V-POL Audit: HSBC Holdings plc

Audit Phase: V-POL (Values-Politics)
Target Entity: HSBC Holdings plc
Jurisdiction: United Kingdom (Incorporation) / Global Operations
Audit Date: 2025

Corporate Communications & Public Stance

HSBC has maintained a stance of institutional silence on the October 2023 Hamas attack and subsequent Israeli military operations in Gaza. The bank issued no standalone corporate statements specifically addressing these events through early 2025¹. This approach aligns with HSBC’s broader public communications framework, which explicitly emphasizes “political neutrality” for contested geopolitical conflicts not directly affecting operating licences — a posture consistent with its positioning during the Hong Kong protests of 2019-2020¹.

A notable disparity exists between HSBC’s response to the Ukraine conflict and its silence on Gaza. HSBC issued formal statements condemning Russia’s invasion of Ukraine in February 2022, announced the suspension of new business in Russia and Belarus, and absorbed approximately $300 million in write-downs. No equivalent positioning was adopted for Gaza¹.

Following the International Court of Justice (ICJ) Advisory Opinion in July 2024, which determined that Israel’s occupation of Palestinian territories is unlawful, no confirmed HSBC statement was identified revising investment or financing posture in response to this ruling. There is no public acknowledgment of any obligation under international law arising from the ICJ opinion¹.

Similarly, following the International Criminal Court (ICC) arrest warrants issued in November 2024 for Israeli Prime Minister Benjamin Netanyahu and Defence Minister Yoav Gallant, no confirmed HSBC statement was identified revising its posture in response to these developments¹.

No public evidence identified for any HSBC statements supporting or condemning specific military operations, calling for ceasefire, or addressing civilian casualties in Gaza.

Operations in Occupied or Contested Territories

HSBC operates directly in Israel through HSBC Bank plc, which holds a full commercial banking licence. According to the Israel Country Commercial Guide, there are currently five foreign banks with commercial activities in Israel: Citibank NA, HSBC Bank plc, Barclays Bank plc, BNP Paribas Israel, and State Bank of India². HSBC Israel offers commercial banking, investment banking, and treasury services³.

Regarding the United Nations Office of the High Commissioner for Human Rights (UN OHCHR) database of businesses involved in Israeli settlements, the 2025 database update listed 158 business enterprises from 11 countries involved in settlement activity. Multiple searches confirm that HSBC is NOT listed in the database⁴⁵.

In terms of infrastructure financing, HSBC and Bank Leumi provided €1 billion ($1.1 billion) in financing for the Tel Aviv Purple Line light rail project, with financial close achieved in July 2023⁶. This project serves areas within Israel’s municipal boundaries and across the Tel Aviv metropolitan region.

HSBC maintains correspondent banking relationships with Israeli banks including Bank Hapoalim, Bank Leumi, Mizrahi Tefahot, Israel Discount Bank, and First International Bank⁷.

Regarding Israeli sovereign bond underwriting, HSBC is NOT among the seven underwriters identified for Israeli sovereign bonds ($19.4 billion, October 2023-January 2025). The identified underwriters are Goldman Sachs, Bank of America, Deutsche Bank, BNP Paribas, Citi, Barclays, and JPMorgan⁸.

No public evidence identified for HSBC operations in the Occupied Palestinian Territories (OPT) beyond Israel proper.

Internal Governance, Content & Retail Policies

HSBC’s Code of Conduct, last updated in October 2024, instructs employees to avoid actions that could be interpreted as taking political stances on contested geopolitical matters. The policy is general in nature and not specific to any particular conflict⁹.

Reports from October-November 2023 described HSBC employees in the United Kingdom staging informal workplace protests wearing keffiyehs and displaying Palestinian symbols. No confirmed legal proceedings or employment tribunal cases specifically linked to HSBC’s handling of employee speech on Gaza were identified⁹.

Content moderation frameworks do not apply to HSBC as the entity is a financial services provider rather than a platform or media company.

No public evidence identified for retail policies, supply chain policies, or content moderation practices relevant to this audit domain.

Brand Heritage & State Partnerships

HSBC’s brand identity centres on global connectivity and trade, historically positioning itself as “The World’s Local Bank.” No evidence was identified of Israeli military or security-sector associations in commercial branding¹.

