary structure, which included a Malta-registered entity previously used for fleet and crew structuring - with no evidence of Israeli entities in the supply chain. The Political score of 2.09 is the highest-domain score and reflects documented operational and governance incidents tied to Ryanair’s former Israeli routes and two crew-conduct episodes, none of which constitute active political advocacy or state partnership beyond routine commercial aviation relationships.

The resulting BRS of 135 places Ryanair in Tier E (Minimal), consistent with a company whose documented Israel/Palestine nexus is confined to a suspended commercial route and routine industry relationships. No evidence was identified of Ryanair being a named target of any formal BDS campaign, lobbying on Israel-Palestine policy, political donations to Israeli or pro-Israel bodies, or involvement in settlement trade.

Timeline of Relevant Events

Corporate Overview

Ryanair Holdings plc is incorporated under Irish law and headquartered in Swords, County Dublin. It is one of Europe’s largest low-cost carriers by passenger volume, operating exclusively short-haul scheduled passenger services on an all-Boeing 737 fleet. The group structure comprises several operating subsidiaries, each holding a separate Air Operator Certificate:

• Ryanair DAC - principal Irish-licensed operating carrier, primary AOC under Irish Aviation Authority/EASA authority
• Ryanair UK - UK CAA-licensed carrier established post-Brexit to preserve UK domestic cabotage rights
• Buzz - Polish-registered subsidiary operating short-haul routes primarily in Central and Eastern Europe
• Lauda Europe - Austrian AOC carrier, formerly Laudamotion, acquired from the estate of Niki Lauda

This multi-subsidiary structure was partly driven by EU airline ownership-and-control rules (EU Regulation 1008/2008), which require EU carriers to be majority-owned and effectively controlled by EU nationals, and post-Brexit, to ring-fence UK flying rights. Ryanair has been subject to European Commission scrutiny regarding continued compliance with the EU majority-ownership threshold given its Nasdaq listing and associated non-EU institutional shareholding¹³¹⁴.

Malta Air, previously a Malta-registered subsidiary used for fleet and crew structuring, was subsequently reabsorbed into the Ryanair DAC structure⁸.

No Israeli entities, franchise relationships, or subsidiaries have been identified within the Ryanair group structure. No beneficial ownership by Israeli state actors, sovereign wealth funds, or politically exposed persons from high-risk jurisdictions has been identified in publicly available corporate filings.

Institutional ownership is concentrated among large European and US asset managers. Capital Group held approximately 15% of voting rights as of April 2026; BlackRock, HSBC, Baillie Gifford, and Vanguard are among other significant institutional holders. CEO Michael O’Leary held approximately 3.9% as of March 2026¹⁵¹⁶.

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified that Ryanair Holdings plc holds, has held, or has tendered for any direct defence contract with any national government, military authority, or supranational defence procurement body. Ryanair’s published business model is exclusively focused on low-cost scheduled passenger aviation and ancillary passenger revenue¹⁷¹⁸.

Ryanair does not operate a cargo or freight division, which limits the pathways through which troop-lift, materiel transport, or logistics contracts typically enter a commercial airline’s revenue base. No records have been identified in EU or national procurement registers linking Ryanair to defence or security tenders.

Ryanair’s fleet consists entirely of Boeing 737-800 and 737 MAX 8/10 aircraft operated in standard commercial passenger configuration¹⁹. No evidence has been identified of Ryanair operating, having ordered, or having made available any aircraft in a tactical, surveillance, intelligence-gathering, or dual-use configuration. Fleet expansion orders - including the widely reported 2023 agreement with Boeing for up to 300 737 MAX aircraft - are documented purely as commercial passenger-capacity purchases²⁰. No government end-user certificates, dual-use export licences, or technology-control regime filings associated with Ryanair have been identified.

