V-POL Audit: Caterpillar Inc

Audit Phase: V-POL Audit Target Entity: Caterpillar Inc. (NYSE: CAT) Date of Audit Documentation: Based on research through April 2026 Audit Standard: Evidence-based review of publicly available information

Corporate Communications & Public Stance

Official Position on Israel-Gaza (2023–2025)

Caterpillar’s recurring public position, documented across multiple years at the Business & Human Rights Resource Centre, states that the company “does not condone the illegal or immoral use of any Caterpillar equipment” and frames all sales to Israel as passing through the U.S. Foreign Military Sales (FMS) program, positioning the U.S. government as the direct customer ¹.

Caterpillar issued no public statement specifically naming Gaza or the West Bank as a subject of operational review during or after October 2023 ¹.

In 2025, Caterpillar issued a formal response to the Norwegian GPFG Council on Ethics exclusion recommendation, reiterating the FMS-channel argument and stating it engages with the U.S. government on responsible use of FMS-supplied equipment. The response did not announce any suspension, review, or modification of its D9 supply relationships or dealer network operations, and did not reference the ICJ Advisory Opinion of July 2024 or the ICC arrest warrants of November 2024 ².

Caterpillar’s response to the GPFG Council stated: “We have compassion for all persons affected by the political strife in the Middle East and support a peaceful resolution to the Israeli-Palestinian conflict” ¹.

Comparative Silence — Ukraine vs. Gaza

In 2022, Caterpillar produced: (a) an explicit named public statement on Ukraine and Russia; (b) a documented suspension of manufacturing and supply chain operations in Russia; and (c) a separate, named Caterpillar Foundation press release of $1 million for Ukrainian humanitarian needs that explicitly identified Ukraine as the beneficiary ³⁴⁵.

The 2023 Gaza-adjacent donation matched the dollar figure ($1 million) but was issued without named-party acknowledgment, without operational action, and without any equivalent public review of equipment end-use ⁶.

Caterpillar has issued public statements on COVID-19 workforce impacts (2020), racial equity (2020), and climate commitments across multiple annual reporting cycles, none of which involved operational suspensions of the type executed in the Russia withdrawal ³⁵.

The Russia exit remains the singular documented precedent for operational action in response to geopolitical events ³⁵.

Market Framing in Annual Reports and SEC Filings

Caterpillar’s 10-K filings treat the Middle East as part of the “EAME” (Europe, Africa, Middle East) geographic segment; Israel is not broken out as a separate reporting line ⁷⁸.

Annual proxy statements from 2020 onward include boilerplate language identifying “export controls,” “sanctions compliance,” and “anti-boycott laws” as regulatory risk factors, without naming specific countries ⁹¹⁰¹¹.

Caterpillar’s 2024 10-K (covering fiscal year 2024, filed February 2025) includes updated risk factor language that explicitly references the Israel-Gaza conflict by name as a source of geopolitical and supply-chain risk ⁷¹².

The EAME segment reported revenues of approximately $8.2–8.5 billion for FY2024; Israel is not separately broken out within the segment ⁷¹².

Constructive Notice — Post-ICJ and Post-ICC Conduct

The ICJ issued its Advisory Opinion on July 19, 2024, concluding that Israel’s occupation is unlawful in its entirety under international law ¹³¹⁴.

The ICC’s Pre-Trial Chamber I issued arrest warrants for Israeli Prime Minister Benjamin Netanyahu and former Defense Minister Yoav Gallant on November 21, 2024 ¹⁵.

The DSCA notification for the $295 million D9 bulldozer FMS sale to Israel is dated February 28, 2025 — approximately seven months after the ICJ Advisory Opinion and three months after the ICC arrest warrants. Caterpillar remained the named principal contractor on this FMS sale ¹⁶.

A comprehensive sweep of all Caterpillar public communications from July 19, 2024 through April 2026 — encompassing press releases, SEC filings, investor earnings calls, the 2025 proxy statement, and the GPFG formal response — identified no public reference to the ICJ Advisory Opinion or the ICC arrest warrants in any Caterpillar corporate communication ²⁹¹⁰.

Multiple credible journalistic sources documented IDF Combat Engineering Corps D9 bulldozer use in Gaza operations beginning October 2023 and continuing through 2024–2025, including clearing operations in Rafah, Khan Younis, Jabalia, and northern Gaza ¹⁷¹⁸.

