HUMAN RIGHTS WATCH 350 Fifth Avenue, 34th Floor New York, NY 10118- March 12, 2018 3299 Tel: 212-290- Mr. Ezra Arusi, CEO 4700 Fax:MIDDLE EAST212-736 AND- Mishab Construction and Development Company, Ltd D1300 I V I S I O N XXXXXXXXXXXXX Sarah Leah Whitson, Executive Director XXXXXXXXXXXXX Lama Fakih, Deputy Director Eric Goldstein, Deputy Via fax: XXXXXXXXXXXXX Director Ahmed Benchemsi, Advocacy and Communications Director Dear Mr. Arusi,

A D V I S O R Y is preparing a publication analyzing the activities of Israeli COMMITTEE Asli Bali, Co-Chair banks in Israeli settlements in the West Bank in the context of their human rights and Kathleen Peratis, Co-Chair Bruce Rabb, Vice-Chair international humanitarian law responsibilities such as those detailed in the United Gary G. Sick, Vice-Chair Nations Guiding Principles on Business and Human Rights. In that context we are Fouad Abdelmoumni Gamal M. Abouali also examining projects undertaken by Israeli construction companies in settlements. Yasser Akkaoui Hala Al-Dossari In the interests of thorough and objective reporting, we are writing to request Salah Al Hejailan Abdul-Ghani Al-Iryani information on these issues, to share your understanding of the legal framework Ahmed Al-Mukhaini Ghanim Al-Najjar guiding those activities, and to offer any other perspectives you may have. Due to our Lisa Anderson Shaul Bakhash publications schedule, we request a response by April 2. David Bernstein Robert L. Bernstein Nathan Brown Paul Chevigny Human Rights Watch is an independent, nongovernmental organization that monitors Hanaa Edwar and reports on human rights in 90 countries around the world. Our and Bahey El Din Hassan Hassan Elmasry Palestine team researches and reports human rights violations by Israel, the Mansour Farhang Loubna Freih Georges Palestinian Authority, and Hamas. Aeyal Gross Amr Hamzawy Asos Hardi In January 2016, Human Rights Watch published a report, Occupation, Inc., Marina Pinto Kaufman Youssef Khlat analyzing business activities in Israeli settlements located in the occupied West Bank. Ahmed Mansoor Stephen P. Marks Our research indicates that by supporting, facilitating, and expanding settlements, Abdelaziz Nouaydi Nabeel Rajab business activity in Israeli settlements inherently contributes to and benefits from Vicki Riskin Charles Shamas serious violations of human rights and international humanitarian law. For these Sid Sheinberg reasons, we recommend that businesses cease settlement-related activities. Sussan Tahmasebi Mustapha Tlili Our current research is examining whether some banks are contributing to violations of Human Rights human rights and international humanitarian law, for example, by providing services that W a t c h , Executive help maintain and expand settlements, including financing construction projects. Director Michele Alexander, Deputy Executive Director, We are requesting further information about a project that your company is undertaking Development and Global initiatives with bank accompaniment as well as information about your policies: Nicholas Dawes, Deputy Executive Director, 1. Is Mishab familiar with the UN Guiding Principles on Business and Human Communications Iain Levine, Deputy Executive Rights? If so, what if any steps has it taken to implement them? Does the Director, Program Chuck Lustig, Deputy company have any other policies and procedures pertaining to human rights or Executive Director, Operations Walid Ayoub, Information international humanitarian law? Technology Director Emma Daly, Communications Director 2. Does Mishab have specific policies regarding its operations as they pertain to or Barbara Guglielmo, Finance and Administration Director in Israeli settlements? If so, can you please provide such policies and any other Babatunde Olugboji, Deputy Program Director related information? Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director James Ross, Legal and Policy DirectorAMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON··MOSCOW· NAIROBI · NEW YORK·PARIS · Joe Saunders, Deputy SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH Program Director Frances Sinha, Human BusinessResources Directores should support and respect the protection of internationally proclaimed human rights. 3. Has Mishab assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the company’s perspectives on its human rights impact in the settlements. 4. Our research indicates that Mishab is undertaking a project called “Mishkanot Elkana” in the settlement of Elkana. Residents of the Palestinian village of Mas- ha have told Human Rights Watch that “Mishkenot Elkana” is being built, at least partially, on land they own. Can you share your understanding of the status of the land on which the project is being constructed? What if any steps have you taken to investigate claims of ownership of the land on which you are building “Mishkenot Elkana” and ensure that the consent of the owners has been properly obtained? 5. Please provide any documents or agreements granting the development rights to Mishab or otherwise authorizing construction of the project in its current location. 6. Can you confirm that Mizrahi Tfahot is accompanying the Mishkenot Elkana project? Please send copies of any agreements signed with Mizrahi Tfahot relevant to the project. We would welcome any clarifications or more accurate information about your operations. Please send your written response by April 2, 2018, so that we can reflect it in our publication. Please send it by fax to XXXXXXXXXXXXX or e-mail to XXXXXXXXXXXXX. We also welcome a chance to meet with you to discuss this further and to address any questions or comments you might have.

