Banking Activities in West Bank Settlements Bruce Rabb, Vice-Chair Gary G

Home , Beitar Illit, Union Bank of Israel

HUMAN RIGHTS WATCH 350 Fifth Avenue, 34th Floor New York, NY 10118-3299 Tel: 212-290-4700 Fax: 212-736-1300 February 5, 2018

To:

MIDDLE EAST AND NORTH AFRICA DIVISION Sarah Leah Whitson, Executive Director Bank Hapoalim Spokesperson Lama Fakih, Deputy Director Eric Goldstein, Deputy Director c/o Shalom Tel Aviv Joe Stork, Deputy Director Ahmed Benchemsi, Advocacy and Via E-mail: XXXXXXXXXXXXX Communications Director

Greetings, ADVISORY COMMITTEE Asli Bali, Co-Chair Kathleen Peratis, Co-Chair Re: Banking Activities in West Bank Settlements Bruce Rabb, Vice-Chair Gary G. Sick, Vice-Chair Fouad Abdelmoumni Gamal M. Abouali Human Rights Watch is preparing a publication analyzing the activities of Yasser Akkaoui Hala Al-Dossari Israeli banks in Israeli settlements in the West Bank in the context of their Salah Al Hejailan Abdul-Ghani Al-Iryani human rights and humanitarian law responsibilities such as those Ahmed Al-Mukhaini Ghanim Al-Najjar detailed in the United Nations Guiding Principles on Business and Human Lisa Anderson Shaul Bakhash Rights. In the interests of thorough and objective reporting, we are writing David Bernstein Robert L. Bernstein to request information on these issues, to share your understanding of Nathan Brown Paul Chevigny the legal framework guiding those activities, and to offer any other Hanaa Edwar Bahey El Din Hassan perspectives you may have. Due to our publications schedule, we request Hassan Elmasry Mansour Farhang a response by February 25. Loubna Freih Georges Aeyal Gross Amr Hamzawy Asos Hardi Human Rights Watch is an independent, nongovernmental organization Shawan Jabarin Marina Pinto Kaufman that monitors and reports on human rights in 90 countries around the Youssef Khlat Ahmed Mansoor world. Our Israel and Palestine team researches and reports human rights Stephen P. Marks Abdelaziz Nouaydi violations by Israel, the Palestinian Authority, and Hamas. Nabeel Rajab Vicki Riskin Charles Shamas Sid Sheinberg In January 2016, Human Rights Watch published a report, Occupation, Inc., Sussan Tahmasebi Mustapha Tlili analyzing business activities in Israeli settlements located in the occupied West Bank. Our research indicates that by supporting, Human Rights Watch facilitating, and expanding settlements, business activity in Israeli Kenneth Roth, Executive Director Michele Alexander, Deputy Executive settlements inherently contributes to and benefits from serious violations Director, Development and Global initiatives Nicholas Dawes, Deputy Executive Director, of human rights and international humanitarian law. For these reasons, Communications Iain Levine, Deputy Executive Director, we recommend that businesses cease settlement-related activities. Program Chuck Lustig, Deputy Executive Director, Operations Walid Ayoub, Information Technology Our current research is examining whether some banks are contributing to Director Emma Daly, Communications Director violations of human rights and international humanitarian law, for Barbara Guglielmo, Finance and Administration Director example, by providing services that help maintain and expand Babatunde Olugboji, Deputy Program Director settlements, including financing construction projects, providing Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director mortgages for settlement homes, operating bank branches within James Ross, Legal and Policy Director Joe Saunders, Deputy Program Director settlements, and providing loans and financial services to settlement Frances Sinha, Human Resources Director municipalities.

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Businesses should support and respect the protection of internationally proclaimed human rights. We are requesting further information about your bank in order to get a better understanding of its operations in relation to the West Bank: 1. Is Bank Hapoalim familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? 2. We understand that Bank Hapoalim’s 2016 Corporate Social Responsibility Report pledges to promote the principles of the UN Global Compact, including respect for internationally recognized human rights. Does Bank Hapoalim have additional written policies or guidelines regarding human rights and international humanitarian law compliance? If so, can you please provide copies of such policies. 3. Does Bank Hapoalim have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information? 4. Has Bank Hapoalim assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A report published a year ago by the nonprofit organization Who Profits cites a number of projects in which Bank Hapoalim is involved in Israeli settlements in the West Bank. Can you confirm the bank’s involvement in the following projects and provide further details about these transactions?

