BDS-1000 Dossier: Subway Restaurants

Key Findings

• Economic: Subway operated a historical Israeli franchise of 23 kosher outlets between 1992 and 2004; the operation closed following the original franchisee’s death and subsequent re-entry attempts in 2009 and 2014 produced no operating restaurants.¹²
• Digital: Payment-processing partner Adyen (Dutch-headquartered) acquired Israeli startup Zooz (Tel Aviv-founded) in 2018 and maintains a Tel Aviv R&D office; this represents a commercially mediated, third-party connection rather than a direct Subway–Israeli relationship.³⁴
• Not found: No current Israeli operational presence, no defence contracts, no settlement supply chain, and no political nexus with the Israeli state or military were identified across all four domain audits; BRS 0 / Tier E.

Classification: Public – Documentary Forensic Dossier Subject Entity: Subway IP LLC / Doctor’s Associates LLC (trading as Subway) Dossier Version: V4 (Human-Vetted) Dossier Date: June 2026

Target Profile

Key Facts: Founded 1965, Bridgeport, Connecticut, USA.

Executive Summary

Subway is a global quick-service restaurant franchisor headquartered in the United States, acquired by private-equity firm Roark Capital Group in April 2024 for approximately $9.55 billion, ending more than five decades of founding-family ownership. The company operates exclusively as a franchise model, holding intellectual property and supplying approved supplier frameworks, while individual franchisees own and operate outlet locations. As of November 2025, no operational Subway franchise exists in Israel, the West Bank, East Jerusalem, or the Golan Heights.

Subway’s historical Israeli presence consisted of a peak of 23 franchised kosher outlets operating between 1992 and 2004. This operation closed following the death of its original franchisee and was not revived. Multiple subsequent attempts to re-enter the Israeli market in 2009 and 2014 failed to produce operating restaurants. The Who Profits Research Center holds no active record for Subway as of this audit cycle. Subway is not named in the UN OHCHR February 2020 database of businesses involved in Israeli settlement activity.

Across the four domain audits - Military (Military), Digital (Digital), Economic (Economic), and Political (Political) - no public evidence was identified linking Subway to Israeli defence contracting, settlement-proximate economic activity, Israeli-state technology partnerships, or pro-Israel political lobbying. The sole documented technology relationship bearing an Israeli dimension is Subway’s payment-processing partnership with Adyen, a Dutch-headquartered fintech that acquired Israeli startup Zooz (Tel Aviv-founded) in 2018 and maintains a Tel Aviv R&D office. This represents a passive, commercially mediated connection to Israeli technology development within a Dutch-headquartered third-party vendor, not a direct Subway–Israeli state relationship.

The remaining evidentiary record is characterised by absence: no defence contracts, no settlement investment, no settlement-franchise locations, no political donations, no institutional lobbying, no state partnerships. The one noted political-activism finding - Ukraine’s National Agency on Corruption Prevention (NACP) adding Subway to its “international sponsors of war” list in January 2024 - concerns Russian operations, not Israeli activity, and is included here as a documented regulatory action bearing on the franchise-autonomy defence’s credibility.

The human-vetted V4 scoring reflects this evidentiary record: all domain scores are 0.00, producing a BRS of 0 and a Tier E (Minimal) classification.

Timeline of Relevant Events

Corporate Overview

Ownership Structure

Subway operates through two principal US-incorporated legal entities: Doctor’s Associates LLC (the original operating entity) and Subway IP LLC (the intellectual-property holding entity). Both entities are domiciled in the United States and have no Israeli corporate lineage, incorporation, or secondary domicile.¹⁸¹⁹²⁰

From 1965 to April 2024, Subway was privately held by the DeLuca and Buck families. Fred DeLuca (co-founder, 1947–2015) and Peter Buck (co-founder, 1930–2021) established the company’s documented philanthropy through separate foundations focused on scholarships, medical research, journalism, and land conservation. No Israel-directed grants were identified in available reporting for either foundation.^21222324

On 30 April 2024, affiliates of Roark Capital Group - an Atlanta, Georgia-based private-equity firm - completed the acquisition of Subway for approximately $9.55 billion.^1418161517 Roark Capital’s portfolio is concentrated in US franchise and food-service brands including Inspire Brands (Arby’s, Buffalo Wild Wings, Sonic), Dunkin’, Auntie Anne’s, Cinnabon, and others.²⁵²⁶ No Israeli-domiciled company, Israeli sovereign bond, or Israel-focused investment vehicle has been identified in Roark Capital’s publicly described portfolio.²⁵²⁶ The firm does not publicly disclose its limited-partner base, which is standard for US private equity.