UN Human Rights Experts issued a statement in June 2024 calling on Caterpillar and weapons companies to “immediately stop the transfer of weapons and other military equipment to Israel” as they may constitute serious violations of human rights and international humanitarian law ¹⁹.

Operations in Occupied or Contested Territories

Territorial Presence — Dealer Network and West Bank Operations

Caterpillar sells and services equipment in Israel through its exclusive authorized dealer, Zoko Enterprises (also referred to as “Zoko Shiluvim” and “Israel Tractors and Equipment – ITE”) ²⁰.

Who Profits Research Center documents Zoko as operating within the occupied West Bank, supplying equipment to construction projects in Israeli settlements ²⁰²¹.

Updated Who Profits documentation (2024) documents Zoko/ITE supplying Caterpillar equipment for: road construction connecting settlements to Israeli-controlled highway networks; quarrying and earthmoving for settlement expansion projects; and infrastructure contracts for Israeli government-tendered projects within Area C of the West Bank, under Israeli Civil Administration authority ²¹.

These are commercial sales through the dealer network, distinct from FMS transactions. Caterpillar’s public communications have not addressed this aspect of Zoko’s operations; the FMS deflection applies only to IDF/military sales, not to Zoko’s civilian settlement construction contracts ²¹¹.

UN OHCHR Businesses Database

The UN OHCHR published its initial database of businesses with activities in Israeli settlements in February 2020, pursuant to HRC resolution 31/36. Caterpillar Inc. is not listed in the UN OHCHR database in the initial 2020 publication or in updates available as of research cutoff ²².

The database methodology is limited to companies directly operating in or supplying settlement infrastructure; Caterpillar’s sales structure — routing through the U.S. FMS program and through an independent authorized dealer (Zoko) rather than through a direct subsidiary — placed it outside the database’s definitional scope as applied ²².

Zoko Enterprises/ITE is documented by Who Profits as operating in settlement-related construction but is not itself listed in the UN database as a named entity ²²²⁰.

IDF D9 Bulldozer Program

The IDF operates a fleet of Caterpillar D9 bulldozers within its Combat Engineering Corps, designated the “IDF Caterpillar D9.” Following delivery, these units are retrofitted with armor plating and protective systems by Israeli defense contractors ²³.

The D9’s IDF role is corroborated by both defense documentation and official U.S. government DSCA procurement records ¹⁶²³.

A March 2025 DSCA notification announced U.S. government approval of a Foreign Military Sale to Israel of Caterpillar D9 bulldozers, estimated at $295 million, with Caterpillar Inc. named as principal contractor ¹⁶.

The sale includes D9R and D9T bulldozers, spare and repair parts, corrosion protection, publications and technical documentation, pre-delivery inspections, U.S. Government and contractor support, technical and logistics support services, storage and program support. Deliveries are estimated to begin in 2027 ¹⁶.

The administration invoked an emergency waiver under Section 36(b) of the Arms Export Control Act to bypass the standard 30-day congressional review period ¹⁶²⁴.

The IDF’s development of remote-controlled and semi-autonomous D9 variants is confirmed in defense press; the remote-controlled variant was developed for use in environments where operator exposure is deemed too dangerous ²³.

Multiple credible journalistic sources documented IDF D9 use in Rafah, Khan Younis, Jabalia, and northern Gaza from October 2023 onward, as well as in IDF raids on Jenin and Tulkarem refugee camps in the West Bank during 2023–2025 ¹⁷¹⁸.

NGO Naming in Major Reports

Al-Haq’s 2024 report “Business and Human Rights: Corporate Complicity in Israel’s Violations of International Law” names Caterpillar Inc. by name in its section addressing demolition and earthmoving equipment suppliers ²⁵.

The report cites the D9 bulldozer’s documented use in Gaza operations, references prior Al-Haq submissions to the UN Human Rights Council regarding D9 use in property destruction in Gaza and the West Bank, and invokes the Corrie v. Caterpillar litigation as background ²⁵.

The report applies the “complicity” standard under the UNGPs: that Caterpillar’s continued supply of D9 bulldozers — via FMS and via the Zoko dealer channel — constitutes “practical assistance” to operations resulting in the destruction of civilian property on a mass scale ²⁵.

