V-ECON Audit: Caterpillar Inc

Audit Phase: V-ECON Audit Subject Entity: Caterpillar Inc. (NYSE: CAT) Jurisdiction Focus: Israel and Occupied Palestinian Territory Operations Audit Date: 2025 Classification: Final

Supply Chain & Sourcing Relationships

Direct Supplier Relationships

• No public evidence identified linking Caterpillar to Israeli agricultural exporters (Mehadrin, Hadiklaim, Galilee Export, Agrexco/Better Produce) or settlement-origin produce. Caterpillar manufactures heavy construction equipment; this product category does not involve agricultural commodity sourcing. ¹

Importer of Record Structure

• Israel Tractors & Equipment Co. (I.T.E.) Ltd operates as the exclusive Caterpillar dealer in Israel, founded in 1948, headquartered in Holon with seven branches nationwide. ²
• I.T.E. is a subsidiary of Zoko Enterprises, which functions as the exclusive supplier of Caterpillar heavy machinery to the Israeli military. ³²
• Zoko Enterprises and I.T.E. perform retrofitting of Caterpillar equipment including armor plating, gunner positions, bulletproof driver cabins, and autonomous systems integration. ³

Seasonal Sourcing Patterns

• No public evidence identified regarding seasonal procurement patterns from Israeli suppliers for Caterpillar products. Caterpillar manufactures heavy construction equipment; this category does not involve agricultural commodity sourcing. ¹

Third-Party and Indirect Sourcing

• No public evidence identified of Israeli-origin Caterpillar products reaching target markets via third-party distributors or white-label arrangements. Caterpillar operates through a direct dealer network. ¹²

Product Origin, Labeling & Regulatory Compliance

Settlement-Origin Products

• Caterpillar products are industrial equipment (bulldozers, excavators), not consumer goods subject to country-of-origin labeling regulations. No settlement-origin labeling issues applicable to this product category. ¹

Labeling Compliance

• Not applicable to Caterpillar’s product category (heavy machinery). No regulatory enforcement actions identified regarding product labeling. ¹

Corporate Labeling Policy

• No public evidence identified of a stated corporate policy specifically addressing sourcing or labeling of goods from occupied or contested territories. Caterpillar’s Supplier Code of Conduct does not contain territory-specific provisions identified in public disclosures. ¹⁴

Investment, Capital & Financial Exposure

Foreign Direct Investment

• No public evidence identified of Caterpillar direct capital investments (acquisitions, factories, data centers, logistics hubs, or real estate holdings) within Israel or occupied territories. Caterpillar’s Israeli presence operates through independent dealer entities (I.T.E./Zoko), not wholly-owned subsidiaries. ¹²⁴
• Caterpillar’s SEC 10-K filings do not disclose Israeli-specific foreign direct investment. ⁴

Research and Development Facilities

• No public evidence identified of Caterpillar R&D facilities, technology partnerships, innovation labs, or accelerator programmes within Israel. ¹⁴

Parent and Beneficial Ownership Flows

• Caterpillar Inc. (NYSE: CAT) is publicly traded on the New York Stock Exchange; no private equity sponsor or majority shareholder identified with separate Israeli investment exposure. Parent company structure does not include Israeli-domiciled entities. ⁴
• Zoko Enterprises and I.T.E. are described as independent companies, not wholly-owned Caterpillar subsidiaries. ³²

Portfolio and Fund Exposure

• Caterpillar is held by major European financial institutions as equity and debt. The Don’t Buy Into Occupation (DBIO) 2024 report documents 822 European financial institutions with $211 billion in loans and underwriting and $182 billion in shares and bonds to 58 settlement-linked companies, with Caterpillar among the highest-receiving companies. ⁵
• Dutch pension funds ABP and PFZW have sold Caterpillar shares in 2024. ING maintains loans to Caterpillar. Achmea and ASR still hold Caterpillar shares. ⁶
• Norway’s Government Pension Fund Global (GPFG) excluded Caterpillar in August 2025, holding a 1.2% stake valued at $2.1 billion at the time of exclusion. ⁷
• KLP excluded Caterpillar from its investment portfolios in June 2024, citing unacceptable risk of contributing to human rights violations. ⁸
• Alameda County sold $32 million in Caterpillar bonds in December 2024. ⁹

Operational Presence & Market Activity

Physical Footprint

• Caterpillar does not operate offices, warehouses, or retail locations directly in Israel or occupied territories. Operations are conducted through an independent dealer network. ¹²
• I.T.E. operates seven branches nationwide in Israel as the exclusive Caterpillar dealer. ²
• No Caterpillar-authorized service facilities identified in West Bank, East Jerusalem, or Golan Heights settlements. ¹