I thank you in advance for your kind cooperation.

Sincerely yours,

Sarah Leah Whitson Executive Director

HUMAN RIGHTS WATCH 350 Fifth Avenue, 34th Floor New York, NY 10118- March 12, 2018 3299 Tel: 212-290- Haim Feiglin, CEO 4700 Fax:MIDDLE EAST212-736 AND- Zemach Hammerman Ltd NORTH AFRICA D1300 I V I S I O N XXXXXXXXXXXXX Sarah Leah Whitson, Executive Director XXXXXX Lama Fakih, Deputy Director Eric Goldstein, Deputy Via email to XXXXXXXXXXXXX and via fax to: XXXXXXXXXXXXX Director Ahmed Benchemsi, Advocacy Telephone: XXXXXXXXXXXXX and Communications Director

Dear Mr. Feiglin, A D V I S O R Y COMMITTEE Asli Bali, Co-Chair Human Rights Watch is preparing a publication analyzing the activities of Israeli Kathleen Peratis, Co-Chair Bruce Rabb, Vice-Chair banks in Israeli settlements in the West Bank in the context of their human rights and Gary G. Sick, Vice-Chair Fouad Abdelmoumni international humanitarian law responsibilities such as those detailed in the United Gamal M. Abouali Nations Guiding Principles on Business and Human Rights. In that context we are Yasser Akkaoui Hala Al-Dossari also examining projects undertaken by Israeli construction companies in settlements. Salah Al Hejailan Abdul-Ghani Al-Iryani In the interests of thorough and objective reporting, we are writing to request Ahmed Al-Mukhaini Ghanim Al-Najjar information on these issues and to offer any other perspectives you may have. Due to Lisa Anderson Shaul Bakhash our publications schedule, we request a response by April 2. David Bernstein Robert L. Bernstein Nathan Brown Paul Chevigny Human Rights Watch is an independent, nongovernmental organization that monitors Hanaa Edwar Bahey El Din Hassan and reports on human rights in 90 countries around the world. Our Israel and Hassan Elmasry Palestine team researches and reports human rights violations by Israel, the Mansour Farhang Loubna Freih Georges Palestinian Authority, and Hamas. Aeyal Gross Amr Hamzawy Asos Hardi Shawan Jabarin In January 2016, Human Rights Watch published a report, Occupation, Inc., Marina Pinto Kaufman Youssef Khlat analyzing business activities in Israeli settlements located in the occupied West Bank. Ahmed Mansoor Stephen P. Marks Our research indicates that by supporting, facilitating, and expanding settlements, Abdelaziz Nouaydi Nabeel Rajab business activity in Israeli settlements inherently contributes to and benefits from Vicki Riskin Charles Shamas serious violations of human rights and international humanitarian law. For these Sid Sheinberg Sussan Tahmasebi reasons, we recommend that businesses cease settlement-related activities. Mustapha Tlili Our current research is examining whether some banks are contributing to violations of Human Rights human rights and international humanitarian law, for example, by providing services that W a t c h Kenneth Roth, Executive help maintain and expand settlements, including financing construction projects. Director Michele Alexander, Deputy Executive Director, We are requesting further information about a project that your company is undertaking Development and Global initiatives with bank accompaniment as well as information about your policies: Nicholas Dawes, Deputy Executive Director, Communications 1. Is Zemach Hammerman familiar with the UN Guiding Principles on Business and Iain Levine, Deputy Executive Human Rights? If so, what if any steps has it taken to implement them? Does the Director, Program Chuck Lustig, Deputy company have any other policies and procedures pertaining to human rights or Executive Director, Operations Walid Ayoub, Information international humanitarian law? Technology Director Emma Daly, Communications Director Barbara Guglielmo, Finance and Administration Director Babatunde Olugboji, Deputy Program Director Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director James Ross, Legal and Policy DirectorAMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · Joe Saunders, Deputy SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH Program Director Frances Sinha, Human BusinessResources Directores should support and respect the protection of internationally proclaimed human rights. 