UN A/HRC/59/23, titled “From economy of occupation to economy of genocide,” submitted by Special Rapporteur Francesca Albanese on June 2025, applies analytical frameworks at the categorical level (demolition equipment suppliers, construction equipment, financial services) rather than naming individual companies ²⁶²⁷.

Paragraphs 25–27 of A/HRC/59/23 apply the UNGPs’ “know or should have known” standard and argue it is met for any company whose equipment has been documented by credible international bodies as used in systematic civilian property destruction ²⁶²⁷.

Paragraph 71 situates continued supply of enabling equipment within the “economy of genocide” analytical framework and argues that companies continuing supply relationships after the ICJ’s July 19, 2024 Advisory Opinion bear heightened responsibility ²⁶²⁷.

Paragraphs 81–86 identify nominal humanitarian donations not accompanied by operational disengagement as insufficient mitigation under the UNGPs ²⁶²⁷.

The Amnesty International report “Israel’s Apartheid Against Palestinians” (February 2022) and the Human Rights Watch report “A Threshold Crossed” (April 2021) established the apartheid legal characterization for the West Bank and Gaza ²⁸²⁹.

Legal and Regulatory Scrutiny

Corrie v. Caterpillar, Inc., 503 F.3d 974 (9th Cir. 2007) is the landmark litigation arising from this nexus. The family of Rachel Corrie — killed by an IDF-operated D9 in Rafah, Gaza, in March 2003 — sued Caterpillar under the Alien Tort Statute and state law ³⁰.

The Ninth Circuit dismissed the case on political question grounds, ruling the suit impermissibly implicated U.S. foreign policy because the equipment was purchased via the FMS program and the U.S. government had approved the sale. The court did not reach the merits of the underlying human rights claims ³⁰.

The U.S. Chamber of Commerce filed an amicus brief supporting Caterpillar’s position ³¹³⁰.

Institutional Divestments

KLP (Norway’s largest private pension fund) published a formal exclusion decision in June 2024, explicitly citing inability to obtain assurances from Caterpillar that its equipment was not being used in violations of international humanitarian law in Gaza and the West Bank. KLP stated the company was “unwilling to take any substantive steps.” KLP sold its approximately $69 million stake in Caterpillar following the exclusion decision ³²³³³⁴.

The Council on Ethics for Norway’s Government Pension Fund Global (GPFG) issued a recommendation in July 2025 to exclude Caterpillar, citing “unacceptable risk” of contributing to “serious violations of individuals’ rights in situations of war or conflict” and referencing the “extensive and systematic” destruction of Palestinian property by Israeli authorities using Caterpillar equipment ³⁵.

The Council on Ethics stated: “There is 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” ³⁵.

The Council specifically rejected the FMS deflection argument as a sufficient answer to the UNGPs due diligence obligation, and characterized Caterpillar’s 2023 humanitarian donation as not constituting remediation ³⁵.

Norges Bank Investment Management (NBIM) excluded Caterpillar from the GPFG on August 25, 2025, holding 1.23% stake (NOK 24.4 billion, approximately $2.1 billion) at year-end 2024 ³⁶.

Alameda County, California voted in December 2024 to divest approximately $32 million in public funds from Caterpillar, citing human rights concerns ³⁷.

Washington State Treasurer sold $62 million in Caterpillar bonds in 2024–2025 ³⁷.

BDS Campaign and Shareholder Pressure

Caterpillar has been a primary BDS target since at least 2004, following the death of Rachel Corrie ³⁸³⁹.

Shareholder resolutions demanding human rights due diligence reports have been filed at Caterpillar Annual General Meetings in multiple consecutive years — documented from 2005 through at least 2025 — by filers including Sisters of Loretto, groups affiliated with Jewish Voice for Peace, and ICCR members ⁴⁰⁴¹⁴².

The board has recommended voting against these resolutions in every documented instance ⁹¹⁰⁴².

At Caterpillar’s 2024 Annual General Meeting, a shareholder resolution demanded that the Board commission an independent human rights impact assessment of the company’s equipment sales to Israel. The Board recommended voting against the resolution ⁴³⁴⁴.