Employment and Tax Contribution

• No public evidence identified of Caterpillar’s direct workforce size or tax registration status in Israel. I.T.E. is an independent company; Caterpillar does not directly employ Israeli residents. ¹²

Market Positioning

• Caterpillar’s SEC 10-K filings do not characterize Israel as a specific market. Geographic segment reporting groups results into regions (e.g., “Asia/Pacific,” “EAME”) without Israel-specific disclosure. ⁴
• Caterpillar’s annual reports and investor presentations do not identify Israel as a strategic growth market or major export destination in public disclosures. ⁴

Corporate Structure & Foundational Ties

Founding and Incorporation History

• Caterpillar Inc. was founded in 1925 in California, United States. The company was not founded in Israel and has no Israeli-origin operations. ⁴

Headquarters and Domicile

• Caterpillar Inc. is incorporated in Delaware, USA, with operational headquarters in Irving, Texas. No dual or legacy headquarters in Israel. ⁴

State and Institutional Linkages

• Caterpillar receives U.S. government approval for Foreign Military Sales to Israel. The Defense Security Cooperation Agency approved a $295 million Foreign Military Sale of Caterpillar D9R and D9T bulldozers to Israel in February 2025, with deliveries expected to begin in 2027. ¹⁰
• Caterpillar equipment is modified by Israeli state-owned defense contractor Israel Aerospace Industries (IAI), which develops unmanned D9 variants (including the Panda RobDozer, “Thunder of Dawn,” and “Winnie the Pooh”) using Caterpillar base platforms. ¹

UN OHCHR Settlement Enterprise Database

• Caterpillar is listed in the UN Human Rights Council Resolution 31/36 settlement enterprise database (published February 2020, updated periodically), cited for activities including: supply of equipment for demolition of housing and property; supply of equipment facilitating construction and expansion of settlements and the wall. ¹¹¹²¹³

UN Special Rapporteur Report

• The UN Special Rapporteur’s report A/HRC/59/23 (Albanese, July 2025) explicitly names Caterpillar among companies providing equipment used to demolish Palestinian homes, with specific reference to D9 bulldozers and partnership with the Israeli defense industry. ¹⁴

Governance Features

• No public evidence identified of governance mechanisms (golden shares, founder shares, charter restrictions) structurally tying Caterpillar to the Israeli state. ⁴

Profit Repatriation & Economic Contribution

Revenue Attribution

• Caterpillar’s SEC filings do not disclose Israel-specific revenue. The company does not break out Israeli market revenue in public filings. ⁴

Profit Flows

• Caterpillar’s global profits flow to its U.S. parent company in Delaware. No evidence of Israeli-domiciled ownership of Caterpillar or profit flows into Israel from Caterpillar’s global operations. ⁴

Economic Ecosystem Role

• No public evidence identified of Caterpillar being characterized as a key employer, sector anchor, or infrastructure provider within the Israeli economy. Caterpillar’s Israeli dealer (I.T.E.) is an independent entity. ¹²

Documented Military Use

• Caterpillar D9 armored bulldozers have been documented in: house demolitions (thousands of Palestinian homes since 1967); settlement construction and expansion; Separation Wall construction; military ground operations in Gaza (2008–2009, 2014, 2021, 2023–present); crowd control against demonstrators (Great March of Return 2018–2019); and killing of civilians including Rachel Corrie (2003). ¹¹⁵

Post-ICJ and ICC Continuity

• Caterpillar equipment deployments are documented as continuing after the July 2024 ICJ Advisory Opinion and after the November 2024 ICC arrest warrants. A July 2025 shipment of dozens of Caterpillar D9 bulldozers was delivered to the Israeli military from the United States, transferred for armor installation and autonomous conversion. ¹¹¹

Legal Proceedings

• Corrie et al. v. Caterpillar was filed in U.S. District Court (Washington state, 2005), alleging Alien Tort Statute violations. The Ninth Circuit dismissed the case in September 2007, ruling beyond court jurisdiction to question foreign policy decisions. ¹⁶

Shareholder Activism

• Jewish Voice for Peace and allied shareholders submitted annual resolutions to Caterpillar from 2011 to 2016, receiving 21% support in 2011. Caterpillar successfully obtained SEC no-action relief in 2013 preventing a shareholder proposal. ¹⁷

Norway Government Pension Fund Global Exclusion Rationale

• The Council on Ethics stated “no doubt that Caterpillar’s products are being used to commit extensive and systematic violations of international humanitarian law” and that “the company has also not implemented any measures to prevent such use.” ¹⁸

End Notes