2. Does Zemach Hammerman have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide copies of such policies and any other related information? 3. Has Zemach Hammerman assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the company’s perspectives on the human rights impact of its activities in the settlements. 4. Research indicates that Zemach Hammerman is undertaking a project called “Amirei Nof” in the settlement of Alfei Menashe. Maps provided by the Israeli Civil Administration indicate that the land on which “Amirei Nof” is being built was declared to be “state land” by the Israeli authorities in 1980. However, according to those maps, it appears that for about half the land on which the project is being built – mostly Block 39, Parcel 10, on the eastern side of the project – the Israeli authorities, via the “Blue Line Team”, removed the designation of “state land” in 2014. These changes in designation elevate concerns that the land is privately owned. Can you share your understanding of the status of the land on which the project is being constructed? 5. Aerial photos of the site where Amirei Nof is being built indicate that, at least on the eastern side of the project, where the designation of state land was removed, construction began in or after 2016. Can you provide a time-table of when construction of the project began, including specifying when Zemach Hammerman began to build on the area where the state land designation was removed? 6. Please provide any documents or agreements granting the development rights to Zemach Hammerman or otherwise authorizing construction of the project in its current location. 7. Can you confirm that Bank Leumi is accompanying the Amirei Nof project? Please provide copies of any agreements signed with the bank relevant to the project. 8. As you know, there are often competing claims of ownership of land in the West Bank. What if any steps have you taken to investigate claims of ownership of the land on which you are building “Amirei Nof” and ensure that the consent of the owners has been properly obtained? We welcome any clarifications or more accurate information about your operations. Please send your written response by April 2, 2018, so that we can reflect it in our publication. Please send it by fax to XXXXXXXXXXXXX or e-mail to XXXXXXXXXXXXX. We also welcome a chance to meet with you to discuss this further and to address any questions or comments you might have.

I thank you in advance for your kind cooperation.

Sincerely yours,

Sarah Leah Whitson Executive Director HUMAN RIGHTS WATCH 350 Fifth Avenue, 34th Floor New York, NY 10118- March 12, 2018 3299 Tel: 212-290- CEO 4700 Fax:MIDDLE EAST212-736 AND- Shoham Construction and Real Estate, Ltd. NORTH AFRICA D1300 I V I S I O N Via e-mail: XXXXXXXXXXXXX Sarah Leah Whitson, Executive Director Lama Fakih, Deputy Director Greetings, Eric Goldstein, Deputy Director Ahmed Benchemsi, Advocacy and Communications Director Human Rights Watch is preparing a publication analyzing the activities of Israeli banks in Israeli settlements in the West Bank in the context of their human rights and