Ryanair’s primary supply chain relationships are with Boeing (aircraft), CFM International (LEAP-1B engines), and a range of MRO, catering, and ground-handling providers. Boeing and CFM International are both significant defence primes or subsidiaries thereof; however, Ryanair’s relationship with these companies is exclusively as a commercial end-user customer purchasing civil-certified aircraft and engines. No evidence has been identified of contractual arrangements, joint ventures, data-sharing agreements, or co-development programmes constituting integration into a defence supply chain¹⁹²⁰.

No public evidence identified of Ryanair providing logistical sustainment, base operating services, fuel supply, catering, or ground handling to any military installation or defence contractor in an operational military context. Ryanair purchases jet fuel (Jet A-1) through commercial bulk contracts; no evidence links these purchasing arrangements to military fuel supply chains or defence logistics frameworks.

Ryanair has no involvement - direct, indirect, or historical - in the manufacture, transport, storage, trading, brokering, or financing of munitions, weapons systems, missiles, armoured platforms, or any other strategic military hardware. The airline’s Air Operator Certificates and published terms and conditions explicitly exclude the carriage of dangerous goods beyond standard IATA passenger categories¹⁷²¹.

Ryanair’s regulatory and legal history is extensive but confined to civil aviation, consumer protection, labour relations, and competition law. No export licence applications, denials, or violations; no sanctions-related findings; no dual-use export control proceedings; and no arms-embargo breaches have been identified in connection with Ryanair in any jurisdiction²²²³²⁴.

No civil society investigation, NGO report, or journalistic inquiry has raised concerns about Ryanair’s involvement in defence contracting, arms supply chains, dual-use technology, or military operations.

Counter-Arguments and Evidence Limits

Ryanair’s strongest counter-argument in the Military domain is structural: it is a pure-play commercial passenger carrier with no cargo operations, no defence contracts, no dual-use technology involvement, and no identified pathways by which its civil aviation activities could feed into military supply chains. Its Boeing and CFM International relationships are indistinguishable from those of any major commercial airline purchasing civil-certified aircraft and engines.

The audit notes that Boeing and CFM International are significant defence primes - but this is true of virtually every major commercial aircraft manufacturer globally, and the evidence standard requires a specific contractual or operational link beyond routine commercial procurement. No such link has been identified for Ryanair.

Evidence limits: this audit relied on public corporate disclosures, regulatory registers, and civil society reporting. Classified or commercially confidential defence supply chain relationships not reflected in public filings would not be captured. The absence of evidence is accurately described as “no public evidence identified,” not a positive assertion of absence.

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

Ryanair operates one of the most digitally self-sufficient models in European aviation, with a strategy centred on direct distribution, proprietary systems, and selective third-party vendor relationships.

Ryanair’s core booking and reservation platform is built on a proprietary system, and the airline has historically resisted distribution through Global Distribution Systems (GDS) such as Amadeus, Sabre, and Travelport²⁵. The airline uses Navitaire (now an Amadeus company) as its passenger service system (PSS), which underpins reservation, check-in, and departure control functions. Ryanair Labs, the airline’s in-house technology division based in Dublin with an additional engineering hub in Madrid, builds and maintains ryanair.com, mobile applications, and internal tooling²⁶.

For payment processing, Ryanair works with major card networks and third-party payment service providers. The airline has used Salesforce for customer relationship management functions. Ryanair has publicly committed to a cloud-first strategy, with Amazon Web Services (AWS) identified as a primary cloud infrastructure provider for ryanair.com, its booking engine, and data analytics platforms²⁷²⁸. Microsoft Azure is also present via Microsoft 365 corporate productivity tooling.

Ryanair has publicly described the use of machine learning and algorithmic pricing across its revenue management systems, consistent with industry-standard revenue management practice at large low-cost carriers. Ryanair Labs has publicly stated its use of data science and ML tooling for personalisation on ryanair.com and has explored AI-assisted customer service tooling (chatbot and virtual assistant features)²⁶²⁹.

