V-ECON Audit — Bentley

Entities in Scope: Bentley Systems, Incorporated (Nasdaq: BSY) · Bentley Motors Limited (subsidiary of Volkswagen Group AG) Audit Phase: V-ECON Date: 2026-05-01

Scope Note: This audit covers two legally distinct entities operating under the “Bentley” name: Bentley Systems, Incorporated (enterprise infrastructure engineering software, headquartered in Exton, Pennsylvania, USA) and Bentley Motors Limited (ultra-luxury automotive manufacturer, headquartered in Crewe, England, wholly owned by Volkswagen AG). Where findings apply to one entity only, this is stated explicitly. Questions pertaining to agricultural sourcing (produce, Mehadrin, Hadiklaim, Agrexco, etc.) consistently return negative findings for both entities, as neither operates in food retail, food service, or agricultural commodities. Claims from a prior AI-generated research brief that could not be corroborated against primary sources are marked [UNVERIFIED] and are excluded from the operative findings; they are noted for completeness and to flag evidence gaps.

Supply Chain & Sourcing Relationships

Agricultural & Produce Sourcing

No public evidence identified that either Bentley Systems or Bentley Motors sources, procures, distributes, or is commercially affiliated with agricultural produce of any origin. No supply chain relationship with Mehadrin, Hadiklaim, Galilee Export, Agrexco, or any successor entity has been identified. Source classes reviewed include Bentley Systems’ SEC filings ¹, corporate website ², and IPO prospectus ³.

Technology Distribution — Israel (Bentley Systems)

Bentley Systems distributes its software portfolio in Israel through Team Software Ltd, a wholly owned subsidiary of Malam Team Ltd, a Tel Aviv Stock Exchange-listed IT integration firm. Team Software is listed as an active authorised channel partner in Bentley’s own partner directory ⁴. This relationship constitutes a third-party commercial channel partnership; Team Software is not a wholly owned or majority-owned subsidiary of Bentley Systems. No separately incorporated Israeli legal entity acting as Bentley Systems’ importer of record has been identified in SEC filings or public corporate disclosures ¹². The Who Profits database maintains a profile of Malam Team documenting the firm’s concurrent contracts with Israeli defence and security bodies ⁵. This creates an indirect commercial nexus: Bentley Systems → Team Software Ltd (channel partner) → Israeli end-user clients, including clients whose other contracts involve contested-territory operations.

Automotive Distribution — Israel (Bentley Motors)

Bentley Motors distributes vehicles in Israel exclusively through Orchid Sports Cars Israel Ltd, an independent third-party exclusive distributor registered in Herzliya Pituach ⁶⁷⁸. Orchid is a privately registered Israeli company ⁸. No ownership stake by Bentley Motors in Orchid has been identified in any public record. Bentley Motors’ official global dealer locator confirms the Tel Aviv location as the sole authorised Israeli retailer ⁶.

Seasonal Sourcing Patterns

No public evidence identified. Neither entity has disclosed or been reported as engaging in seasonal procurement from Israeli suppliers in any product category.

Indirect & Third-Party Sourcing Flows

• Bentley Systems: Software licensing revenue from Israeli end users flows through the Malam Team / Team Software channel. No white-label or physical-goods reseller arrangement has been identified.
• Bentley Motors: Vehicles reach the Israeli market exclusively through the Orchid Sports Cars distribution chain. No direct procurement contracts between Bentley Motors and Israeli entities for components, sub-assemblies, or raw materials have been identified in publicly available sources.
• VW Group (Bentley Motors’ parent): Volkswagen Group maintains an active technology-sourcing relationship with Mobileye Global Inc., headquartered in Jerusalem, Israel, for autonomous driving systems ⁹¹⁰. This relationship is addressed in detail under §3 (Investment, Capital & Financial Exposure).

Product Origin, Labeling & Regulatory Compliance

Settlement-Origin Products

No public evidence identified. Neither Bentley entity produces, imports, or labels physical consumer goods subject to country-of-origin labeling regulations in any jurisdiction reviewed. No NGO report from Who Profits ⁵¹¹, Corporate Occupation, or AFSC Investigate has cited either Bentley entity for settlement-origin product sourcing or labeling violations. Neither entity appears in the Who Profits settlements presence database ¹¹.

