V-ECON Audit — NatWest Group plc

Audit Phase: V-ECON (Economic Forensics) Date: 2026-05-01 Subject: NatWest Group plc (LSE: NWG; NYSE: NWG) Registered Number: SC289689 (Scotland)

Supply Chain & Sourcing Relationships

NatWest Group plc is a UK-domiciled retail and commercial banking group. It is not a food retailer, agricultural importer, fresh produce distributor, or consumer goods company. The canonical supply chain audit categories for V-ECON — including agricultural aggregators, Medjool date exporters, avocado and citrus importers, fresh herb and potato supply chains, and importer-of-record structures for fresh produce — are structurally inapplicable to NatWest’s business model. This finding is consistent with NatWest’s published corporate filings and responsible procurement disclosures.¹²³

• Direct supplier relationships with Israeli agricultural exporters (e.g. Mehadrin, Hadiklaim, Galilee Export, Agrexco or successors): No public evidence identified. No commercial relationship between NatWest and any Israeli agricultural exporter is documented in any corporate filing, NGO report, trade press record, or news source available to this audit.¹²³

• Importer-of-record structure: No public evidence identified. NatWest operates no subsidiary, joint venture, or dedicated entity functioning as an importer of record for any physical goods.¹⁴

• Seasonal sourcing patterns (counter-seasonal fresh produce procurement windows): No public evidence identified. The concept of seasonal agricultural procurement windows is inapplicable to a banking institution.¹

• Third-party and indirect sourcing of agricultural or food goods: No public evidence identified. NatWest’s disclosed procurement activities relate to IT infrastructure, professional services, facilities management, and financial services inputs. The Supplier Code of Conduct and Responsible Procurement Policy published by NatWest addresses supplier conduct standards across these categories, with no reference to food or agricultural supply chains.³

Product Origin, Labeling & Regulatory Compliance

NatWest does not stock, retail, distribute, import, or label food products or consumer goods of any geographic origin. UK country-of-origin food labeling regulations administered by the Food Standards Agency and DEFRA apply to food business operators and are structurally inapplicable to NatWest. No enforcement action, DEFRA advisory, FSA citation, or Trading Standards referral involving NatWest in connection with produce labeling is known from any available source.

• Settlement-origin product exposure: No public evidence identified. No NGO investigation — including by Corporate Occupation, Who Profits Research Centre, Amnesty International, or equivalent civil society bodies — has published findings implicating NatWest in the sourcing or sale of goods originating in Israeli settlements in the occupied territories.²

• Labeling compliance obligations: Not applicable. NatWest falls outside the class of entities subject to origin-labeling requirements for food or agricultural goods.¹

• Corporate policy on settlement-origin sourcing: No public evidence identified. NatWest has no publicly stated policy specifically addressing the sourcing or labeling of goods from occupied or contested territories. The absence of such a policy is consistent with the absence of any operational activity in those product categories, rather than constituting an affirmative gap. NatWest’s Responsible Business Report 2023 and Supplier Code of Conduct contain no provisions in this area.²³

• Regulatory exposure (UK sanctions, import controls, or trade measures relating to Israel/OPT): No public evidence identified of any regulatory citation, sanction, import control measure, or compliance proceeding involving NatWest in connection with goods of Israeli or settlement origin.¹²

Investment, Capital & Financial Exposure

• Foreign direct investment in Israel or the occupied territories: No public evidence identified. NatWest’s geographic footprint is concentrated overwhelmingly in the United Kingdom, with legacy retail and commercial banking operations in the Republic of Ireland and limited international wholesale banking activities. NatWest has not publicly announced or disclosed any direct capital investment — including acquisitions, physical facilities, data centres, logistics hubs, or real estate — within Israel or the occupied territories.¹⁵

• R&D, technology, and innovation centres in Israel: No public evidence identified. NatWest has not publicly announced any R&D facility, technology partnership, innovation laboratory, or accelerator programme within Israel. NatWest’s Annual Reports 2022 and 2023 make no reference to Israeli technology investment or partnership arrangements.¹⁵²