For Caterpillar’s 2025 Annual Meeting, an ICCR-affiliated shareholder resolution demanding an independent human rights impact assessment was filed. The Board’s 2025 proxy statement recommended voting against the resolution ¹⁰⁴¹.

The 2025 resolution received approximately 28–33% of shares voted in favor ¹⁰⁴¹.

This was reported as the twentieth consecutive year shareholders had filed such a resolution at Caterpillar ⁴⁴.

Caterpillar moved its 2025 AGM from Peoria, Illinois (its headquarters) to Little Rock, Arkansas — a move criticized by activists as an attempt to avoid protest ¹⁰.

An SEC no-action letter correspondence relating to Caterpillar human rights resolutions is on record with the SEC ⁴⁵.

Internal Governance, Content & Retail Policies

Employee Relations

No public reports, lawsuits, or documented disciplinary actions specifically concerning employee speech about Palestine, pro-Palestinian symbols, or union activity related to the Israel-Palestine conflict were identified in research.

Caterpillar’s Code of Personal and Business Conduct (July 2023) includes provisions on political activity, conflicts of interest, and reputational conduct, but contains no language specifically addressing geopolitical conflicts or product end-use ethics ⁴⁶.

No public evidence identified. Source classes checked: NLRB filings, major labor press, BDS movement news archives, Business & Human Rights Resource Centre employee rights section.

Platform and Editorial Policy

Caterpillar is a manufacturing company and does not operate a consumer content platform, social media platform, or editorial publishing operation. This sub-category is structurally inapplicable to Caterpillar’s business model.

No public evidence identified. Not applicable.

Retail and Supply Chain Practices

No public reports or regulatory actions regarding the labeling, sourcing, or categorization of products originating from Israeli settlements in Caterpillar’s supply chain were identified.

Caterpillar’s products are manufactured primarily in the United States, with additional facilities in Europe, Brazil, and Asia. The company does not import consumer goods from the occupied territories.

No public evidence identified. Source classes checked: U.S. Customs records, EU trade regulatory filings, Israeli export documentation.

Cat Financial / Caterpillar Financial Products Corporation

Caterpillar Financial Products Corporation (Cat Financial) operates as a wholly owned finance subsidiary providing retail financing, wholesale financing (floorplan), and operating lease financing for Caterpillar equipment ⁷.

For Israel specifically, research does not confirm that Cat Financial has a direct retail-financing relationship with Israeli end-customers; the Israeli market’s financing structure is not specifically documented in Cat Financial’s public filings or press releases ⁷.

Zoko/ITE, as an independent authorized dealer, may use its own financing arrangements or local Israeli bank financing rather than Cat Financial for retail transactions ⁷.

No positive evidence identified linking Cat Financial to settlement-construction or IDF-adjacent financing.

Brand Heritage & State Partnerships

Military-Industrial Positioning

Caterpillar does not market the D9 using military heritage in civilian-facing advertising, and no Israel-specific “defense branding” campaign was identified ⁴⁷⁴⁸.

Caterpillar’s defense and government products operations explicitly market to military and government customers; the D9’s IDF use is acknowledged in the DSCA FMS record and documented in defense trade publications ¹⁶²⁴.

The company does not suppress this association in defense-sector contexts but does not feature it in civilian investor relations materials ¹⁶²⁴.

Institutional Ties and Sponsorships

No evidence was identified of Caterpillar Inc. (the U.S. parent corporation) receiving Israeli state honors, hosting Israeli government officials in a formal non-commercial capacity, or sponsoring “Brand Israel” cultural campaigns.

CP Holdings Ltd. (UK), the parent company of Zoko Enterprises/ITE, is documented in Who Profits records ⁴⁹. UK Companies House records show current Persons with Significant Control as Mark Adam Gibbor (born July 1988) and Iris Gibbor (born August 1951) ⁵⁰.

The claim that Sir Bernard Schreier of CP Holdings received a “Jubilee Award” from Prime Minister Netanyahu in 1998 is reproduced in secondary civil-society sources but has not been confirmed from a primary Israeli government record or Israeli press archive in research ⁴⁹³⁹.