Labeling Compliance — Regulatory Record

Not applicable to either Bentley entity in the conventional produce-labeling or consumer-goods sense. No enforcement actions, regulatory citations, or consent decrees relating to country-of-origin labeling have been identified for either entity in any jurisdiction.

Corporate Labeling Policy

No public evidence identified of a stated corporate policy governing the sourcing or labeling of goods from occupied or contested territories for either entity. Bentley Systems’ SEC filings ¹ and Bentley Motors’ publicly accessible corporate responsibility disclosures (accessible via the VW Group 2023 Annual Report ¹²) do not contain territory-specific sourcing or labeling policies applicable to the Israeli/Palestinian context.

Jerusalem Light Rail Case Study (Bentley Systems)

Bentley Systems’ case study library references a Jerusalem Light Rail project ¹³, consistent with broader marketing of Bentley’s transportation engineering software to Middle Eastern infrastructure programs. The case study, if confirmed, would document Bentley Systems’ software use in a project that traverses territories whose legal status under international law is contested. This finding is a software-service association, not a product-origin or labeling compliance matter; it is noted here for cross-domain completeness. The specific content of the case study (engineering firms named, project scope) could not be independently confirmed without live web access (see Evidence Gaps).

Investment, Capital & Financial Exposure

Foreign Direct Investment

Bentley Systems: No public evidence identified of direct capital investment — acquisition, real estate holding, logistics hub, or manufacturing facility — by Bentley Systems within Israel or the occupied Palestinian territories. Bentley Systems’ 10-K filings report property and equipment on a consolidated basis, with geographic segment revenue reported only as Americas, EMEA, and APAC; Israel is not separately disclosed and is aggregated within the EMEA segment ¹. No Israeli subsidiary entity appears in the subsidiary list of BSY’s SEC filings based on available records.

Bentley Motors / VW Group — Konnect Innovation Hub: Volkswagen Group operates Konnect, a corporate innovation and venture-scouting hub physically located in Tel Aviv, established to identify Israeli technology startups for integration into VW Group’s product and R&D roadmap ¹⁴. Konnect’s stated mandate spans autonomous driving, cybersecurity, and artificial intelligence. This constitutes operational foreign direct investment by the VW Group — Bentley Motors’ ultimate parent — on Israeli soil, though Bentley Motors is not named as the operating entity for Konnect and no evidence specifically identifies Bentley Motors (as distinct from other VW brands) as an active beneficiary of Konnect sourcing.

R&D and Innovation Relationships

Bentley Systems: No public evidence identified of an R&D facility, technology lab, or active innovation partnership operated or funded by Bentley Systems within Israel.

Bentley Motors / VW Group — Mobileye Partnership: Volkswagen Group holds a longstanding and expanding commercial technology partnership with Mobileye Global Inc. (Nasdaq: MBLY), headquartered at 13 Hartom Street, Jerusalem, Israel, as confirmed in Mobileye’s SEC Form 20-F ¹⁵. VW Group’s partnership with Mobileye dates to at least 2020 ¹⁰, with a formal expansion announced in 2022 ⁹. Mobileye’s SuperVision autonomous driving platform ¹⁶ is integrated across VW Group vehicle architectures, and VW Group’s broader ADAS strategy is partly built around Mobileye’s sensor fusion and EyeQ chip stack ¹². A prior AI-generated research brief claimed that Bentley Motors specifically confirmed Mobileye SuperVision integration for its upcoming EV product line; this claim is partially corroborated — the VW Group platform-level adoption is confirmed, but Bentley Motors-specific product confirmation is not independently verifiable from named primary sources at the level of granularity claimed. The structural exposure remains: licensing fees and technology payments flow from VW Group (and by extension all VW brands, including Bentley Motors) to a Jerusalem-headquartered entity.

Beneficial Ownership and Capital Flows

Bentley Systems: As of the 2023 10-K, the founding Bentley family (Gregory Bentley and related family trusts) retains effective voting control through a dual-class share structure in which Class B shares carry ten votes per share ¹³. No Bentley family member or major BSY institutional shareholder is publicly documented as holding separately identified Israeli subsidiary investments or Israeli sovereign bonds beyond general institutional portfolio exposure. Profits flow from global operations — including the EMEA segment, which encompasses Israel — to Bentley Systems’ US-domiciled parent entity, benefiting US-based shareholders and the founding family ¹³.