Franchise Model

Subway’s global operating model is asset-light: the franchisor holds intellectual property and maintains approved supplier frameworks, while individual franchisees own and operate outlet locations and source locally from franchisor-sanctioned supplier lists.²⁷ This structure means that the franchisor (Subway IP LLC / Doctor’s Associates LLC) holds minimal physical infrastructure globally. Country-level revenue breakdowns are not publicly disclosed; the company is privately held.

Israeli Entities and Franchise Relationships

No current Israeli master franchisee, joint venture, or wholly-owned subsidiary relationship has been identified for Subway. The historical Israeli franchise operation (1992–2004) was owned and operated by a named individual franchisee, not by Subway corporate. The identity and corporate structure of the Israeli master franchisee - past or present - is not documented in available public sources.²⁸

Multiple attempted re-entries into the Israeli market (2009, 2014) did not result in operating restaurants. The Who Profits Research Center holds no active record for Subway (the company URL returned HTTP 404 on review).²⁹ Subway does not appear on the BDS Movement’s corporate boycott-targeting guidance, which lists other fast-food brands including McDonald’s, Burger King, Papa John’s, Pizza Hut, and Domino’s.³⁰

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified of any direct or indirect mechanism linking Subway to Israeli military activity, defence contracting, or occupation-related infrastructure.

The audit assessed six categories: direct defence contracting and procurement; dual-use products and tactical variants; heavy machinery, construction, and infrastructure; supply chain integration with defence primes; logistical sustainment and base services; and munitions and weapons systems. In every category, the finding is “No public evidence identified.”³¹–³²

Specifically:

• IMOD/IDF Contracts: No verified contracts, tender awards, framework agreements, or memoranda of understanding between Subway and the Israeli Ministry of Defence, Israel Defence Forces, Israel Prison Service, or Israel Border Police appear in any publicly available procurement record, corporate disclosure, or investigative report.³³
• SIBAT Listings: Subway does not appear in SIBAT (Israel Defence Export and Defence Cooperation Directorate) export directories, international defence exhibition catalogues, or Israeli defence procurement registries.³⁴
• Dual-Use Products: Subway’s product range consists exclusively of food-service items. No ruggedised, tactical, mil-spec, or defence-grade variants are publicly marketed, documented, or reported as sold to Israeli security forces.³²
• Export Licences: No export licence applications, end-user certificates, or government export control reviews related to Subway’s sales to Israeli defence or security end-users appear in UK, US, or EU export control registers.³⁴
• Construction and Infrastructure: No verified reports, NGO investigations, photographic evidence, or UN documentation places Subway-branded or Subway-supplied equipment in the context of settlement construction, the separation barrier, checkpoints, or military installations.³⁵³⁶³⁷
• Defence Prime Supply: No verified supply relationships exist in which Subway provides components, sub-systems, raw materials, or manufacturing services to Elbit Systems, Israel Aerospace Industries, Rafael, or any other Israeli defence prime contractor.³⁸³⁴
• Base Services: No verified contracts for catering, facilities maintenance, or support services to IDF bases, military training facilities, or detention centres have been identified. A documented presence on US military bases via AAFES/MWR programmes exists but is entirely outside the geographic and jurisdictional scope of this audit.³²
• Munitions and Weapons: Subway has no documented role in lethal systems manufacturing, munitions supply, or strategic defence platform supply in any jurisdiction.³⁸³⁴
• NGO Investigation: No NGO - including Who Profits, Amnesty International, Human Rights Watch, AFSC, or Corporate Occupation - or academic institution or UN body has published an investigation specifically addressing Subway’s military, security, or dual-use supply chain relationship with the Israeli state.^31353637

One evidentiary gap is acknowledged: whether ingredients supplied to Subway franchise locations operating in Israel (historical) sourced from settlement-based agriculture or settlement-adjacent food processing facilities is not documented in any publicly available supply chain audit.³¹²⁸ This gap could not be resolved through available sources and constitutes an open evidentiary question for the historical operating period.