Biometric verification: Ryanair introduced a facial biometric verification process for customers booking through third-party online travel agencies (OTAs) such as eDreams, Kiwi.com, and Lastminute.com. Ryanair states this is a fraud-prevention measure to confirm passenger identity matches the booking³⁰³¹. Spain’s data protection authority, the AEPD, launched an investigation into whether this biometric data processing meets GDPR Article 9 requirements³². The European Consumer Organisation (BEUC) and multiple national consumer bodies have raised concerns about proportionality and lawfulness under GDPR³³.

No public evidence identified of Ryanair deploying in-cabin surveillance technology, facial recognition at boarding gates operated by the airline itself, or CCTV analytics beyond standard airport-operator infrastructure. No public evidence identified of Ryanair holding contracts with defence ministries, intelligence agencies, or military procurement bodies. No public evidence identified of Ryanair participation in any sovereign cloud programme, national cloud initiative, or government-directed data localisation arrangement. No public evidence identified of Ryanair having data centre or cloud infrastructure relationships with Chinese, Russian, or other non-Western hyperscalers.

No public evidence identified of Ryanair deploying AI systems in safety-critical aviation operations beyond standard avionics and flight management systems supplied by aircraft manufacturers.

Counter-Arguments and Evidence Limits

Ryanair’s strongest counter-argument in the Digital domain is that its technology stack is entirely conventional for a large European airline: AWS and Azure cloud infrastructure, Navitaire PSS, Salesforce CRM, and in-house consumer-facing applications. None of these relationships are defence-adjacent, and no evidence has been identified connecting any vendor relationship to surveillance infrastructure, intelligence cooperation, or military applications.

The biometric verification controversy is a data protection matter, not a military or political adjacency issue. Ryanair’s stated rationale (fraud prevention for OTA-sourced bookings) is internally consistent, and the AEPD investigation remains a regulatory compliance matter under GDPR rather than a finding of wrongdoing.

Evidence limits: the audit is based on publicly disclosed vendor relationships, press reporting, and technical blog content from Ryanair Labs. Code-level inspection of ryanair.com’s third-party analytics and advertising technology stack was not within scope; specific vendor identities at the code level are not consistently disclosed in public-facing documentation. A finding of “no public evidence identified” in sub-categories does not preclude undisclosed commercial arrangements.

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

Ryanair’s documented economic relationships with Israel are confined to the airline’s former scheduled passenger operations to Tel Aviv and Ramon Airport (Eilat). These routes were commercial in character, subject to standard bilateral air service agreements, and operated under the regulatory framework of the European Union Aviation Safety Agency (EASA) and the Irish Aviation Authority (IAA)³⁴.

Ryanair’s primary capital procurement relationship is with Boeing, the US-based aircraft manufacturer. The airline operates an all-Boeing 737 fleet and has placed among the largest orders in Boeing’s commercial history, including the 2023 agreement for up to 300 737 MAX aircraft³⁵³⁶. This Boeing relationship is a structural procurement dependency, not a targeted investment in or economic partnership with Israeli entities. Boeing is a US company; no Israeli-state nexus in Boeing’s ownership or control has been identified in the reviewed record.

Ancillary supply relationships - catering, ground handling, and fuel - are contracted on a regional or airport-by-airport basis across the European Economic Area and United Kingdom. No publicly identified supply contracts with state-owned enterprises in geopolitically sensitive jurisdictions have been found in available public disclosures. Fuel procurement is conducted through rolling forward-hedging programmes using standard commodity derivatives with undisclosed financial institution counterparties³⁷.

Ryanair’s North African operations, principally to and from Morocco, represent its furthest operational reach outside the EU/UK/EEA zone. No operational presence in Libya, Algeria, or other jurisdictions of heightened Economic concern has been identified.

No evidence of charter operations, wet-lease arrangements, or codeshare agreements with carriers registered in sanctioned or high-risk jurisdictions has been identified. No evidence of direct investment in, or capital flows to or from, entities domiciled in sanctioned states. No sovereign wealth fund holdings from high-risk jurisdictions have been identified in disclosed major shareholding registers.