Bentley Motors: Wholly owned by Volkswagen AG (100% since acquisition). VW AG’s majority voting control is held by Porsche Automobil Holding SE (controlled by the Porsche and Piëch families) and approximately 12% by the Qatar Investment Authority (QIA) as of post-2022 restructuring ¹². Profits flow upward to Volkswagen AG (Wolfsburg, Germany) and ultimately to these primary beneficial shareholders ¹². No evidence of profit repatriation from Bentley Motors or VW Group to Israeli-domiciled entities has been identified.

Portfolio and Fund Exposure

No public evidence identified of disclosed holdings in Israeli-domiciled companies, Israeli sovereign bonds, or Israel-focused investment funds held directly by either Bentley Systems or Bentley Motors as operating entities.

Revenue Scale

Bentley Systems reported total 2023 revenue of approximately $1.23 billion ¹⁷. No Israel-specific revenue figure is disclosed; Israel is aggregated within the EMEA segment ¹. Bentley Motors’ revenue is consolidated within VW Group financials under the “Premium” brand group, and no Israel-specific revenue figure is publicly disclosed ¹².

Operational Presence & Market Activity

Physical Footprint

Bentley Systems — Israel: Bentley Systems maintains a channel partner presence in Israel through Team Software Ltd / Malam Team ⁴⁵ but no Bentley Systems-owned office, support centre, data centre, or warehouse in Israel has been confirmed in SEC filings or corporate disclosures ¹². A broader Middle East regional commercial presence is referenced in Bentley’s editorial “Code, Concrete, and the Middle East’s New Infrastructure Moment” ¹⁸, but no Israel-specific owned-or-leased address is identified in official filings. The absence of a disclosed Israeli legal entity in BSY’s 10-K subsidiary schedule is consistent with operations being conducted entirely through the Malam Team channel partnership.

Bentley Motors — Israel: An authorised dealership and showroom is operated by Orchid Sports Cars Israel Ltd in Herzliya Pituach, marketed publicly as “Bentley Tel Aviv” ⁶⁷¹⁹. This is a third-party dealership, not a company-owned retail location. Its presence on Bentley Motors’ global dealer locator ⁶ constitutes official brand recognition of the Israeli point of sale. Autocar Professional reported the showroom opening and cited Bentley’s stated intention to actively pursue the Israeli market among its affluent technology-sector consumers ⁷.

VW Group / Konnect — Israel: As noted above, the Konnect innovation hub operates physically from Tel Aviv as a VW Group entity ¹⁴, representing the most substantial direct operational footprint at the group level.

Software Use in Israeli Infrastructure Programs

• Jerusalem Light Rail: Bentley Systems’ case study library references the Jerusalem Light Rail project ¹³, documenting the use of Bentley infrastructure software on a transit system whose routing has been noted in international legal and NGO contexts as traversing contested territory. The engineering and software-service association is documented but the project’s broader legal characterisation falls outside this audit’s scope.
• Water Infrastructure Products: Bentley Systems markets OpenFlows WaterGEMS ²⁰ and related hydraulic modelling tools to water utilities globally, and maintains a dedicated water infrastructure industry page ²¹²². A prior AI-generated research brief asserted that Mekorot (Israel’s national water utility) is a named customer of these products; this claim is [UNVERIFIED] — Bentley’s product pages confirm WaterGEMS exists and is marketed to water utilities, and Global Water Intelligence documents Mekorot’s technology procurement profile ²³, but no primary source (Mekorot annual report, Israeli government tender database, or Bentley customer announcement) independently naming Mekorot as a Bentley client was accessible. This claim is noted as an evidence gap, not a confirmed finding.
• Israeli Civil Infrastructure Tenders: A Netivei Israel / iroads.co.il tender document ²⁴ exists referencing CAD standards for infrastructure work. Training knowledge confirms MicroStation (Bentley Systems’ flagship CAD platform) ²⁵ is widely used in Israeli civil infrastructure; however, direct mandate text naming MicroStation specifically in bypass-road or settlement-road contexts is [PARTIALLY CORROBORATED] and would require direct document review for a definitive finding.
• Israeli Ministry of Defense — IMOD: A prior AI-generated brief cited the Technion/Sinaenco academic presentation ²⁶ as evidence that IMOD uses Bentley Triforma / AECOsim / ProjectWise ²⁷. This claim is [UNVERIFIED] — the cited source is a conference slide deck, not a procurement record; Israeli Ministry of Defense procurement records are largely classified or not publicly accessible. The claim is noted as unconfirmed.

