V-MIL Audit — AXA Group (Euronext: CS)

Audit Phase: V-MIL (Military Forensics) Audit Date: 2026-05-01 Auditor Note: All findings are grounded exclusively in the existing audit and the updated research memo. Claims marked as unverified or discarded in the memo are excluded from substantive findings. Evidence gaps are noted where relevant. No scores, tiers, or BRS/V-domain values are assigned.

Direct Defence Contracting & Procurement

AXA Group is an insurance and financial services conglomerate. It does not operate as a defence contractor, systems integrator, or equipment supplier in its own right, and no public evidence has been identified of any direct contract, tender award, framework agreement, or MOU between AXA Group (as a corporate entity) and the Israeli Ministry of Defence (IMOD), the Israel Defense Forces, the Israel Prison Service, or Israel Border Police.

The material finding in this domain is indirect, arising through AXA Venture Partners (AVP), AXA’s venture capital arm, which led a $5 million Series A funding round for Hub Security (subsequently rebranded HUB Cyber Security Ltd., NASDAQ: HUBC) in May 2020.¹² The co-investors in that round included OurCrowd.²

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 a direct lineage from Israeli military intelligence infrastructure.¹²

The defence procurement nexus crystallised in September 2022, when Hub Security announced it had been awarded a tender by the Israeli Ministry of Defence valued at NIS 4.2 million (approximately $1.2 million USD at then-prevailing rates), covering Hub’s hardware and software products and services over a three-year period running from 2022 through 2025.³ This contract was therefore 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.”⁴

A critical confirmatory data point is furnished by SEC filings dated 30 September 2023, which list AVP Early Stage II S.L.P. (managed by AXA Venture Partners) as a beneficial owner of 8,785,035 shares of HUB Cyber Security, representing 8.94% of outstanding shares at that date.⁵ 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. AXA Venture Partners’ public portfolio page corroborates the active portfolio relationship.⁶

AVP stake status post-October 2023:

HUB Cyber Security (NASDAQ: HUBC) experienced severe share price deterioration following its SPAC merger completion in early 2023, trading significantly below its merger price throughout 2023 and into 2024, reaching lows below $1.00 per share and triggering NASDAQ minimum bid price compliance notices.⁷⁸ Despite this trajectory, 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.⁶ The AVP stake should accordingly be treated as likely still extant or in wind-down as of early 2025, absent a primary filing confirming divestment. The EDGAR filing history for Hub Security (CIK 1905660), including Form 6-K beneficial ownership schedules and Form 20-F annual reports, provides the primary vehicle for resolving this gap and should be reviewed directly.⁹⁷

Temporal overlap — IMOD contract and AVP holding:

The NIS 4.2 million IMOD contract (September 2022, three-year term to approximately 2025)³ was:

• Awarded approximately 18 months after AVP’s Series A (May 2020).¹
• Active at the time of the confirmed 8.94% AVP beneficial ownership (30 September 2023).⁵
• Active at the outbreak of the October 2023 conflict and during Hub Security’s public wartime cyber-defence statement.⁴
• Continuing into 2024 under its original three-year term.

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

Constructive notice:

Hub Security’s October 2023 public statement confirming its wartime “digital defenses” engagement⁴ constitutes constructive notice to all equity holders — including AVP/AXA as the 8.94% shareholder of record — of the company’s active role in the conflict-period security posture. Continuation of any equity holding post-October 2023 therefore occurred with constructive notice of Hub Security’s conflict-period activities. This analysis is further sharpened by the ICJ Advisory Opinion of 19 July 2024, which raised the constructive notice threshold for business enterprises whose activities materially support the occupation economy.¹⁰

A subsequent procurement event is documented in late 2024 / early 2025, when Hub Security announced a further contract award — 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.”¹¹¹² The precise execution date of this contract, and whether it post-dates or pre-dates any potential AVP divestment or reduction of its Hub Security stake, has not been confirmed from a primary source and constitutes a material evidence gap. If AVP’s stake remained extant at that date — which cannot be confirmed but has not been ruled out — this represents a post-ICJ Advisory Opinion continuation of financial exposure to an Israeli government contractor with an active IMOD contract history.

No public evidence has been identified of AXA Group appearing in SIBAT (Israel’s Defence Export & Defence Cooperation Directorate) listings, Israeli defence exhibition catalogues (e.g., ISDEF, Eurosatory Israeli exhibitor registries), or defence procurement registries in any jurisdiction.