• Parent and beneficial ownership flows: NatWest Group plc is the ultimate parent entity, incorporated in Scotland and listed on the London Stock Exchange and New York Stock Exchange.⁴ Following a sustained multi-year divestment programme, the UK Government (acting through HM Treasury and UK Government Investments) completed its full exit from NatWest in or around March 2025, reducing its shareholding to 0% via a combination of retail share offers and institutional sell-downs.⁶⁷⁸ Prior to full exit, the UK Government held approximately 11.4% as of early 2024, down from a post-bailout peak of approximately 84% in 2009.⁶⁸ No Israeli state entity, Israeli sovereign wealth vehicle, or Israel-domiciled corporate entity is identified in NatWest’s major shareholder disclosures. The largest disclosed institutional shareholders are major global asset managers — including BlackRock, Vanguard, and Legal & General — none of which are Israeli-domiciled.⁹

• Portfolio and fund exposure (Israeli equities, Israeli sovereign bonds, Israel-focused funds): NatWest’s principal asset management activities are conducted through NatWest Cushon (workplace pensions, acquired 2023) and legacy wealth management through Coutts & Co. No publicly disclosed holdings specifically in Israeli-domiciled equities, Israeli government bonds, or Israel-focused investment funds are documented in NatWest’s Pillar 3 disclosures, ESG Appendix, or Responsible Business Report.¹⁰¹¹² Evidence gap: NatWest Cushon and Coutts may hold Israeli-market securities as de minimis components of diversified global index mandates; such holdings are not individually disclosed and cannot be confirmed or denied from available public records alone. No evidence of targeted or material Israeli-market portfolio holdings is identified.

• NatWest Markets (wholesale and investment banking) — Israeli issuer mandates: NatWest Markets plc, the Group’s wholesale banking subsidiary, may in principle have participated as bookrunner, arranger, or secondary market maker in Israeli sovereign or corporate debt and equity transactions. No specific transaction records involving Israeli issuers are identified in records available to this audit. This gap cannot be fully resolved from publicly available disclosures.¹¹²

• Climate and transition finance: NatWest’s Climate Transition Plan 2024 and ESG Appendix 2023 focus on UK domestic decarbonisation lending and energy transition finance. No Israeli-market climate finance or green bond issuance for Israeli entities is referenced in these documents.¹³¹¹

Operational Presence & Market Activity

• Physical footprint in Israel or the occupied territories: No public evidence identified. NatWest does not operate retail branches, commercial banking offices, private banking centres, support or processing centres, warehouses, or any other disclosed operational facility within Israel or the occupied territories. NatWest’s Annual Reports 2022 and 2023 define the Group’s operational geography as UK-primary, with residual Republic of Ireland and limited international wholesale operations.¹⁵

• Employment and tax contribution in Israel: No public evidence identified. NatWest’s disclosed total headcount of approximately 59,000–62,000 employees as of 2023 is allocated across UK domestic operations with small legacy international teams. No Israeli workforce registration, employment disclosure, employer tax registration, or social security contribution within the Israeli jurisdiction is documented in any available filing.¹

• Market positioning and revenue geography: No public evidence identified that NatWest characterises Israel as a target market — whether a growth market, minor export destination, or strategic geography. Israel does not appear as a named geography in NatWest’s segmental revenue disclosures, geographic asset allocations, or strategic priority statements in the 2022 or 2023 Annual Reports.¹⁵

• Correspondent banking relationships with Israeli commercial banks: NatWest, as a major UK clearing bank, may in principle maintain correspondent banking relationships with Israeli commercial banks (e.g. Bank Hapoalim, Bank Leumi, Mizrahi Tefahot) for the processing of international payments on behalf of UK customers. The existence, scope, and materiality of any such relationships are not publicly disclosed. No correspondent banking counterparty list is published in NatWest’s Pillar 3 disclosures or Annual Reports. This represents a genuine and unresolved evidence gap.¹⁰¹

• Trade finance for Israeli import/export activity: NatWest’s commercial banking division may provide standard trade finance instruments (letters of credit, documentary collections, guarantees) to UK companies trading with Israeli counterparties. This activity would not be separately disclosed and cannot be confirmed or denied from available public records.¹⁵