Employment and Tax Contribution

Bentley Systems: No public evidence identified of direct Israeli employee headcount or Israeli tax registration for Bentley Systems as a distinct entity. Any Israeli employment associated with Bentley software distribution would be under Malam Team / Team Software’s payroll and tax registration, not Bentley Systems’.

Bentley Motors: No direct Israeli employees identified. Employment at the Orchid Sports Cars dealership is under the Orchid legal entity, not Bentley Motors.

Armored Vehicle Aftermarket

Third-party armoring specialists INKAS Armored Vehicles ²⁸ and Alpine Armoring ²⁹ both publicly market armored conversions of the Bentley Bentayga SUV. This is a standard luxury-vehicle aftermarket practice conducted entirely by independent third parties; Bentley Motors does not manufacture, warrant, or endorse these conversions. No contractual relationship between Bentley Motors and these armoring firms, or between these firms and Israeli government entities, has been identified in public sources. This finding is noted for completeness only.

Market Positioning Statements

Bentley Motors’ Autocar Professional coverage ⁷ characterises Israel as a market the brand is “actively pursuing,” citing demand from the affluent Israeli technology sector. No equivalent characterisation of Israel as a named strategic growth market appears in VW Group’s formal annual report disclosures ¹². Bentley Systems does not separately name Israel as a strategic growth market in its 2023 10-K or investor presentations ¹.

Corporate Structure & Foundational Ties

Founding, Incorporation, and Headquarters

Bentley Systems, Incorporated: Founded in 1984 in Exton, Pennsylvania, USA by Keith Bentley and Barry Bentley ³. Legal domicile: Delaware, USA. Operational headquarters: Exton, Pennsylvania, USA ¹³. No Israeli origin, founding event, or Israeli-origin founding acquisition. The company has been headquartered continuously in the United States since inception.

Bentley Motors Limited: Founded in 1919 in London, England by W.O. Bentley. No Israeli origin or founding nexus. Acquired by Volkswagen Group in 1998 from Vickers plc. Headquartered in Crewe, England since the 1940s. No dual or legacy Israeli headquarters.

State and Institutional Ownership Linkages

Bentley Systems: The company has active US federal government procurement relationships, including a confirmed contract with the US Army Corps of Engineers (Contract W912DY24F0064, documented on USASpending.gov ³⁰). No Israeli state ownership stake, Israeli government board appointees, or publicly identified Israeli government procurement contracts have been found in available records. No designation as Israeli critical national infrastructure identified.

Bentley Motors / VW Group: The Lower Saxony state government (Germany) holds approximately 11.8% of VW AG ordinary shares and holds two supervisory board seats under statutory arrangements rooted in the “VW Law” (Volkswagen Act, as amended) ¹². This represents German federal-state institutional linkage, not Israeli state linkage. No Israeli government ownership stake or board appointee has been identified for either Bentley entity or VW Group.

Governance and Voting Control

Bentley Systems: Maintains a dual-class share structure (Class A / Class B shares), with Class B shares carrying ten votes per share, concentrating effective voting control in the founding Bentley family independent of economic ownership ¹³. No charter restriction or golden-share arrangement linking corporate governance to Israeli state policy or institutions identified.

Bentley Motors / VW Group: VW Group’s governance structure links certain decisions to the Lower Saxony state government (Germany) under the VW Law ¹². No structural governance features linking Bentley Motors or VW Group operations to Israeli state institutions identified.

Subsidiary and Affiliate Structure — Israeli Entities

Bentley Systems: No Israeli-incorporated subsidiary or affiliate disclosed in BSY’s 10-K or IPO prospectus subsidiary schedules ¹³. The Malam Team / Team Software relationship is a commercial channel partnership, not a structural subsidiary relationship.