Dual-Use Products & Tactical Variants

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. The dual-use analysis in this domain therefore concerns exclusively AXA’s investee companies and the technology characteristics of those investments.

Hub Security — dual-use cybersecurity technology:

Hub Security’s core product lines — Hardware Security Modules (HSMs), Confidential Computing platforms, and encrypted data processing infrastructure — are explicitly marketed using the descriptor “military-grade” security.¹² These are inherently dual-use technologies: they have documented civilian enterprise applications (financial sector data protection, cloud security) and, simultaneously, are supplied under the confirmed IMOD contract.³ The civilian and military end-use cases share identical technical platforms; no separate “tactical variant” manufacturing process has been identified, and the prior suggestion that Hub produces distinct military-specific product lines is not supported by available evidence. The products are commercial-off-the-shelf (COTS) security infrastructure with confirmed military end-users.

The company’s IDF Unit 8200 and Unit 81 heritage is relevant to dual-use classification: Unit 8200 is Israel’s primary signals intelligence and offensive cyber unit, analogous to the US NSA or UK GCHQ, and alumni-founded companies routinely develop technologies applicable across both commercial and state-security markets.¹²

PAX “Companies Arming Israel and Their Financiers” (June 2024) — dual-use financier scope:

The PAX for Peace report “Companies Arming Israel and Their Financiers” (June 2024 edition) examines both companies supplying weapons and military technology to Israel and their financial backers.¹³¹⁴ Given AXA IM’s confirmed holdings in companies named in the PAX primary supplier category (RTX, Boeing, Lockheed Martin, BAE Systems), AXA is structurally within the PAX financier analytical scope. Whether PAX names AXA by name in its published financier list or tables is [PARTIALLY VERIFIED] — this gap requires direct primary document review.¹³

AFSC Investigate database:

The AFSC Investigate database profiles companies with ties to Israeli military operations.¹⁵ Whether AXA has a dedicated AFSC Investigate profile was not confirmed in training knowledge, constituting a residual evidence gap requiring direct database query.

Neura — behavioural AI / IoT (historical investee):

AXA Strategic Ventures led an $11 million Series A investment in Neura, an Israeli AI and IoT startup whose technology generates behavioural identity profiles by analysing smartphone and IoT sensor data to predict individual user behaviour patterns.¹⁶¹⁷ This investment was made approximately 2015–2016. Neura was subsequently acquired by Twilio in 2019, at which point it ceased to operate as an independent Israeli entity and the AXA investment relationship concluded. This is therefore a historical, closed exposure and does not represent an active dual-use risk. Claims in prior analysis characterising Neura as an ongoing active exposure or as having been adopted by Israeli security services for targeting purposes were not supported by verifiable evidence and are excluded from this audit’s findings.

Export control applicability:

Hub Security’s HSM and confidential computing products are subject to Israeli domestic export control regulations under the Defence Export Control Law (5766-2007, administered by SIBAT/DECA). No public evidence has been identified of third-country export licence applications, end-user certificate proceedings, or government export control reviews arising from AXA’s investment relationship with Hub Security or from any other AXA-linked investee’s supply to Israeli defence end-users. This gap should be addressed through targeted review of Israeli DECA public records and relevant third-country licensing authority records.

Heavy Machinery, Construction & Infrastructure

AXA Group does not manufacture, supply, or operate heavy machinery, construction equipment, or engineering vehicles. No public evidence has been identified of AXA Group holding direct contracts for construction, maintenance, servicing, or expansion of checkpoints, detention facilities, military bases, the separation barrier, or settlement-related physical infrastructure.

The material finding in this domain arises from AXA’s asset management arm’s investment in CAF (Construcciones y Auxiliar de Ferrocarriles), the Spanish rail and transport manufacturer.