A second gap: whether Subway franchise locations operated within Area C of the West Bank, East Jerusalem, or Israeli settlements - as distinct from internationally recognised Israeli territory - is not definitively documented. The Who Profits database has not specifically catalogued individual Subway outlet locations by settlement status.²⁸

Counter-Arguments and Evidence Limits

Subway’s strongest counter-argument in this domain is structural: as a submarine-sandwich franchisor, the company’s business domain is entirely civilian. The company manufactures no components, operates no dual-use infrastructure, and provides no services that could plausibly sustain military operations. The “Iron Sandwich” allegation framework - that Subway’s scale creates passive financial flows supporting Israeli military activity through general taxation - is not specific to Subway and would apply equally to any large taxpayer operating in Israel.

The documented AAFES/MWR presence on US military bases demonstrates that Subway has navigated military-base access arrangements where such arrangements exist, but this is documented exclusively for US installations, is commercially standard (cafeteria concessions on military bases are routine), and is entirely outside the scope of this audit’s geographic focus.

The evidentiary limit most favourable to Subway is the absence of any civil-society investigation targeting its military nexus. BDS campaign listings that include Subway are based on its historical and (alleged) current commercial presence in Israel, not on any documented defence supply chain - a distinction the audit explicitly records.³⁹²⁸

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

The Digital audit identified one documented technology relationship bearing an Israeli dimension: Subway’s payment-processing partnership with Adyen, a Dutch-headquartered fintech.⁹

In December 2019, Subway formally announced a partnership with Adyen to advance its payment experience across North American locations.⁹ Adyen acquired Israeli fintech startup Zooz in 2018. Zooz was founded in Tel Aviv and developed payment-routing optimisation technology (“smart routing”). Following the acquisition, Adyen maintained the Tel Aviv operation as an active R&D office, described on its own careers pages as a continuation of the Zooz team.³⁴ The practical consequence is that Subway’s transaction-routing logic for North American locations runs on infrastructure with code development and maintenance activities occurring at Adyen’s Tel Aviv R&D centre.³⁴ This constitutes a passive, commercially mediated connection to Israeli technology development within a Dutch-headquartered third-party vendor’s R&D infrastructure.

A second documented relationship exists with Capgemini, which Subway engaged as a strategic digital transformation partner during its “Project Future” modernisation programme (announced 2021).¹⁰¹¹ Capgemini published a client case study confirming the engagement and quoting Subway’s CIO directly. However, the case study does not name specific security, cloud, or infrastructure vendors deployed within the engagement; the possibility that Capgemini’s own partner stack introduces Israeli-origin tooling cannot be assessed from available public sources.¹⁰

The prior-generation research (the “Iron Sandwich” report) asserted relationships between Subway or its parent company Inspire Brands with several Israeli-origin cybersecurity vendors: Wiz, SentinelOne, Check Point, Bionic.ai / CrowdStrike, CyberArk, NICE, and Verint.^{4041424344454647} Each of these claims has been individually assessed and not sustained by primary-source evidence:

• Wiz: The prior report cited a technographic aggregator page (Himalayas.app), not primary corporate disclosure. Wiz has not published a comprehensive customer list. No primary-source evidence confirming deployment at Subway or Inspire Brands has been identified.⁴⁸
• SentinelOne: The prior report cited an AMG Pantheon Master Fund Schedule of Investments - a third-party multi-manager fund filing, not a Roark Capital disclosure. This does not establish a direct investment by Roark Capital in SentinelOne or a contractual relationship between Subway and SentinelOne.⁴⁹⁵⁰
• Bionic.ai / CrowdStrike: The Globes article confirming Bionic.ai’s acquisition by CrowdStrike does not reference Inspire Brands as a customer. No primary-source evidence identified.⁴⁴
• Check Point, CyberArk, NICE, Verint: No primary-source evidence of licensing, subscription, or deployment relationships with Subway or Inspire Brands has been identified in training data.⁴⁶⁴⁷⁴⁵

In surveillance and biometrics: PopID (a US-based subsidiary of Cali Group) was piloted at some Subway locations in 2020 for COVID-19 temperature screening and “face pay” capability.⁵¹ PopID is not of Israeli origin. Post-2021 deployment status is unknown. No evidence identified of Subway relationships with Israeli-origin facial recognition companies Oosto (formerly AnyVision) or Trigo Retail.⁵²⁵³