Providing a loan of ILS 49.5 million to the Mateh Binyamin Local Council in January 2015;

Providing a loan of USD 1.5 million to the Megilot Dead Sea Local Council in July 2014;

Providing a loan of ILS 2 million to the Megilot Dead Sea Local Council in June 2016;

Accompanying an infrastructure and road project carried out by the Adi Hadar construction company, Geva C and Area D, in Beitar Illit, subject to agreement from June 2015;

Accompanying construction projects carried out by Bonayich Construction Development and Investment, in Hill B and Hill C in Beitar Illit;

Accompanying a construction project carried out by Hasid Brothers in Hill A in Beitar Illit;

Accompanying a construction project carried out by Bonayich Construction Development and Investment in Givat HaDagan in Efrat; Accompanying construction projects carried out by ZIP Construction and Renovation in Givat HaTamar, Givat HaZayit East and Givat HaDagan in Efrat;

Accompanying a construction project, “Nofey Adumim” in Ma’ale Adumim, carried out by the Ofer Aharon company (completed December 2016). 6. In addition, Human Rights Watch’s research indicates involvement by Bank Hapoalim in additional projects in settlements. Can you confirm the bank’s involvement in the following projects and provide further details? a. Accompanying a 50-unit housing project, “Ganei Tamar”, in Efrat, carried out by the Aluel construction company; b. Accompanying a 24-unit housing project, “Efrat HaPtuha”, in Efrat, carried out by the Mishkan Eliyahu company; c. Accompanying a 40-unit housing project, “Mishkenot Traklin”, in Beitar Illit, carried out by Traklin Development and Construction. Please provide further information about the overall scope of Bank Hapoalim’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value. Specifically, we seek information on the scope of mortgages provided by the banks for homes purchased in the settlements and the overall funding the bank provides for construction projects.

Sincerely yours,

Sari Bashi Israel and Palestine Advocacy Director Middle East and North Africa Human Rights Watch Telephone: XXXXXXXXXXXXX E-mail: XXXXXXXXXXXXX HUMAN RIGHTS WATCH 350 Fifth Avenue, 34th Floor New York, NY 10118-3299 Tel: 212-290-4700 Fax: 212-736-1300 February 5, 2018

To:

MIDDLE EAST AND NORTH AFRICA DIVISION Sarah Leah Whitson, Executive Director Mr. Benny Shoukron Lama Fakih, Deputy Director Eric Goldstein, Deputy Director Mizrahi-Tefahot Bank Spokesperson Joe Stork, Deputy Director Ahmed Benchemsi, Advocacy and Via E-mail: XXXXXXXXXXXXX Communications Director

AMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH

Businesses should support and respect the protection of internationally proclaimed human rights. We are requesting further information about your bank in order to get a better understanding of its operations in relation to the West Bank: 1. Is Mizrahi-Tefahot Bank familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? 2. We understand that Mizrahi-Tefahot Bank’s 2016 Corporate Social Responsibility Report pledges to promote the principles of the UN Global Compact, including respect for internationally recognized human rights. Does Mizrahi-Tefahot Bank have additional written policies or guidelines regarding human rights and international humanitarian law compliance? If so, can you please provide copies of such policies. 3. Does Mizrahi-Tefahot Bank have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information? 4. Has Mizrahi-Tefahot Bank assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A recent report by the nonprofit organization Who Profits cites a number of projects in which Mizrahi-Tefahot Bank is involved in Israeli settlements in the West Bank. Can you confirm the bank’s involvement in the following projects and provide further details about these transactions?