CAF leads the TransJerusalem J-Net consortium (alongside Shapir Engineering)¹⁸ contracted to expand the Jerusalem Light Rail (JLR) Red Line and construct the Green Line.¹⁹²⁰ This infrastructure serves to link 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.²¹²²

AXA’s position as an investor in CAF has been documented by the “Don’t Buy into Occupation” (DBIO) coalition, a research and advocacy consortium led by FIDH and CNCD-11.11.11.²¹²² The most recently published iteration, DBIO V (November 2025), continues to include this finding.²¹ The FIDH report from November 2022 provides earlier documentation of the same holding.²² Who Profits specifically profiles the Jerusalem Light Rail, documenting the settlement-connectivity function of the infrastructure.²³

Current project status (2024–2025):

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; Israeli municipal rail infrastructure projects of this scale proceed on multi-year timelines independent of military conflict. The project therefore continued through the post-ICJ Advisory Opinion period (post-19 July 2024) and the post-ICC arrest warrants period (post-November 2024).¹⁹²⁰ The DBIO V report (November 2025)²¹ — the most recent iteration — confirms continuation of this documentation into the most recent reporting period, post-dating both the ICJ Advisory Opinion and ICC arrest warrants. AXA IM’s holdings in CAF, if retained, therefore represent ongoing financial exposure to a company engaged in settlement-connectivity infrastructure construction in the post-Advisory Opinion period.

Settlement nexus specificity:

The Green Line’s planned route connects East Jerusalem settlement neighbourhoods with central Jerusalem. The Red Line expansion, also within the CAF consortium scope, serves similar connectivity functions for Pisgat Ze’ev and Neve Yaakov. Both routes traverse or terminate in areas designated as occupied territory under international law, including findings by the UN Special Rapporteur.²⁴ The DBIO reports specifically characterise this infrastructure as facilitating the consolidation of the occupation.²¹²²

OHCHR settlement database relevance:

The UN OHCHR database of business enterprises involved in settlement activities (maintained under HRC res. 31/36 / 53/25)²⁵ primarily names companies with direct operational activity in settlements. AXA, as a financial investor, would not typically be listed in the operational-company database. However, CAF — as a direct infrastructure contractor to the JLR — may appear in OHCHR settlement database or successor databases. Whether CAF appears in the OHCHR database is a verification gap requiring direct database review.²⁵

The UN Special Rapporteur’s 2025 report on the “economy of occupation and genocide” (A/HRC/59/23, Francesca Albanese) addresses the role of infrastructure investment in sustaining the occupation economy, and the Law for Palestine database derived from this report encompasses entities in the infrastructure category relevant to this audit.²⁶²⁴

Evidential qualification: The precise quantum of AXA’s equity or debt exposure to CAF has not been verified from a primary AXA regulatory filing (e.g., AXA Investment Managers UCITS fund disclosures or AMF regulatory submissions). The DBIO/FIDH references confirm AXA’s investor status and CAF’s role in the JLR, but the specific holding size and the currency of AXA’s position as of the audit date requires confirmation from AXA IM’s primary fund disclosures. AXA’s relationship to the JLR project is that of an equity investor in CAF, not a direct engineering or construction contractor.

Supply Chain Integration with Defence Primes

AXA Investment Managers — holdings in global defence and aerospace primes:

Research conducted by the BDS Movement’s “Stop AXA Assistance to Israeli Apartheid” coalition and the NGO Ekō, based on portfolio data as of 30 June 2024, reported AXA holding approximately $150.43 million across eleven companies identified as supplying weapons systems to Israel, comprising approximately $78.87 million in equity and $71.56 million in corporate bonds.²⁷²⁸²⁹ The companies named in this research include Boeing, Lockheed Martin, General Dynamics, RTX (Raytheon Technologies), BAE Systems, L3Harris, Rolls-Royce, and Northrop Grumman, among others.²⁸

Evidential qualification: This figure originates from advocacy coalition research, not from AXA’s own regulatory filings or from a regulated primary financial data provider. AXA Investment Managers managed approximately €850+ billion in assets globally as of 2023–2024,³⁰ a scale at which holdings in major US and UK defence primes through diversified equity indices and investment-grade bond mandates are routine and structurally expected. The $150.43 million figure is treated as partially verified — the category of holdings (positions in these named firms) is consistent with the known composition of large diversified asset managers, but the precise quantum has not been independently confirmed from AXA IM’s primary disclosures. Primary verification would require cross-reference against AXA IM’s published fund holdings, Form 13F filings (for US-domiciled assets), UCITS transparency reports, and the AXA Universal Registration Document 2024.³¹

PAX “Companies Arming Israel and Their Financiers” (June 2024) — financier analysis:

The PAX for Peace report¹³¹⁴ is the most directly relevant Tier-1 source for this sub-section, specifically analysing financial relationships between investors and companies arming Israel. PAX’s methodology cross-references SIPRI arms transfer data, company filings, and institutional holding databases. Given AXA IM’s confirmed holdings in companies named in the PAX “direct supplier” category — including RTX (Iron Dome Tamir interceptor co-production with Rafael Advanced Defense Systems³²), Boeing (F-15 components, JDAM precision guidance kits), and Lockheed Martin (F-35 programme, Israel operates the F-35I “Adir”³³) — AXA is structurally within the PAX financier analytical scope. Whether PAX names AXA by name in its published financier list or tables is [PARTIALLY VERIFIED]: structurally expected given AXA IM’s confirmed holdings in these entities, but not confirmed without access to the primary document. This gap requires direct document review.¹³

AXA IM Controversial Weapons Exclusion Policy:

AXA IM maintains a formal Controversial Weapons Exclusion Policy³⁴ governing investments in companies involved in anti-personnel mines, cluster munitions, biological and chemical weapons, and nuclear weapons outside NPT. Key points:

• The policy does not extend to conventional weapons manufacturers, including the US/UK defence primes (Boeing, RTX, Lockheed Martin, BAE Systems, L3Harris, Northrop Grumman, General Dynamics) whose products are supplied to Israeli forces. These firms do not trigger AXA IM’s published exclusion criteria even when their products are used in active conflict.
• The Ekō/Profundo research (June 2024) confirmed this policy gap — finding AXA IM continued to hold the named defence prime positions following October 2023 without triggering any formal exclusion mechanism.³⁵
• No evidence has been identified of AXA IM adopting a conflict-specific exclusion, temporary hold, or enhanced due diligence posture in relation to its defence prime holdings following October 2023 or following the ICJ Advisory Opinion of 19 July 2024.

AXA IM Stewardship and Engagement:

AXA IM’s Stewardship and Engagement Report 2023³⁶ covers AXA IM’s voting and engagement activities with portfolio companies. Whether AXA IM engaged with Boeing, RTX, Lockheed Martin, BAE Systems, or other defence prime holdings on the subject of their Israeli military supply during 2023–2024, and whether any such engagement is disclosed in AXA IM’s stewardship reporting, is a verification gap.³⁶

Reclaim Finance documentation:

Reclaim Finance maintains a tracker of AXA’s published ESG and investment policies.³⁷ Their documentation confirms AXA IM’s exclusion framework architecture but does not identify any defence-sector exclusions beyond controversial weapons,³⁷ corroborating the Ekō/Profundo assessment that no formal policy update addressing defence prime holdings in the Gaza conflict context has been adopted.³⁵

Elbit Systems — confirmed divestment:

Multiple independent sources, including the Ekō/Profundo research report of June 2024 and the Ireland Palestine Solidarity Campaign, confirm that AXA divested its holdings in Elbit Systems by approximately 2018–2019,²⁷³⁸³⁹ prior to the current conflict. This divestment is described in campaign documentation as having been secured following sustained pressure from the “Stop AXA” campaign.²⁷³⁸ The August 2024 Middle East Monitor report confirms the completion of both the Israeli bank and Elbit divestments.³⁹

AXA’s own Responsible Investment Policy documentation addresses exclusions for controversial weapons categories, primarily cluster munitions and anti-personnel mines.⁴⁰ Whether any Israeli defence entities beyond Elbit Systems appear on AXA’s formal exclusion list, and whether that list was updated following October 2023, requires verification against AXA’s most current responsible investment policy publications.⁴⁰³⁴

Joint development and co-production:

No public evidence has been identified of joint development programmes, co-production agreements, technology transfer arrangements, or licensed manufacturing agreements between AXA Group and any Israeli defence firm (including Elbit Systems, Israel Aerospace Industries, Rafael Advanced Defense Systems, or IMI Systems/Elbit Land).

AXA’s connection to strategic platforms (e.g., Iron Dome’s Tamir interceptor co-produced by RTX and Rafael; F-35 components supplied by multiple primes; Merkava components supplied by US firms) is exclusively an indirect investment relationship arising from AXA IM’s holdings in firms such as RTX and Lockheed Martin.²⁸ AXA itself does not supply sub-systems, components, or materials to these platforms.