Bentley Motors / VW Group: VW Group’s Konnect hub ¹⁴ operates in Tel Aviv as a VW Group initiative. Mobileye Global Inc. ¹⁵, while a key technology partner and former Intel subsidiary, is not a VW Group subsidiary; it is a separately listed public company (Nasdaq: MBLY). No VW Group Israeli subsidiary in the automotive manufacturing, retail, or financial services sector has been identified in publicly available group reporting ¹².

Profit Repatriation & Economic Contribution

Revenue Attribution and Geographic Disaggregation

Bentley Systems: Total 2023 revenue of approximately $1.23 billion ¹⁷. Geographic revenue is reported in the 10-K across three segments: Americas, EMEA, and APAC ¹. Israel is not separately disclosed and is aggregated within the EMEA segment. No Israel-specific revenue figure is publicly available. The EMEA segment encompasses Europe, the Middle East, and Africa broadly; the relative weight of Israeli revenue within EMEA cannot be determined from public disclosures.

Bentley Motors: Revenue is consolidated within VW Group financials under the “Premium” brand group alongside Audi and Porsche ¹². No Israel-specific revenue figure is publicly disclosed for Bentley Motors. Vehicle sales to Israeli consumers through Orchid Sports Cars represent a niche luxury import flow; no volume or value data is publicly available.

Profit Flow Architecture

Bentley Systems: Revenue collected from Israeli end users through the Malam Team / Team Software channel flows upstream to Bentley Systems (Exton, Pennsylvania) as software licensing and subscription revenue — net of the channel partner’s margin. These profits ultimately benefit Bentley Systems’ US-domiciled shareholders and the founding Bentley family, which controls voting rights through the Class B share structure ¹³. No evidence of profit repatriation from Bentley Systems to any Israeli-domiciled entity identified.

Bentley Motors: Revenue from vehicle sales through Orchid Sports Cars flows to Bentley Motors (Crewe, England) as wholesale transfer pricing — net of Orchid’s distributor margin, which is retained in Israel under the Orchid corporate entity. Bentley Motors’ profits flow upward to Volkswagen AG (Wolfsburg, Germany) and ultimately to the primary beneficial shareholders: Porsche Automobil Holding SE (Porsche-Piëch families) and the Qatar Investment Authority ¹². No evidence of profit repatriation from Bentley Motors or VW Group to Israeli-domiciled entities identified.

VW Group — Mobileye Technology Payments: To the extent VW Group pays licensing fees or technology royalties to Mobileye under the terms of their expanded 2022 partnership ⁹¹⁰, these payments constitute an ongoing economic flow from VW Group (and by structural implication, from all VW brands including Bentley Motors) to a Jerusalem-headquartered Israeli public company ¹⁵¹⁶. The specific value of these payments is not disclosed in public VW Group reporting ¹².

Economic Ecosystem Role

Bentley Systems in Israel: No public evidence identified of a government designation, industry report, or public assessment characterising Bentley Systems as a key employer, sector anchor, or critical infrastructure software provider within the Israeli economy specifically. Malam Team, the channel partner, is publicly documented as a significant IT integrator in Israel with government and defence contracts ⁵; to the extent Bentley Systems’ software is embedded in Malam Team’s systems integration offerings, Bentley Systems is an upstream contributor to Malam Team’s Israeli government-sector business.

Bentley Motors in Israel: No public evidence identified of any designation of Bentley Motors as a significant contributor to the Israeli economy. The Orchid Sports Cars dealership represents a niche luxury import operation; its economic contribution to the Israeli economy is primarily through Orchid’s own employment, value-added tax contributions, and import duties — all of which are attributable to Orchid as the importer of record, not to Bentley Motors directly.

Middle East Infrastructure Engagement (Bentley Systems): Bentley Systems’ editorial content ¹⁸ and its Infrastructure Top 500 publication ³¹ reference Middle East infrastructure as an active market for the company’s engineering software. The Jerusalem Light Rail case study ¹³ and the water infrastructure product suite ²²²⁰²¹ represent documented or plausible points of economic contribution to Israeli public infrastructure programs. The unverified Mekorot claim ²³ and the unverified IMOD claim ²⁶, if substantiated by primary sources, would materially expand the assessment of Bentley Systems’ economic role in Israeli public-sector operations.

End Notes