Providing a loan to the Har Hevron Local Council, the total sum of which was raised to ILS 4.9 million in June 2015;

Providing a loan of ILS 1.5 million to the Alefi Menashe Local Council around June 2014;

Providing guarantees of ILS 250,000 to the Kedumim Local Council in November 2012;

Accompanying a construction project carried out by the Haim Zaken construction company, “Mitzpeh Yael”, in Hill B, western Beitar Illit, completed in 2016;

Accompanying a 60-unit housing project in southwestern Ariel, carried out by Malibu Construction;

Accompanying a construction project, “Euro by the Park”, in southern Ariel, carried out by Euro-Israel and completed in 2016;

Accompanying phases A and B of a construction project, “Green Ariel”, carried out by Kaham Investments and completed in 2016; Accompanying a construction project, “Ma’aleh Hadar”, in central Ma’ale Adumim, carried out by the Mizpor Adumim construction company subject to an agreement from 2012. Project completed in 2016. 6. In addition, Human Rights Watch’s research indicates involvement by Mizrahi-Tefahot Bank in additional projects in settlements. Can you confirm the bank’s involvement in the following projects and provide further details? a. Accompanying a 106-unit housing project, “Mishkenot Elkana”, in northern Elkana, carried out by the Mishab construction company; b. Accompanying a 145-unit housing project, “Ahdut Elkana”, in northern Elkana, carried out by the Shoam construction company; c. Accompanying a 43-unit housing project, “Bustan HaDagan”, in Efrat, carried out by Yaakov Kening LTD construction company; d. Accompanying a 98-unit housing project, “Nofey Kramim”, in Kiryat Arba, carried out by ZF Building and Development; e. Accompanying a 48-unit housing project in southwestern Ma’ale Adumim, carried out by the Kotler Adika construction company; f. Project approval (for mortgages) for a 120-unit construction project (phase 1) in Kedem, near Avne Hefetz, carried out by the Harey Zahav construction company; g. Project approval (for mortgages) for a construction project “Pisgat Dolev”, carried out by the Hemdat Shomron construction company h. Project approval (for mortgages) for a construction project “Kedma in Leshem, the New Street”, carried out by the Kedma construction company. 7. Please provide further information about the overall scope of Mizrahi-Tefahot Bank’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value. Specifically, we seek information on the scope of mortgages provided by the banks for homes purchased in the settlements and the overall funding the bank provides for construction projects.

We would welcome any clarifications or more accurate information about your operations. Please send your written response by February 25, 2018, so that we can reflect it in our publication. We thank you for any further comment or response you wish to provide us and any relevant information would be reflected in our publication. I thank you in advance for your kind cooperation.

Sincerely yours,

To:

MIDDLE EAST AND NORTH AFRICA DIVISION Sarah Leah Whitson, Executive Director Mr. Shoham Levy Lama Fakih, Deputy Director Eric Goldstein, Deputy Director Bank of Jerusalem Spokesperson Joe Stork, Deputy Director Ahmed Benchemsi, Advocacy and Via E-mail: XXXXXXXXXXXXX Communications Director

AMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH

Businesses should support and respect the protection of internationally proclaimed human rights. We are requesting further information about your bank in order to get a better understanding of its operations in relation to the West Bank: 1. Is the Bank of Jerusalem familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? 2. Does the Bank of Jerusalem have written policies or guidelines regarding human rights and international humanitarian law compliance? If so, can you please provide copies of such policies. 3. Does the Bank of Jerusalem have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information? 4. Has the Bank of Jerusalem assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A recent report by the nonprofit organization Who Profits notes that the Bank of Jerusalem is accompanying an 80-unit housing project in northwestern Beitar Illit, carried out by Traklin Development and Construction. Can you confirm the bank’s involvement in this project? 6. In addition, Human Rights Watch’s research indicates that the Bank of Jerusalem is accompanying a 28-unit housing project carried out by the Barkan construction company in Givat HaTamar in Efrat. Can you confirm the bank’s involvement in this project and provide further details? 7. Please provide further information about the overall scope of the Bank of Jerusalem’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value. Specifically, we seek information on the scope of mortgages provided by the banks for homes purchased in the settlements and the overall funding the bank provides for construction projects.

Sincerely yours,

To:

MIDDLE EAST AND NORTH AFRICA DIVISION Sarah Leah Whitson, Executive Director Ms. Dafna Zucker Lama Fakih, Deputy Director Eric Goldstein, Deputy Director Spokesperson Joe Stork, Deputy Director Ahmed Benchemsi, Advocacy and First International Bank of Israel Communications Director Via E-mail: XXXXXXXXXXXXX