Ryanair’s corporate structure included Malta Air, a Malta-registered subsidiary previously used for fleet and crew structuring. This arrangement was a standard aviation-industry structuring mechanism, not an Israeli-facing economic activity. Malta Air has since been restructured/reabsorbed into Ryanair DAC⁸.

As an Irish-domiciled holding company, Ryanair’s profits are subject to Ireland’s corporate tax regime (12.5% standard rate, transitioning to 15% minimum under OECD Pillar Two)³⁸. No evidence has been identified of profit-shifting arrangements, transfer pricing disputes, or tax authority actions involving jurisdictions of Economic concern.

Counter-Arguments and Evidence Limits

Ryanair’s strongest counter-argument in the Economic domain is that its Boeing procurement relationship is indistinguishable from that of any major commercial airline and reflects a routine civil aviation supply chain, not a targeted economic relationship with Israeli entities. The Malta Air subsidiary structure was a standard EU-industry compliance and efficiency mechanism, not an Israeli-facing economic activity.

The audit notes that Boeing is a significant US defence prime - but this is true of virtually every major commercial aircraft manufacturer globally (Airbus, Embraer, Bombardier all hold defence portfolios), and the evidence standard requires a specific contractual or operational link beyond routine commercial procurement. No such link has been identified for Ryanair.

Evidence limits: this audit relied on public corporate disclosures, regulatory filings, and trade press. Private contractual arrangements not reflected in public filings would not be captured. The absence of evidence is accurately described as “no public evidence identified,” not a positive assertion of absence.

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

Ryanair’s documented political adjacency to the Israel-Palestine conflict is the most substantive of the four domains, though it remains limited in scope and largely operational in character.

Operations in Israel: Ryanair operated scheduled passenger services to Tel Aviv Ben Gurion Airport and Ramon Airport near Eilat prior to October 2023. In a 27 October 2022 corporate announcement (“Ryanair launches biggest ever schedule to Israel”), the airline referred to “the strong working relationship we have developed with the Ministries of Tourism and Transport” and announced new routes including a new winter Tel Aviv route and four routes to Ramon Airport (Eilat)¹. Israel’s Minister of Tourism described Ryanair as “a great partner” in reaching a target of 10 million tourists annually by 2030, and the Eilat Hotel Association described Ryanair as “a pioneer and a leader of foreign carriers conducting flights to Eilat”¹. These are documented as commercial route-development and tourism-promotion relationships with Israeli ministries and the Israel Airports Authority; no separate political, diplomatic, security, or public-diplomacy agreement was identified¹.

Flight suspensions: Following the October 2023 outbreak of war, Ryanair suspended scheduled services to and from Tel Aviv Ben Gurion Airport. The suspension was communicated as an operational/safety and commercial matter, not as a political position²⁴. On 11 September 2025, CEO Michael O’Leary stated in Dublin that Ryanair may not resume Israeli flights, citing disputes with the Israel Airports Authority and framing the matter as commercial rather than political¹⁰.

Crew-conduct incidents: Ryanair maintains a stated policy that “it is not Ryanair policy for staff to wear badges, symbols or other items that might be considered political, divisive or potentially offensive to passengers or colleagues”¹¹¹². Two documented conflict-related episodes have arisen:

1. On 10 June 2023, on flight FR3794 from Italy to Tel Aviv, a cabin crew member repeatedly announced that the aircraft was landing in “Tel Aviv in occupied Palestine”³⁷. Ryanair apologised; CEO O’Leary stated in a letter to the Simon Wiesenthal Center that he was “100% satisfied that this was an innocent mistake with no political overtones or intent,” said it is not Ryanair policy to refer to Tel Aviv as being in any country other than Israel, and said the crew member received a warning³⁷.