The Shekel Brainweigh hypothesis - that an Israeli IoT weight-sensor company may supply OEM hardware for Subway’s “smart fridge” concept locations - is assessed as inferential. The Subway newsroom release confirms weight-sensor shelves exist but does not name the OEM supplier.⁵⁴

Project Nimbus (the confirmed $1.2 billion Google Cloud / AWS contract to provide cloud infrastructure to the Israeli government and military) is not a Subway contract. The prior report’s framing - that Subway’s cloud expenditure indirectly supports Project Nimbus through aggregate hyperscaler revenue - represents an inferential chain applicable to any enterprise customer of Google Cloud or AWS globally, not a direct or distinguishing relationship.⁵⁵

Counter-Arguments and Evidence Limits

Subway’s strongest counter-argument in this domain is that the Adyen/Zooz connection is entirely indirect: Subway contracted with a Dutch-headquartered, Amsterdam-listed fintech company for payment processing. Adyen’s decision to maintain a Tel Aviv R&D office following an acquisition is a corporate staffing decision by Adyen, not a contractual relationship between Subway and any Israeli entity. The R&D office develops payment-routing technology used globally; Subway neither selected nor directed the Tel Aviv location.

The counter-argument is substantively accurate: there is no evidence that Subway directed, specified, or had knowledge of Adyen’s acquisition of an Israeli company or the location of its R&D staff. The connection is structural and passive, mediated entirely through a third-party commercial relationship. No evidence of any security-sector connection through this channel has been identified.⁹³⁴

With respect to the failed prior-report claims (Wiz, SentinelOne, Check Point, etc.), the counter-argument is simply that these relationships were not supported by the primary-source evidence and were correctly excluded from the audited record. The prior report conflated fund-investment schedule filings with direct investment, and technographic aggregator pages with corporate disclosures.

The evidentiary limit in this domain is the absence of primary-source disclosure on Subway’s technology stack. As a privately held company, Subway is not required to publicly disclose its vendor relationships, making comprehensive verification dependent on voluntary disclosure, investigative journalism, or NGO documentation - none of which has specifically targeted Subway’s technology stack in this context.

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

No public evidence identified of any current economic relationship between Subway and the Israeli state, Israeli settlements, or the occupied territories.

Supply Chain and Sourcing: Subway does not publish a global supplier list. Ingredient sourcing is managed at the franchise/regional level under franchisor-sanctioned supplier frameworks.²⁷ No current commercial relationship between Subway and any named Israeli agricultural exporter (Mehadrin, Hadiklaim, Galilee Export, or any successor to Agrexco/Carmel) has been identified in corporate disclosures, NGO databases, or trade press.⁵⁶⁵⁷ During the historical Israeli operating period (1992–2004), the then-active Israeli franchise sourced certain ingredients - including dairy products from Tnuva, an Israeli dairy cooperative - to meet kashrut requirements; this relationship is documented as belonging to the pre-2004 operating period.¹² No named Israeli agricultural aggregator or settlement-origin supplier has been identified in connection with Subway’s current global supply chain.

No NGO investigation, regulatory citation, customs record, or DEFRA audit finding names Subway in connection with settlement-origin produce.⁵⁶⁵⁷³⁰ Subway does not appear among the companies named in the BDS Movement’s corporate boycott-targeting guidance.³⁰

Investment and Capital: No direct capital investment by Subway - under Roark Capital or prior DeLuca/Buck family ownership - within Israel or the occupied territories has been identified, including acquisitions, manufacturing facilities, data centres, logistics hubs, or real estate.¹⁴¹⁸ Subway’s asset-light franchise model means the franchisor holds minimal physical infrastructure globally.

No Subway R&D facility, technology partnership, innovation laboratory, or accelerator programme within Israel has been identified; Subway’s disclosed innovation function is located at its Miami, Florida headquarters.¹⁹

Roark Capital’s publicly described portfolio shows no Israeli-domiciled company, Israeli sovereign bond, or Israel-focused investment vehicle.²⁵²⁶ The LP base is not publicly disclosed, which is standard for US private equity.

Operational Presence: Subway’s documented Israeli economic footprint is historical: a peak of 23 franchised outlets operating 1992–2004, now defunct. As of November 2025, Subway maintains no operational franchises in Israel.⁵ No Subway location in the West Bank, Gaza, or the Golan Heights has been identified.⁵⁶⁵⁷⁵

Profit Flows: With no identified active Israeli franchise operations, no current royalty or fee flow either into or out of Israel has been identified.⁵ Under Subway’s franchise model, royalties and fees flow from franchisees to Subway’s US entities, not to an Israeli-domiciled beneficiary.