ADVISORY COMMITTEE Dear Ms. Zucker, Asli Bali, Co-Chair Kathleen Peratis, Co-Chair Bruce Rabb, Vice-Chair Gary G. Sick, Vice-Chair Re: Banking Activities in West Bank Settlements Fouad Abdelmoumni Gamal M. Abouali Yasser Akkaoui Hala Al-Dossari Human Rights Watch is preparing a publication analyzing the activities of Salah Al Hejailan Abdul-Ghani Al-Iryani Israeli banks in Israeli settlements in the West Bank in the context of their Ahmed Al-Mukhaini Ghanim Al-Najjar human rights and humanitarian law responsibilities such as those Lisa Anderson Shaul Bakhash detailed in the United Nations Guiding Principles on Business and Human David Bernstein Robert L. Bernstein Rights. In the interests of thorough and objective reporting, we are writing Nathan Brown Paul Chevigny to request information on these issues, to share your understanding of Hanaa Edwar Bahey El Din Hassan the legal framework guiding those activities, and to offer any other Hassan Elmasry Mansour Farhang perspectives you may have. Due to our publications schedule, we request Loubna Freih Georges Aeyal Gross a response by February 25. Amr Hamzawy Asos Hardi Shawan Jabarin Marina Pinto Kaufman Human Rights Watch is an independent, nongovernmental organization Youssef Khlat Ahmed Mansoor that monitors and reports on human rights in 90 countries around the Stephen P. Marks Abdelaziz Nouaydi world. Our Israel and Palestine team researches and reports human rights Nabeel Rajab Vicki Riskin violations by Israel, the Palestinian Authority, and Hamas. Charles Shamas Sid Sheinberg Sussan Tahmasebi Mustapha Tlili In January 2016, Human Rights Watch published a report, Occupation, Inc., analyzing business activities in Israeli settlements located in the Human Rights Watch occupied West Bank. Our research indicates that by supporting, Kenneth Roth, Executive Director Michele Alexander, Deputy Executive facilitating, and expanding settlements, business activity in Israeli Director, Development and Global initiatives Nicholas Dawes, Deputy Executive Director, settlements inherently contributes to and benefits from serious violations Communications Iain Levine, Deputy Executive Director, of human rights and international humanitarian law. For these reasons, Program Chuck Lustig, Deputy Executive Director, we recommend that businesses cease settlement-related activities. Operations Walid Ayoub, Information Technology Director Emma Daly, Communications Director Our current research is examining whether some banks are contributing to Barbara Guglielmo, Finance and Administration Director violations of human rights and international humanitarian law, for Babatunde Olugboji, Deputy Program Director example, by providing services that help maintain and expand Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director settlements, including financing construction projects, providing James Ross, Legal and Policy Director Joe Saunders, Deputy Program Director mortgages for settlement homes, operating bank branches within Frances Sinha, Human Resources Director

AMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH

Businesses should support and respect the protection of internationally proclaimed human rights. settlements, and providing loans and financial services to settlement municipalities. We are requesting further information about your bank in order to get a better understanding of its operations in relation to the West Bank: 1. Is the First International Bank of Israel familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? 2. Does the First International Bank of Israel have written policies or guidelines regarding human rights and international humanitarian law compliance? If so, can you please provide copies of such policies. 3. Does the First International Bank of Israel have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information? 4. Has te First International Bank of Israel assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A recent report by the nonprofit organization Who Profits cites a number of projects in which the First International Bank of Israel is involved in Israeli settlements in the West Bank. Can you confirm the bank’s involvement in the following projects and provide further details about these transactions?

Through Bank Otsar Ha-hayal, providing a loan of ILS 670,000 to the Alfei Menashe Local Council, around September 2014;

Through Bank Otsar Ha-hayal, providing a guarantee of ILS 100,000 to the Kedumim Local Council around November 2012;

Accompanying a construction project, “Ginot Minrav”, on hill C in northern Beitar Illit (construction began in 2015). 6. Please provide further information about the overall scope of the First International Bank of Israel’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value. Specifically, we seek information on the scope of mortgages provided by the banks for homes purchased in the settlements and the overall funding the bank provides for construction projects.