2. On 21 February 2026, a complaint was received that a Ryanair staff member wore a badge depicting a clenched fist wrapped in a Palestinian flag at Stansted Airport help desk¹¹¹². Ryanair apologised, reminded staff of its policy, stated it opposes all forms of discrimination including antisemitism, and said the matter was under internal review¹¹¹². UK Lawyers for Israel (UKLFI) stated it appreciated Ryanair taking the issue seriously¹².

Comparative responsiveness (Ukraine): Following Russia’s February 2022 invasion of Ukraine, Ryanair publicly announced it was working with Irish and UK humanitarian organisations to carry relief supplies in the holds of scheduled flights to south-east Poland - described as the first time in roughly 30 years it had carried cargo - and stated it was carrying refugees around Europe at fixed low fares of €20, €30, and €50⁵⁶. Ryanair was publicly criticised for not matching competitor Wizz Air’s offer of free tickets to refugees, and the Polish ambassador and others called on it to drop prices further⁵⁶. No comparable Ryanair humanitarian mobilisation in connection with the Israel-Gaza conflict was identified⁵⁶.

BDS targeting: Ryanair is not named anywhere in the BDS National Committee’s “Guide to BDS Boycott,” whose consumer-boycott, organic-boycott, and pressure-target lists name companies including Chevron, Intel, HP, Microsoft, Carrefour, AXA, SodaStream, Disney+, WIX, Google, and Amazon - but not Ryanair³⁹.

Lobbying: Ryanair Holdings is registered in the EU Transparency Register with a Brussels office and states it is also registered on the Irish Register of Lobbying and other registers as required⁴⁰⁴¹. Its disclosed engagement covers EU policy on aviation, transport, consumers, competition, environment, and taxation. No public evidence was identified of Ryanair lobbying on Israel-Palestine policy, BDS or anti-BDS legislation, settlement-trade rules, or Middle East foreign policy. No public evidence was identified of Ryanair corporate membership of, or funding for, pro-Israel or pro-Palestinian advocacy organisations⁴⁰⁴¹.

Political donations: No public evidence was identified of Ryanair Holdings plc making corporate donations to Israeli parastatal bodies, settlement organisations, military-welfare funds (e.g. Friends of the IDF), or the Jewish National Fund.

Corporate structure: No controlling or special-purpose stake held by any Israeli state entity or sovereign-wealth fund was identified. No charter provision, founding document, or shareholder agreement tying Ryanair’s mission to the geopolitical goals of Israel or any other state was identified¹³¹⁴.

CEO Michael O’Leary: On 10 November 2024, O’Leary publicly endorsed Fine Gael Minister Peter Burke at a campaign launch in Mullingar, urging voters to support Fine Gael and Fianna Fáil while criticising the Green Party and Sinn Féin - a documented personal political intervention in Irish domestic politics, not connected to Israel-Palestine⁹. No public evidence was identified of any personal donation by O’Leary to FIDF, the Jewish National Fund, Israeli settlement bodies, Israeli military-welfare organisations, or to pro-Palestinian advocacy bodies, and no public evidence of any personal board or leadership role in such organisations⁹.

Board of Directors: No public evidence was identified of any current Ryanair board member holding a seat or advisory role on a pro-Israel or pro-Palestinian lobbying organisation, geopolitical pressure group, or state-aligned institution related to the conflict⁴²⁴³.

Counter-Arguments and Evidence Limits

Ryanair’s strongest counter-arguments in the Political domain are multiple and well-supported by the evidence record:

1. No political statements: Ryanair has not issued any named, dated corporate statement expressing political solidarity with or criticism of either party to the Israel-Palestine conflict. Its communications on Israel have been confined to operational advisories about flight suspensions and resumptions.

2. No political advocacy: No evidence has been identified of Ryanair lobbying on Israel-Palestine policy, BDS legislation, settlement trade, or Middle East foreign policy. The airline’s lobbying activities are documented in the EU Transparency Register and cover aviation, transport, consumers, competition, environment, and taxation - standard industry advocacy.