Counter-Arguments and Evidence Limits

Subway’s strongest counter-argument in this domain is structural: the company operates no stores in Israel and therefore derives no revenue, royalties, or fees from Israeli operations. The historical presence (1992–2004) ended nearly two decades ago, predating the period of most intensified BDS campaign focus. The multiple failed re-entry attempts (2009, 2014) demonstrate that Subway has not sought to re-establish an Israeli economic footprint.

The Tnuva sourcing reference - while documented - belongs to the pre-2004 operating period and reflects a routine ingredient-sourcing arrangement by an independent franchisee meeting local regulatory requirements (kosher certification), not a strategic economic relationship with the Israeli state.

The evidentiary limit most favourable to Subway’s counter-argument is that the Who Profits Research Center - the primary NGO tracker of corporate involvement in Israeli settlement activity - holds no active record for Subway (HTTP 404 on review).²⁹ Subway’s absence from the UN OHCHR February 2020 settlement database further supports the absence of documented settlement-proximate economic activity.⁵⁸

The evidentiary limit most challenging to Subway is the opacity of its approved-supplier frameworks: because ingredient sourcing is managed at the franchise/regional level without franchisor-level public disclosure, it is not possible to definitively rule out third-party settlement-adjacent sourcing through distributors. This gap is acknowledged as an open evidentiary question, not an established finding.

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

No public evidence identified of Subway directing political lobbying, financial contributions, or institutional financing toward Israeli state interests, pro-Israel organisations, or settlement-linked groups.

Corporate Communications: No named, dated corporate statement by Subway, Doctor’s Associates LLC, Subway IP LLC, or Roark Capital Group addressing the 7 October 2023 Hamas attack, subsequent Israeli military operations in Gaza, ceasefire calls, or the Israel-Palestine conflict as a geopolitical matter has been identified.⁵⁹⁶⁰ Subway’s documented posture is one of political non-engagement: in response to a consumer enquiry during the boycott period, Subway stated that franchisees independently own and operate each outlet and that political engagement is “one of the consistent behaviours that we do not engage in.”⁶¹

Lobbying: Subway is privately held and not subject to public-company disclosure requirements. Per OpenSecrets, neither Subway Inc nor Roark Capital Group reported federal lobbying or outside political spending in the 2024 election cycle.⁶²⁶³ No public evidence identified of Subway lobbying on anti-BDS legislation, Israel trade agreements, settlement-trade rules, or Middle East security policy. No public evidence identified of Subway corporate membership of, or funding for, pro-Israel lobbying organisations.

Political and Financial Contributions: No public evidence identified of Subway corporate, Doctor’s Associates LLC, Subway IP LLC, or Roark Capital Group directing donations to the Friends of the Israel Defense Forces (FIDF), the Jewish National Fund (JNF), Israel Bonds, settlement-linked groups, or Israeli military-welfare funds.⁶²⁶³

The Frederick A. DeLuca Foundation (co-founder Fred DeLuca, d. 2015) is documented as funding scholarships, autism care, and cancer research. The Peter and Carmen Lucia Buck Foundation (co-founder Peter Buck, d. 2021, receiving ~50% of Subway as a 2023 bequest estimated at ~$5 billion) focuses on education, journalism, medicine, and land conservation. No Israel-specific grants were identified in available reporting for either foundation.^21222324

Founding and State Partnerships: Subway was founded in 1965 in Bridgeport, Connecticut by Fred DeLuca and Peter Buck. No military, defence-sector, or state-security origin features in the founding narrative. No Israeli state honours, formal partnerships with Israeli governmental institutions, participation in Israeli public-diplomacy campaigns, or “Brand Israel” programme involvement has been identified.⁶⁴⁶⁵

Executive Leadership: No public statements, op-eds, signed letters, or attributable social-media posts by Subway executives or Roark Capital principals specifically addressing the Israel-Palestine conflict were identified. No Subway executives or Roark Capital partners hold documented board seats or advisory roles in AIPAC, Israel Bonds, FIDF, JNF, or equivalent organisations in their Subway capacity.⁶⁶¹⁵⁶⁷

One Documented Regulatory Action - Russia, Not Israel: Ukraine’s NACP added Subway to its “international sponsors of war” list in January 2024, citing Subway’s continued Russian operations (550 restaurants, 122 cities) after the February 2022 invasion.¹²¹³ The NACP characterised Subway’s franchise-autonomy defence as “untrue and misleading,” asserting that when Russian banks blocked royalty payments in May 2022, Subway engaged legal counsel to devise mechanisms to collect and transfer royalties to its corporate holding company.¹² This finding concerns Russian operations and is included here as a documented regulatory action bearing on the credibility of Subway’s franchise-autonomy defence in any jurisdiction. It does not relate to Israeli activity.