Group attribution:

The following AXA Group operating entities are operationally integrated at group level under consolidated reporting, AXA IM’s responsible investment policies, and AXA’s group-level ESG governance:³⁰⁴⁰

• AXA Investment Managers (AXA IM) — Confirmed holdings in Boeing, RTX, Lockheed Martin, BAE Systems, L3Harris, Rolls-Royce, Northrop Grumman, General Dynamics per BDS/Ekō research.²⁸ Confirmed prior divestment from Elbit Systems and Israeli banks.^41353839 Confirmed holdings in CAF (JLR).²¹²²
• AXA Venture Partners (AVP) — Confirmed lead investor in Hub Security (May 2020); confirmed 8.94% beneficial ownership (30 September 2023).¹²⁵ Hub Security held active IMOD contract (2022–2025).³
• AXA XL — Confirmed Global Partner Network relationship with Harel Insurance in Israel.⁴²⁴³⁴⁴ No verified evidence of defence or settlement-specific underwriting.
• AXA Strategic Ventures — Invested in Neura (2015–2016, closed on Twilio acquisition 2019). Historical closed exposure.¹⁶¹⁷

Logistical Sustainment & Base Services

AXA does not operate as a catering, facilities management, fuel supply, transport, telecommunications, or logistics services provider. No public evidence has been identified of AXA Group holding contracts to provide support services of any kind to IDF bases, military training facilities, detention centres, or security installations.

AXA XL / Harel Insurance — Global Partner Network relationship:

AXA XL, AXA Group’s commercial property & casualty and specialty insurance arm, operates a multinational Global Partner Network through which locally licensed insurers act as fronting and network partners for cross-border programme clients.⁴⁴ Harel Insurance Investments & Financial Services Ltd. — Israel’s second-largest general insurer⁴² — is identified in published materials as functioning in the capacity of AXA’s network partner / fronting insurer in Israel.⁴²⁴³

In this structure, the local network partner (Harel) underwrites and issues local policies, with AXA XL acting as the programme co-ordinator and reinsurer or excess-of-loss capacity provider. The AXA XL acquisition was completed in September 2018,⁴⁵ meaning the XL/Harel relationship, if established around 2019–2020, has been operational throughout the conflict period. There is no publicly available documentation of whether AXA XL’s programme with Harel extends to, or explicitly excludes, risks arising from activity in occupied territories or from defence-related clients in Israel. The terms of the AXA XL–Harel Global Partner agreement, including any territorial exclusions or policy-scope limitations relating to occupied territories or defence risks, are not available in the public record and constitute an evidence gap.⁴²⁴³⁴⁴

AXA Israel operating entity:

AXA operates in Israel through AXA Israel, a locally licensed insurance entity or branch structure, distinct from the AXA XL/Harel Global Partner arrangement. AXA Israel provides standard retail and commercial insurance lines in the Israeli market. No public evidence has been identified of AXA Israel underwriting specific defence, military installation, or settlement-related risks, though the breadth of commercial P&C underwriting in a market of this size structurally encompasses a wide range of clients. AXA Israel’s specific client roster and underwriting scope are not in the public record.

Catastrophe bond / ILS market:

The prior analysis referenced AXA XL’s ILS Capital Management unit as a potential participant in the Turris Re catastrophe bond programme, which covers Israeli earthquake risk and is sponsored by Migdal Insurance. General Artemis.bm records document ILS market activity in Israel,⁴⁶⁴⁷ but specific confirmation of AXA XL’s participation as an investor in Turris Re tranches was not identified in available sources. This claim is unverified and is excluded from substantive findings.

Munitions, Weapons Systems & Strategic Platforms

AXA Group is not a weapons manufacturer, prime contractor, ordnance producer, or licensed manufacturer of any lethal platform or sub-system. This domain section is structurally inapplicable to AXA’s direct corporate activities.

• Munitions and precursor materials: No public evidence identified of AXA supplying ammunition, explosive ordnance, chemical propellants, warhead components, or munitions precursors to any end-user in any jurisdiction.

• Strategic and existential defence systems: AXA does not design, manufacture, or integrate components for Iron Dome, David’s Sling, Arrow missile defence, combat aircraft, main battle tanks, warships, or ballistic missile systems.

• Sub-system and critical component supply: No public evidence identified. AXA’s sole connection to strategic defence platforms is as a passive financial investor in global asset management funds and mandates that hold positions in companies — including RTX (Raytheon Technologies) and Lockheed Martin — which themselves supply or co-produce components for Israeli strategic platforms (e.g., RTX’s co-production of Iron Dome’s Tamir interceptor with Rafael Advanced Defense Systems³²; Lockheed Martin’s F-35 programme, with Israel operating the F-35I “Adir”³³).²⁸ This is an indirect, multi-remove investment relationship. AXA does not itself supply, co-produce, or sub-contract any element of these platforms.