A claimed specific named Caterpillar-Technion partnership involving a “Panda” remote-controlled D9T is unverified from primary sources. The IDF’s development of remote-controlled D9 variants is confirmed in defense press, but attribution to a Caterpillar-funded Technion project is not confirmed ²³⁵¹.

Lobbying, Advocacy, Financing & Logistics

Political Lobbying

Caterpillar is a registered federal lobbyist with disclosures covering issues including infrastructure spending, export controls, trade policy, and Foreign Military Financing ⁵².

The company is a member of the Business Roundtable (BRT) and the National Association of Manufacturers (NAM), both of which have lobbied against BDS-related legislation at state and federal levels and have supported anti-boycott bills ⁹¹⁰.

The BRT has also aligned with Caterpillar’s FMS-deflection position on equipment liability, including through the U.S. Chamber of Commerce amicus brief in Corrie v. Caterpillar ³¹.

Caterpillar’s Lobbying Disclosure Act filings disclose lobbying activity under issue area codes TRD (Trade), FOR (Foreign Policy), and DEF (Defense) ⁵².

Caterpillar discloses lobbying on “Foreign Military Sales program administration” and “export control regulations” under the TRD and DEF codes ⁵².

No LDA filing specifically names “BDS,” “Israel Anti-Boycott Act,” or equivalent Israel-specific anti-BDS legislative language as a Caterpillar lobbying issue in the company’s own right ⁵².

The FMS program lobbying has the functional effect of protecting Caterpillar’s D9 sales channel to Israel but is categorized in procurement and export-control terms rather than Israel-specific advocacy terms ⁵².

Financial Contributions

The Caterpillar Foundation (EIN 37-6061351) files annual IRS Form 990s as a public charity ⁵³⁵⁴.

The Foundation’s publicly stated focus areas are education, environmental sustainability, and community development ⁵³.

In October 2023, the Caterpillar Foundation announced a $1 million donation “to support humanitarian efforts” following the October 7 events in Israel. The release did not name recipient organizations, did not identify recipient organizations, and did not reference any operational review or supply-chain assessment ⁶.

Research of the Foundation’s publicly available 990 filings does not confirm grants to FIDF, JNF/KKL, Lev Echad, Israeli military welfare organizations, settlement groups, or pro-Israel advocacy organizations ^53555657.

The identity of the recipient organizations for the $1 million donation remains an open evidence gap; the 990 filing detail (Schedule I) requires direct extraction to confirm or exclude FIDF, JNF, or settlement-adjacent recipients ⁵³⁵⁵.

No evidence of corporate donations to settlement groups or military-welfare funds was identified in research. Source classes checked: corporate press releases, charity watchdog databases, Business & Human Rights Resource Centre.

Caterpillar Inc. PAC

Caterpillar maintains a Political Action Committee (Caterpillar Inc. PAC, FEC Committee ID: C00040980) with disclosed federal contributions on record with the FEC ⁵⁸.

Documented recipients include members of the House and Senate Armed Services Committees, House Transportation & Infrastructure Committee, and Senate Finance Committee ⁵⁸.

Research does not identify Caterpillar PAC contributions specifically to NORPAC, DMJPAC, AIPAC-affiliated PACs, or to candidates selected primarily on Israel-policy grounds ⁵⁸.

The PAC has donated to sponsors of anti-BDS legislation, but these recipients also sit on committees of primary relevance to Caterpillar’s core interests (trade, defense), and the donations cannot be attributed specifically to anti-BDS motivation without additional evidence ⁵⁸.

Crisis Asset Mobilization

The February 28, 2025 DSCA-notified FMS sale of Caterpillar D9 bulldozers to Israel, valued at approximately $295 million and with Caterpillar named as principal contractor, constitutes the delivery of physical corporate assets during an active conflict ¹⁶.

This is a government-to-government transaction, formally separate from direct commercial sales, but it confirms Caterpillar’s continued production and fulfillment role during the period of the Gaza conflict and post-ICJ Advisory Opinion ¹⁶²⁴.

The sale proceeded with no accompanying public statement from Caterpillar addressing the post-ICJ legal context ².

Senator Bernie Sanders introduced S.J.Res.32 in March 2025 — a Joint Resolution of Disapproval to block the $295 million D9 bulldozer FMS sale to Israel ⁵⁹.