Sincerely yours,

MIDDLE EAST AND NORTH Ms. Sarit Weiss AFRICA DIVISION Sarah Leah Whitson, Executive Director Spokesperson Lama Fakih, Deputy Director Eric Goldstein, Deputy Director Discount Bank Joe Stork, Deputy Director Ahmed Benchemsi, Advocacy and Via E-mail: XXXXXXXXXXXXX Communications Director

Dear Ms. Weiss, A DVISORY COMMITTEE Asli Bali, Co-Chair Kathleen Peratis, Co-Chair Re: Banking Activities in West Bank Settlements Bruce Rabb, Vice-Chair Gary G. Sick, Vice-Chair Fouad Abdelmoumni Gamal M. Abouali Human Rights Watch is preparing a publication analyzing the activities of Yasser Akkaoui Hala Al-Dossari Israeli banks in Israeli settlements in the West Bank in the context of their Salah Al Hejailan Abdul-Ghani Al-Iryani human rights and humanitarian law responsibilities such as those Ahmed Al-Mukhaini Ghanim Al-Najjar detailed in the United Nations Guiding Principles on Business and Human Lisa Anderson Shaul Bakhash Rights. In the interests of thorough and objective reporting, we are writing David Bernstein Robert L. Bernstein to request information on these issues, to share your understanding of Nathan Brown Paul Chevigny the legal framework guiding those activities, and to offer any other Hanaa Edwar Bahey El Din Hassan perspectives you may have. Due to our publications schedule, we request Hassan Elmasry Mansour Farhang a response by February 25. Loubna Freih Georges Aeyal Gross Amr Hamzawy Asos Hardi Human Rights Watch is an independent, nongovernmental organization Shawan Jabarin Marina Pinto Kaufman that monitors and reports on human rights in 90 countries around the Youssef Khlat Ahmed Mansoor world. Our Israel and Palestine team researches and reports human rights Stephen P. Marks Abdelaziz Nouaydi violations by Israel, the Palestinian Authority, and Hamas. Nabeel Rajab Vicki Riskin Charles Shamas Sid Sheinberg In January 2016, Human Rights Watch published a report, Occupation, Inc., Sussan Tahmasebi Mustapha Tlili analyzing business activities in Israeli settlements located in the occupied West Bank. Our research indicates that by supporting, Human Rights Watch facilitating, and expanding settlements, business activity in Israeli Kenneth Roth, Executive Director Michele Alexander, Deputy Executive settlements inherently contributes to and benefits from serious violations Director, Development and Global initiatives Nicholas Dawes, Deputy Executive Director, of human rights and international humanitarian law. For these reasons, Communications Iain Levine, Deputy Executive Director, we recommend that businesses cease settlement-related activities. Program Chuck Lustig, Deputy Executive Director, Operations Walid Ayoub, Information Technology Our current research is examining whether some banks are contributing to Director Emma Daly, Communications Director violations of human rights and international humanitarian law, for Barbara Guglielmo, Finance and Administration Director example, by providing services that help maintain and expand Babatunde Olugboji, Deputy Program Director settlements, including financing construction projects, providing Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director mortgages for settlement homes, operating bank branches within James Ross, Legal and Policy Director Joe Saunders, Deputy Program Director settlements, and providing loans and financial services to settlement Frances Sinha, Human Resources Director municipalities.

AMSTERDAM · BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH

Businesses should support and respect the protection of internationally proclaimed human rights. We are requesting further information about your bank in order to get a better understanding of its operations in relation to the West Bank: 1. Is Discount Bank familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? 2. We understand that Discount Bank’s 2016 Corporate Social Responsibility Report pledges to promote the principles of the UN Global Compact, including respect for internationally recognized human rights. Does Discount Bank have additional written policies or guidelines regarding human rights and international humanitarian law compliance? If so, can you please provide copies of such policies. 3. Does Discount Bank have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information? 4. Has Discount Bank assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A recent report by the nonprofit organization Who Profits cites a number of projects in which Discount Bank is involved in Israeli settlements in the West Bank. Can you confirm the bank’s involvement in the following projects and provide further details about these transactions?

Providing a loan of up to ILS 1.5 million to the Gush Etzion Regional Council in May 2016;

Providing an additional ten-year loan to the Gush Etzion Regional Council in June 2015;

Providing a loan of ILS 6 million to the Gush Etzion Regional Council in June 2014;

Providing two loans two the Har Hevron Regional Council through Mercantile Discount Bank: one for ILS 4.8 million and another for ILS 2.4 million in March 2016;

Accompanying stage 3 of a construction project, “Amirei Nof,” in Alfei Menashe, concluded in 2016;

Accompanying stage 3 of a construction project, “Green Ariel,” through Mercantile Discount Bank subject to an agreement from December 2015; Accompanying a construction project, “Home in Ariel across from the University,” through Mercantile Discount Bank (currently under construction);

Accompanying, via Mercantile Discount Bank, a construction project, “Home in Ariel”, concluded in 2015;

Accompanying, via Mercantile Discount Bank, a construction project implemented by Kotler Adika in the Mishor Adumim industrial area. 6. Please provide further information about the overall scope of Discount Bank’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value. Specifically, we seek information on the scope of mortgages provided by the banks for homes purchased in the settlements and the overall funding the bank provides for construction projects.