• Hub Security — non-kinetic military capability: Hub Security’s confirmed IMOD-contracted products are cybersecurity infrastructure (HSMs, confidential computing), not munitions or weapons systems in any conventional sense.³ They are non-kinetic in character, though they support military digital operations.

No new evidence identified contradicting or extending the prior section. The structural conclusion — that AXA’s only connection to weapons systems is as a passive financial investor in global asset management funds holding positions in defence primes — remains unchanged.

Export Licensing, Regulatory & Legal History

Export licensing proceedings:

No public evidence has been identified of any government decision — in France, the United Kingdom, the European Union, the United States, or any other jurisdiction — to grant, deny, suspend, or revoke export licences specifically in connection with AXA Group’s investment activities, AXA XL’s insurance underwriting, or the products of AXA’s investee companies supplied to Israeli military or security end-users.

Hub Security’s HSM and confidential computing products, supplied under the confirmed IMOD contract,³ are subject to Israeli domestic export control regulation administered by SIBAT/DECA (Defence Export Control Agency). No evidence of third-country export licence applications or denials arising from this supply relationship, and no evidence of any end-user certificate controversy, was found in available sources.

Arms embargo and sanctions compliance:

No investigations, citations, enforcement actions, or compliance notices related to AXA’s adherence to arms embargoes, export control regimes, or sanctions affecting defence trade with Israel were identified in available public record. AXA’s activities in Israel fall within financial services and insurance, which are generally outside the scope of arms embargo instruments, though EU and national sanctions regimes affecting financial flows are applicable. France has not imposed a national arms embargo on Israel. French export licence decisions regarding defence exports to Israel are processed through the CIEEMG (Commission Interministérielle pour l’Étude des Exportations de Matériels de Guerre). AXA, as a financial services group, is not subject to CIEEMG review for its investment activities.

Regulatory compliance — French AMF / ACPR:

AXA is dually regulated in France by the ACPR (Autorité de contrôle prudentiel et de résolution) and the AMF (Autorité des marchés financiers). The AMF published guidance in 2023–2024 on the obligations of French collective investment vehicles in relation to ESG claims and responsible investment disclosures; AXA IM’s ESG reporting is subject to this framework.⁴⁸ No AMF enforcement action or formal query specifically related to AXA IM’s defence prime holdings or Israeli-linked investments was identified in training knowledge. The ACPR has not, based on available evidence, issued specific supervisory notices or actions related to AXA’s war-economy or occupation-linked investment exposures. AXA’s Universal Registration Document (DEU) filed annually with the AMF provides the primary vehicle for ESG and responsible investment disclosures.³⁰³¹ The AMF/ACPR supervisory action gap is assessed as a confirmed negative finding.

Shareholder resolution activity (AXA AGM 2024):

At the April 2024 AXA Annual General Meeting, the “Stop AXA” campaign and associated investor coalitions organised pressure around CEO Buberl’s statements on Israeli bank and Elbit divestment.⁴¹³⁸⁴⁹ No formal shareholder resolution on a specific divestment mandate requiring divestment from named defence primes was confirmed as having been filed and voted at the 2024 AGM. The documented outcome was Buberl’s verbal confirmation of the Israeli bank / Elbit divestments, not a binding resolution.⁴¹ Reclaim Finance’s documentation of AXA AGM activity is limited primarily to climate-related resolutions.³⁷

Legal challenges and judicial review:

No court proceedings, judicial reviews, or legal challenges brought against AXA, or brought against any government in connection with AXA’s defence supply or investment activities relating to Israel, were identified in available sources.

Constructive notice: post-19 July 2024 and post-November 2024:

The ICJ Advisory Opinion of 19 July 2024 on the Legal Consequences of Israel’s Occupation of the Palestinian Territory found the occupation unlawful under international law and imposed obligations on third states and, by implication, on business enterprises operating in or financing the occupation. International legal scholars and UN bodies have noted that the Advisory Opinion raises the constructive notice threshold for corporate actors whose activities materially support the occupation economy.¹⁰ The ICC arrest warrants of November 2024 for Israeli Prime Minister Netanyahu and former Defence Minister Gallant represent a further escalation of the international legal framing. AXA’s holdings in Hub Security (via AVP), in CAF (via AXA IM), and in US/UK defence primes (via AXA IM) continued through this period absent any confirmed divestment announcement.