Counter-Arguments and Evidence Limits

Subway’s strongest counter-argument in this domain is the comprehensive absence of documented political activity: no lobbying disclosures, no documented donations to named pro-Israel organisations, no state partnerships, no institutional ties. The political non-engagement posture - declining to take public positions on geopolitical conflicts - is documented and consistent across both the Israel/Palestine and Russia contexts.

The one significant evidentiary challenge to Subway’s franchise-autonomy defence comes from the NACP finding on Russia. The Ukrainian authority found that Subway’s claimed separation between corporate and franchisee operations was compromised by the company’s legal effort to maintain royalty flows from Russian franchisees during a period of international sanctions pressure.¹² This finding does not address Israeli activity and cannot be directly transposed; however, it establishes a documented precedent in which a regulatory authority found Subway’s franchise-autonomy framing to be materially inaccurate. The existence of this finding does not add evidence of Israeli political activity but is relevant to assessing the credibility of the company’s general governance posture.

The evidentiary limit in this domain is the privacy of private-equity ownership structures: Roark Capital does not publicly disclose its LP base. While no Israeli-domiciled LP or Israeli-focused fund has been identified in Roark’s publicly described portfolio, the complete LP structure cannot be confirmed from public records.

Named Entities and Evidence Map

BDS-1000 Score (V4)

• V_MAX: 0.00 Sum_OTHERS: 0.00
• BRS Score: 0 Tier: E (Minimal)

Score Rationale (2–3 sentences): All four domain scores are 0.00, producing a BRS of 0 and Tier E (Minimal). The maximum score across all domains (V_MAX) is 0.00, reflecting the complete absence of documented military, digital, economic-investment, or political-lobbying nexus with the Israeli state. The score results from the evidence-only methodology applied across all four audits: every assessed category returned “No public evidence identified” or documented the closure of Israeli operations (2004), the failure of subsequent re-entry attempts (2009, 2014), and the absence of current operational presence as of November 2025. The sole partial connection - Adyen’s Tel Aviv R&D office, a passive structural relationship mediated through a Dutch-headquartered third-party vendor - does not meet the threshold for a scored vector under the evidence-only framework.

Methodology Note

• Evidence-only standard: All findings are drawn exclusively from the four domain audits (Military, Digital, Economic, Political). No claims, relationships, or assessments have been added beyond what those audits documented. “No public evidence identified” is used in every instance where a domain category returned no verifiable public-source evidence.
• Scale-free Impact (I × M × P) scoring: Impact (I) reflects the activity type - whether the company’s core business involves a category of goods or services with inherent military, digital, economic, or political nexus. Magnitude (M) reflects the scale of the relationship. Proximity (P) reflects directness. Each domain score (V) is the product of the three factors; V_MAX is the highest single-domain score.
• Temporal rule: Divested or exited operations are discounted. Subway’s 2004 closure of Israeli operations and the failure of subsequent re-entry attempts (2009, 2014) are factored into the economic and operational presence assessments.
• Entity attribution: No transitive guilt applies. Parent-company ownership (Roark Capital) is assessed only for disclosed beneficial ownership of Israeli-domiciled assets or Israel-focused investment mandates; ordinary commercial lending, fund management, or LP exposure is not attributed.
• Settlement operations: If a company operates within Israeli settlements or the occupied territories, this dual-counts Economic (economic activity in occupied territory) and Political (political endorsement of annexation). No settlement operations have been identified for Subway.
• Franchise autonomy: The franchise-model structure means that franchisor-level and franchisee-level activities are assessed separately. Subway’s documented Russian operations and the NACP’s challenge to the franchise-autonomy defence are recorded as relevant governance findings but do not alter the Israeli-activity score in the absence of Israeli-specific evidence.

End Notes