3. No named BDS target: Ryanair is not listed in the BDS National Committee’s boycott guide, which is the primary reference document for formal BDS targeting. The absence of Ryanair from this list is a documented finding.

4. Reactive crew-conduct management: The two documented crew-conduct incidents were handled through Ryanair’s stated policy against political insignia. In both cases, Ryanair apologised, reiterated its policy, and initiated internal review - demonstrating a reactive rather than politically motivated governance stance.

5. Divested/suspended operations: Ryanair’s Israeli operations have been suspended since October 2023, and CEO O’Leary has publicly stated the airline may not resume them. Under the temporal rule applied in this methodology, divested or exited operations are mitigated factors.

6. Not a settlement operation: No evidence was identified of Ryanair operating in the West Bank, Gaza, the Golan Heights, or other territory occupied in 1967. Its Israeli operations were confined to Tel Aviv and Ramon Airport, both within internationally recognised Israeli territory.

7. Comparative humanitarian response: While Ryanair’s Ukraine humanitarian response was criticised as insufficient by some observers, the existence of that response - and the absence of any comparable mobilisation for Israel - is documented. This cuts both ways: it demonstrates the absence of a pro-Israel political posture, not an active one.

Evidence limits: this audit relied on public corporate communications, lobbying-register disclosures, press reporting, and NGO/campaign materials. Private political communications, informal diplomatic contacts, or non-public representations to government officials not reflected in lobbying disclosures would not be captured. A finding of “no public evidence identified” in sub-categories does not constitute a positive assertion of absence.

Named Entities and Evidence Map

BDS-1000 Score (V4)

• V_MAX: 2.09 Sum_OTHERS: 0.37
• BRS Score: 135 Tier: E (Minimal)

The dominant driver of Ryanair’s BRS is the Political score of 2.09, which reflects the airline’s former scheduled operations in Israel, two documented crew-conduct incidents involving political insignia, and a documented commercial tourism-promotion relationship with Israeli ministries - all of which are operationally bounded and politically reactive in character rather than proactively advocacy-driven. Military and Digital are entirely zero; Economic is minimal, driven by the Boeing fleet procurement relationship and former Malta Air subsidiary structure. The tier classification E (Minimal) reflects a company whose documented Israel/Palestine nexus is narrow, commercially framed, and consistent with routine civil aviation activity.

Method: scale-free Impact × (magnitude × proximity), evidence-only basis, human-vetted. No claims are included that were not confirmed across the four domain audits.

Methodology Note

• Evidence-only basis: Every factual claim in this dossier traces to the four domain audits (Military, Digital, Economic, Political). Claims the audits marked unverified, unresolved, or divested are carried with those caveats or excluded. “No public evidence identified” is used wherever audit checks found nothing.
• Scale-free Impact scoring: Impact reflects activity type (Military = weapons/defence; Digital = surveillance/digital; Economic = economic; Political = political/advocacy). Magnitude (M) reflects scale; Proximity (P) reflects directness. Scores are human-vetted.
• Temporal rule: Divested, exited, or suspended operations are discounted. Ryanair’s Israeli route suspension since October 2023 is reflected in scoring.
• Entity attribution: No transitive guilt - supply chain relationships with defence-adjacent vendors (Boeing, CFM International) are scored only where a specific contractual or operational link beyond routine civil procurement is identified, which was not the case for Ryanair.
• Settlement operation dual-counting: Where a company’s operations constitute settlement activity, both Economic and Political scores apply. Ryanair’s Israeli operations were confined to Tel Aviv and Ramon Airport (within internationally recognised Israeli territory); no West Bank, Gaza, or 1967-occupied territory operations were identified.
• Human vetting standard: Several companies’ scores were reduced or zeroed during human vetting where allegations did not withstand verification. This dossier applies exactly that standard: fabricated claims were rejected; divested operations were discounted; wrong-entity attributions were removed; and soft claims were not hardened.

End Notes