AXA’s ESG exclusion framework:

AXA’s publicly disclosed Responsible Investment Policy incorporates exclusions for controversial weapons, with documented coverage of cluster munitions, anti-personnel mines, biological and chemical weapons, and nuclear weapons outside the NPT framework.⁴⁰³⁴ No public documentation confirms that Israeli defence entities beyond Elbit Systems are included on AXA’s exclusion list, nor that any formal policy update addressing the post-October 2023 conflict environment has been adopted. The Ekō/Profundo research assessed that AXA’s divestment from Israeli banks and Elbit represents a de facto portfolio decision rather than a codified ESG exclusion policy update.³⁵

Corporate governance principals — controlling principal analysis:

• Thomas Buberl (Group CEO, AXA)⁵⁰: No public evidence has been identified of Buberl holding defence-industry directorships, Israeli defence-related board roles, FIDF/reservist-fund donations, personal equity in Israeli defence primes, or public co-belligerency statements. His April 2024 AGM statement on Israeli bank divestment⁴¹³⁸ is the only documented public statement by Buberl on conflict-related investment issues.
• Denis Duverne (Non-Executive Chairman, AXA)⁵¹: No public evidence has been identified of Duverne holding defence-industry directorships, Israeli defence-related roles, or personal equity in Israeli defence primes or military entities.
• AXA Board of Directors⁵²: AXA’s board as disclosed in its Universal Registration Document comprises independent directors drawn primarily from European finance, industry, and public policy backgrounds. No board member has been publicly identified as holding a position at an Israeli defence firm, on a defence-related advisory board, or as making public statements in support of Israeli military operations.
• Mutuelles AXA (largest shareholder bloc, ~14–16% of share capital)⁵³: A federation of French mutual insurance entities with no identified Israeli defence sector connections.
• BlackRock Inc. (intermittent ~5% passive holding)⁴⁸: BlackRock is a passive index investor in AXA shares. BlackRock’s own separate portfolio holdings are entirely distinct from AXA’s corporate activities and do not constitute a principal-attribution finding for AXA.

No military-channel acts by AXA’s identified controlling principals (CEO, Chair, board members, or majority shareholders) have been identified in available public record. This is a negative finding, not an omission.

Civil Society Scrutiny & Documented Investigations

Organised campaigns:

The “Stop AXA” campaign — coordinated by a coalition including the BDS Movement, Ekō, the Ireland Palestine Solidarity Campaign (IPSC), and associated national affiliates — has operated as an organised, multi-year campaign specifically targeting AXA since approximately 2016–2017, initially focusing on AXA’s holdings in Israeli banks, subsequently broadening to Elbit Systems, and latterly to US and UK defence prime holdings.²⁷

The BDS Movement maintains dedicated campaign infrastructure for AXA, including a campaign hub page²⁷ and a specific research report published in 2024 alleging AXA’s complicity in financing weapons manufacturers supplying the Gaza conflict.²⁸²⁹ An open letter to AXA CEO Thomas Buberl was published by the BDS coalition in October 2023, immediately following the outbreak of hostilities, demanding divestment from Israeli banks and defence-linked holdings.⁵⁴ This constitutes formal, documented civil society notice to AXA’s CEO — the highest individual executive — of the coalition’s specific demands and the alleged basis for corporate complicity. After October 2023, AXA’s leadership cannot be said to have been unaware of the civil society characterisation of its investment portfolio.

The Madison-Rafah Sister City Project has similarly publicised campaign achievements in relation to AXA divestments.⁵⁵ AXA appears on Ethical Consumer’s published boycotts list in connection with this campaign.⁵⁶

NGO and academic reports:

• Ekō / Profundo (June 2024): An independently commissioned research report confirmed AXA’s divestment from all five major Israeli banks (Bank Hapoalim, Bank Leumi, Mizrahi Tefahot, Israel Discount Bank, First International Bank of Israel) and from Elbit Systems, while documenting continued holdings in US and UK defence primes and providing specific holding values.⁴¹³⁵ Refinitiv data examined in that report found only a trace residual (~$130,000) in Bank Leumi, attributed to reporting lag rather than active holding.³⁵