Corporate Structure & Primary Mission

Foundational Mandate and Ownership

Caterpillar Inc. was incorporated in Delaware in 1925 as a merger of Holt Manufacturing and C.L. Best Tractor Co. Its corporate charter defines it as a commercial manufacturer of construction, mining, and energy equipment ⁴⁷⁴⁸.

There is no provision in its charter, no golden share held by any state, and no founding document language tying its mission to Israeli or U.S. government geopolitical objectives ⁴⁷⁴⁸.

Caterpillar is a publicly traded corporation (NYSE: CAT) with no state-held shares and no sovereign ownership stake ⁹¹⁰.

Its largest shareholders are institutional asset managers (Vanguard, BlackRock, State Street), none of which hold golden shares or carry governance rights beyond standard voting, as documented in its annual proxy statements ⁹¹⁰.

Stated Corporate Purpose

The company’s stated corporate purpose, per its 2023 Annual Report, is to help customers build a better, more sustainable world — framed in standard commercial and ESG terms, not geopolitical terms ⁴⁷⁴⁸.

Annual proxy statements include boilerplate risk disclosures on export controls, sanctions compliance, and anti-boycott laws without naming specific countries ⁹¹⁰.

The 2024 10-K marks the first documented instance in which the Israel-Gaza conflict was explicitly named as a material risk factor in Caterpillar’s SEC filings ⁷¹².

Executive & Leadership Footprint

D. James Umpleby III (Chairman & CEO, 2017–present)

Confirmed as CEO from January 2017 and Chairman from 2018 ⁶⁰.

No personal philanthropic donations to FIDF, JNF, or regional advocacy organizations were identified in research ⁹¹⁰.

No public statements, op-eds, or signed letters by Umpleby specifically addressing the Israel-Palestine conflict were identified across news archives, advocacy organization member lists, or SEC filings ⁹¹⁰.

The company’s public positions on the issue are delivered through the corporate communications function, not through personal executive statements ¹.

Umpleby’s personal philanthropic activity, to the extent discernible from public records, appears oriented toward engineering education and Peoria-area community organizations ⁹¹⁰.

His equity holdings disclosed in DEF 14A proxy statements consist of Caterpillar stock, stock options, and deferred compensation units; no personal equity positions in Elbit Systems, Rafael, IAI, or other Israeli defense or surveillance firms have been identified ⁹¹⁰.

No board seat, advisory role, or leadership position in AIPAC, FIDF, ADL, USISTF, or equivalent organizations has been identified ⁹¹⁰.

Susan Schwab (Board Director, 2009–present)

Confirmed former U.S. Trade Representative (2006–2009) and strategic advisor at Mayer Brown LLP ⁶¹.

Her board tenure at Caterpillar is documented in governance filings ⁹¹⁰.

No evidence of personal donations or advocacy positions regarding the Israel-Palestine conflict was identified ⁹¹⁰.

David L. Calhoun (Former Board Director, 2011–2024)

Confirmed departure from Caterpillar’s board in 2024 ⁶⁰.

Calhoun served concurrently as Boeing CEO (2020–2024) ⁶⁰.

No evidence of personal donations or advocacy regarding Israel-Palestine was identified ⁶⁰.

His presence on Caterpillar’s board while leading Boeing is a structural governance fact, not a personal advocacy finding ⁶⁰.

Other Board Members

Caterpillar’s board as of 2023–2024 comprised approximately 10–12 directors with backgrounds in manufacturing, energy, financial services, and government ⁹¹⁰.

No board members were identified in research as holding personal leadership roles in AIPAC, FIDF, JNF, or equivalent organizations ⁹¹⁰.

Dealer-Level Leadership (Zoko/CP Holdings)

Zoko/CP Holdings leadership are not Caterpillar Inc. corporate officers or board members ⁴⁹²⁰.

Who Profits documents CP Holdings’ ownership of Zoko ⁴⁹.

CP Holdings is a privately held UK conglomerate; its ownership structure is documented in UK Companies House records showing PSCs as Mark Adam Gibbor and Iris Gibbor ⁵⁰.

The specific claim about a named historical chairman and a 1998 Israeli government award is reproduced in secondary civil-society sources but has not been confirmed from a primary Israeli government record or UK Companies House director history in research ⁴⁹³⁹.

End Notes