HSBC maintains relationships with Gulf state sovereign wealth funds, including the Abu Dhabi Investment Authority and Saudi Public Investment Fund, as documented in annual reports¹.

No confirmed evidence was identified of HSBC acting as a distribution agent or primary dealer for Israel Bonds.

No public evidence identified for corporate sponsorship of British Israel Communications (BICOM), Conservative Friends of Israel (CFI), or Labour Friends of Israel (LFI) events.

Lobbying, Advocacy, Financing & Logistics

HSBC’s political lobbying disclosures indicate no direct political donations to UK political parties. Lobbying activities focus on financial regulation (Basel III, ring-fencing), sanctions compliance, and tax policy. No Israel-Palestine-specific lobbying was confirmed in UK or US Lobbying Disclosure Act (LDA) filings¹.

In July 2025, the UK National Contact Point (UK NCP) accepted a complaint against HSBC lodged by a group of NGOs regarding US private prison investments (CoreCivic and GEO Group). This complaint is NOT related to Israel-Palestine¹⁰¹¹.

Regarding defense holdings, HSBC holds shares in defense firms that supply weapons to Israel, including BAE Systems, Boeing, and Caterpillar. War on Want documented “millions of pounds” in these holdings¹²¹³.

On Elbit Systems, HSBC held 16,317 shares in Elbit Systems valued at approximately $8.3 million as of September 2025. Full divestment was confirmed by April/May 2026, with the holding reduced to zero shares¹⁴.

HSBC deploys NICE Actimize (an Israeli anti-money laundering platform) group-wide since approximately 2019 and CyberArk (privileged access management with R&D in Be’er Sheva, Israel). Neither relationship was modified following the ICJ Advisory Opinion or ICC arrest warrants¹³.

Regarding crisis asset mobilization, no confirmed instances were identified of HSBC directing free services to Israeli military or state-aligned NGOs during the conflict. HSBC did mobilize employee matched-giving for Ukraine (2022) and Turkey/Syria earthquake (2023), but no equivalent Gaza-specific programme was confirmed¹.

No public evidence identified for direct financing of Israeli military logistics, arms shipments, or defense-related supply chains beyond equity holdings.

Corporate Structure & Primary Mission

HSBC Holdings plc is incorporated in England and Wales and is publicly listed on the London Stock Exchange (LSE), Hong Kong Stock Exchange (HKEX), and New York Stock Exchange (NYSE)¹.

No single shareholder holds 10% or more of HSBC as of 2024. Ping An reduced its shareholding below the 5% threshold by Q3-Q4 2023. Ownership is highly dispersed¹.

HSBC Bank Middle East Limited operates across the UAE, Saudi Arabia, Bahrain, Kuwait, Oman, Qatar, and Egypt — but not in Israel or the Occupied Palestinian Territories¹⁵.

HSBC’s stated corporate purpose is “Opening up a world of opportunity,” reflecting standard commercial banking objectives. No geopolitical state mission is embedded in the corporate charter¹.

HSBC’s Modern Slavery and Human Rights Statement and Responsible Investment reports do not address Israel-Palestine specifically or reference the Occupied Palestinian Territories as a human rights risk geography¹.

Executive & Leadership Footprint

Noel Quinn served as Group CEO from 2019 until September 2024. No confirmed personal donations to the Israel Defense Forces (IDF) Fund, Jewish National Fund (JNF), or settlement-linked organizations were identified. No family foundation grants to Israeli advocacy groups were documented¹.

Georges Elhedery became Group CEO from September 2024. He was born in Beirut and holds Lebanese-French nationality. No confirmed personal donations to Israeli organizations or public statements on the conflict were identified. No family foundation was documented¹.

Mark Tucker served as Group Chairman from 2017 until May 2024. No confirmed personal philanthropy to Israeli advocacy organizations was identified¹⁶.

No confirmed board member personal memberships in the American Israel Public Affairs Committee (AIPAC), Conservative Friends of Israel (CFI), British Israel Communications (BICOM), Anti-Defamation League (ADL), or equivalent pro-Israel organizations were identified among HSBC board members¹⁶.

No confirmed public statements, op-eds, or social media posts by HSBC executives specifically supporting Israeli military operations or Palestinian rights (October 2023-2025) were identified¹.

No public evidence identified for executive-level personal philanthropy to Israeli advocacy organizations.

End Notes