Corporate Structure & Foundational Ties

• Founding and incorporation history: NatWest Group plc was formed through the evolution and merger of the Royal Bank of Scotland (founded Edinburgh, 1727) and National Westminster Bank (formed 1968 via the merger of National Provincial Bank and Westminster Bank). The Group adopted its current name, NatWest Group plc, in July 2020 following a rebrand from The Royal Bank of Scotland Group plc.¹⁴ The company has no Israeli founding, no Israeli-origin acquisition constituting its core identity, and no legacy Israeli brand, operation, or subsidiary of material significance.⁴¹⁴

• Headquarters and domicile: NatWest Group plc is incorporated in Scotland under Companies House number SC289689, headquartered at 36 St Andrew Square, Edinburgh EH2 2YB, with principal operational offices in London.⁴ No dual or secondary Israeli headquarters or registered office exists.

• UK state linkage — principal structural relationship: NatWest’s defining institutional relationship is with the UK Government. Following the collapse of RBS during the 2008–2009 financial crisis, the UK state acquired a majority ownership stake of approximately 84%, making NatWest effectively a state-supported institution for over a decade.⁶⁸ The government’s shareholding was progressively reduced from 2015 onward through institutional block sales and, later, retail share offers, concluding with full divestment to 0% in approximately March 2025.⁶⁷⁸⁹ NatWest is designated a systemically important financial institution (SIFI) under UK prudential regulation and is subject to oversight by the Bank of England’s Prudential Regulation Authority as critical national financial infrastructure. No equivalent Israeli state ownership stake, Israeli government board appointee, Israeli government contract, or Israeli critical infrastructure designation is identified in any available source.⁶⁹

• Governance mechanisms and foundational ties to foreign states: No public evidence identified of golden shares, founder shares, charter restrictions, or any governance mechanism tying NatWest’s operations or strategic mission to the Israeli state or its policy objectives. NatWest’s Articles of Association, publicly filed at Companies House, contain no such provisions known to this audit.⁴

• NGO and civil society investigations: The Who Profits Research Centre and the Corporate Occupation project maintain databases of companies with economic ties to the Israeli economy or Israeli settlements. Neither organisation is confirmed to have published a specific NatWest entry in records available to this audit. This represents an unresolved evidence gap that should be resolved by checking live NGO databases before any downstream reliance on this section.²

Profit Repatriation & Economic Contribution

• Revenue attribution — Israel as a named market: No public evidence identified. NatWest’s segmental revenue disclosures across its three reporting segments (Retail Banking, Private Banking, and Commercial & Institutional) do not include Israel as a named revenue geography. Israel does not appear in geographic breakdowns of net interest income, non-interest income, or total assets in the 2022 or 2023 Annual Reports.¹⁵

• Profit flows and repatriation to Israeli-domiciled beneficiaries: NatWest’s profit generation is substantially UK-domestic. Profits are distributed outward from UK operations to shareholders domiciled globally, principally UK institutional investors, US-domiciled index funds, and retail shareholders following the completion of UK Government divestment. No evidence of profit repatriation flows directed toward Israel or of Israeli-domiciled beneficial owners receiving material distributions is identified in major shareholder disclosures or corporate filings.¹⁹

• Economic ecosystem role within Israel: No public evidence identified. No publicly available economic assessment, industry report, Israeli government designation, sectoral analysis, or civil society publication characterises NatWest as a significant employer, anchor institution, infrastructure provider, or material economic actor within the Israeli economy or any specific sector thereof.¹²

• Dividend and capital return flows: NatWest’s dividend distributions and share buyback programmes are disclosed in its Annual Reports and London Stock Exchange RNS filings. These disclosures do not identify any Israeli-domiciled entity among the material beneficiaries of such capital returns, consistent with the absence of Israeli-domiciled entities among disclosed major shareholders.¹¹²⁹

• NatWest Group Pension Fund — potential Israeli-market asset exposure: NatWest operates a large legacy defined benefit pension scheme. The asset allocation of the NatWest Group Pension Fund is not disclosed at a country or individual security level in publicly available scheme reports sufficient to identify Israeli-market holdings. This constitutes a genuine and unresolved evidence gap; however, no affirmative evidence of Israeli-market exposure is identified.

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