A D V I S O R Y international humanitarian law responsibilities such as those detailed in the United COMMITTEE Nations Guiding Principles on Business and Human Rights. In that context we are Asli Bali, Co-Chair Kathleen Peratis, Co-Chair also examining projects undertaken by Israeli construction companies in settlements. Bruce Rabb, Vice-Chair Gary G. Sick, Vice-Chair In the interests of thorough and objective reporting, we are writing to request Fouad Abdelmoumni Gamal M. Abouali information on these issues and to offer any other perspectives you may have. Due to Yasser Akkaoui Hala Al-Dossari our publications schedule, we request a response by April 2. Salah Al Hejailan Abdul-Ghani Al-Iryani Ahmed Al-Mukhaini Ghanim Al-Najjar Human Rights Watch is an independent, nongovernmental organization that monitors Lisa Anderson Shaul Bakhash and reports on human rights in 90 countries around the world. Our Israel and David Bernstein Palestine team researches and reports human rights violations by Israel, the Robert L. Bernstein Nathan Brown Palestinian Authority, and Hamas. Paul Chevigny Hanaa Edwar Bahey El Din Hassan Hassan Elmasry In January 2016, Human Rights Watch published a report, Occupation, Inc., Mansour Farhang Loubna Freih Georges analyzing business activities in Israeli settlements located in the occupied West Bank. Aeyal Gross Amr Hamzawy Our research indicates that by supporting, facilitating, and expanding settlements, Asos Hardi Shawan Jabarin business activity in Israeli settlements inherently contributes to and benefits from Marina Pinto Kaufman Youssef Khlat serious violations of human rights and international humanitarian law. For these Ahmed Mansoor Stephen P. Marks reasons, we recommend that businesses cease settlement-related activities. Abdelaziz Nouaydi Nabeel Rajab Vicki Riskin Our current research is examining whether some banks are contributing to violations Charles Shamas Sid Sheinberg of human rights and international humanitarian law, for example, by providing Sussan Tahmasebi Mustapha Tlili services that help maintain and expand settlements, including financing construction projects. Human Rights W a t c h We are requesting further information about a project that your company is undertaking Kenneth Roth, Executive Director with bank accompaniment as well as information about your policies: Michele Alexander, Deputy Executive Director, Development and Global 1. Is Shoham familiar with the UN Guiding Principles on Business and Human initiatives Rights? If so, what if any steps has it taken to implement them? Does the Nicholas Dawes, Deputy Executive Director, company have any other policies and procedures pertaining to human rights or Communications Iain Levine, Deputy Executive international humanitarian law? Director, Program Chuck Lustig, Deputy Executive Director, Operations 2. Does Shoham have specific policies regarding its operations as they pertain to or Walid Ayoub, Information Technology Director in Israeli settlements? If so, can you please provide such policies and any other Emma Daly, Communications Director related information? Barbara Guglielmo, Finance and Administration Director Babatunde Olugboji, Deputy Program Director Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director James Ross, Legal and Policy DirectorAMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · Joe Saunders, Deputy SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH Program Director Frances Sinha, Human ResourcesBusiness Directores should support and respect the protection of internationally proclaimed human rights. 3. Has Shoham assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the company’s perspectives on its human rights impact in the settlements. 4. We understand that Shoham is undertaking a project called “Ahdut Elkana” in the settlement of Elkana. Residents of the Palestinian village of Mas-ha have told Human Rights Watch that “Ahdut Elkana” is being built, at least partially, on land they own. Can you share your understanding of the status of the land on which the project is being constructed? What if any steps have you taken to investigate claims of ownership of the land on which you are building “Ahdut Elkana” and ensure that the consent of the owners has been properly obtained? 5. Please provide any documents or agreements granting the development rights to Shoham or otherwise authorizing construction of the project in its current location. 6. Can you confirm that Mizrahi Tfahot is accompanying the Ahdut Elkana project? Please send copies of any agreements signed with Mizrahi Tfahot relevant to the project. We would welcome any clarifications or more accurate information about your operations. Please send your written response by April 2, 2018, so that we can reflect it in our publication. Please send it by fax to XXXXXXXXXXXXX or e-mail to XXXXXXXXXXXXX. We also welcome a chance to meet with you to discuss this further and to address any questions or comments you might have.

I thank you in advance for your kind cooperation.

Sincerely yours,

Sarah Leah Whitson Executive Director