• FIDH / CNCD “Don’t Buy into Occupation” (DBIO) series: The DBIO report series, co-published by FIDH and CNCD-11.11.11 across multiple iterations from 2019 through 2025, has named AXA in the context of investment in companies operating in or financing the occupation, including CAF (Jerusalem Light Rail) and Israeli financial institutions.²¹²²⁵⁷ The most recent published edition, DBIO V (November 2025), continues this documentation post-dating both the ICJ Advisory Opinion and ICC arrest warrants.²¹

• PAX for Peace — “Companies Arming Israel and Their Financiers” (June 2024):¹³¹⁴ This report analyses both direct corporate suppliers of weapons to Israel and their financial backers. As noted across Sections 2 and 4, AXA is structurally within PAX’s financier analytical scope given AXA IM’s confirmed holdings in companies named in the PAX primary supplier category. Whether PAX names AXA by name in its published financier list is [PARTIALLY VERIFIED] — this gap requires direct primary document review.

• UN Special Rapporteur, A/HRC/59/23 (2025): The report by Special Rapporteur Francesca Albanese on the “economy of occupation and genocide” addresses the role of financial institutions and investors in sustaining the occupation economy, including financial flows to companies supplying weapons, surveillance technology, and military infrastructure.²⁴ The Law for Palestine database derived from this report includes companies in sectors where AXA holds investments.²⁶²⁴ Whether AXA is itself named directly in the body of the Special Rapporteur’s report requires verification against the primary text.

• AFSC Investigate (database):¹⁵ Profiles companies with ties to Israeli military operations. Whether AXA has a dedicated AFSC Investigate profile was not confirmed in training knowledge, constituting a residual evidence gap.

• APAN / Australian advocacy (2023): AXA was referenced in the Australian Palestinian Advocacy Network’s submission to the Australian government’s feasibility study on trade and investment with Israel, conducted by DFAT.⁵⁸

• Who Profits:²³ No specific Who Profits company profile for AXA Group was identified in available sources. Who Profits primarily profiles companies with direct operational presence in occupied territories; AXA, as a financial investor, does not appear to have generated a dedicated Who Profits entry. Who Profits does specifically profile the Jerusalem Light Rail, relevant to AXA’s indirect CAF investor relationship.²³

• Business & Human Rights Resource Centre: BHRRC has published documentation on Israeli banks financing illegal settlements, relevant to AXA’s now-divested banking holdings.⁵⁹

• Reclaim Finance:³⁷ Maintains a tracker of AXA’s published ESG and investment policies. Documentation confirms AXA IM’s lack of a formal exclusion policy for conventional weapons manufacturers, corroborating the finding that no post-October 2023 policy update has been publicly adopted for defence prime holdings.³⁷³⁴

• European Council on Foreign Relations (ECFR) Differentiation Tracker:⁶⁰ Tracks EU member state and institutional differentiation policies regarding settlement-linked entities; provides regulatory context for AXA’s operating environment in European markets.

• OHCHR database of business enterprises involved in settlement activities (HRC res. 31/36 / 53/25):²⁵ Primarily names companies with direct operational activity in settlements. AXA, as a financial investor, would not typically be listed directly; whether CAF appears is a verification gap addressed in Section 3.

AXA’s documented responses:

At AXA’s April 2024 Annual General Meeting, Group CEO Thomas Buberl publicly stated the group held “zero investments in Israeli banks, direct or indirect.”⁴¹³⁸ This statement was subsequently corroborated by the Ekō/Profundo independent research.⁴¹³⁵

The confirmation of the full Israeli bank and Elbit divestment was reported across multiple advocacy and media outlets in August 2024.³⁹⁵⁵ The IPSC characterised this as a “huge victory” for the Palestine solidarity movement.³⁸

AXA has not adopted a formal written policy prohibiting investment in Israeli banks, settlement-linked entities, or Israeli defence-related companies as a category, according to campaign assessments of its responsible investment framework.³⁵ The divestment from Israeli banks and Elbit appears to be a de facto portfolio decision. No public policy statement or corporate commitment specifically addressing AXA’s continued holdings in US and UK defence primes in the context of the Gaza conflict has been identified as of the audit date.⁴⁰

The “Stop AXA” campaign’s publicly stated remaining demands concern AXA’s holdings in US and UK arms manufacturers supplying Israel, and the absence of a codified exclusion policy for Israeli defence and settlement-linked entities.²⁷²⁸

End Notes