Sincerely yours,

Sari Bashi Israel and Palestine Advocacy Director Middle East and North Africa Human Rights Watch Telephone: XXXXXXXXXXXXX Fax: XXXXXXXXXXXXX E-mail: XXXXXXXXXXXXX HUMAN RIGHTS WATCH 350 Fifth Avenue, 34th Floor New York, NY 10118- February 5, 2018 3299 Tel: 212-290- 4700 Spokesperson Department Fax:MIDDLE EAST212-736 AND- NORTH AFRICA Bank Leumi D1300 I V I S I O N Via E-mail: XXXXXXXXXXXXX, XXXXXXXXXXXXX Sarah Leah Whitson, Executive Director Lama Fakih, Deputy Director Eric Goldstein, Deputy Director Joe Stork, Deputy Director Greetings, Ahmed Benchemsi, Advocacy and Communications Director

Re: Banking Activities in West Bank Settlements 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 Gary G. Sick, Vice-Chair Fouad Abdelmoumni and humanitarian law responsibilities such as those detailed in the United Gamal M. Abouali Yasser Akkaoui Nations Guiding Principles on Business and Human Rights. In the interests of Hala Al-Dossari Salah Al Hejailan thorough and objective reporting, we are writing to request information on these Abdul-Ghani Al-Iryani Ahmed Al-Mukhaini issues, to share your understanding of the legal framework guiding those Ghanim Al-Najjar Lisa Anderson activities, and to offer any other perspectives you may have. Due to our Shaul Bakhash David Bernstein publications schedule, we request a response by February 25. Robert L. Bernstein Nathan Brown Paul Chevigny Hanaa Edwar Human Rights Watch is an independent, nongovernmental organization that Bahey El Din Hassan Hassan Elmasry monitors and reports on human rights in 90 countries around the world. Our Mansour Farhang Loubna Freih Georges Israel and Palestine team researches and reports human rights violations by Aeyal Gross Amr Hamzawy Israel, the Palestinian Authority, and Hamas. Asos Hardi Shawan Jabarin Marina Pinto Kaufman Youssef Khlat In January 2016, Human Rights Watch published a report, Occupation, Inc., Ahmed Mansoor Stephen P. Marks analyzing business activities in Israeli settlements located in the occupied West Abdelaziz Nouaydi Nabeel Rajab Bank. Our research indicates that by supporting, facilitating, and expanding Vicki Riskin Charles Shamas settlements, business activity in Israeli settlements inherently contributes to and Sid Sheinberg Sussan Tahmasebi benefits from serious violations of human rights and international humanitarian law. Mustapha Tlili For these reasons, we recommend that businesses cease settlement-related

activities. H uman Rights W a t c h Kenneth Roth, Executive Director Our current research is examining whether some banks are contributing to violations Michele Alexander, Deputy Executive Director, of human rights and international humanitarian law, for example, by providing Development and Global initiatives services that help maintain and expand settlements, including financing Nicholas Dawes, Deputy Executive Director, construction projects, providing mortgages for settlement homes, operating bank Communications branches within settlements, and providing loans and financial services to Iain Levine, Deputy Executive Director, Program settlement municipalities. Chuck Lustig, Deputy Executive Director, Operations Walid Ayoub, Information We are requesting further information about your bank in order to get a better Technology Director Emma Daly, Communicationsunderstanding of its operations:: Director Barbara Guglielmo, Finance and Administration Director Babatunde Olugboji, Deputy Program Director Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director James Ross,AMSTERDAM Legal and Policy· BEIRUT · BERLIN·BRUSSELS·CHICAGO · GENEVA·JOHANNESBURG · LONDON·LOS ANGELES·MOSCOW· NAIROBI · NEW YORK·PARIS · Director SAN FRANCISCO - TOKYO · TORONTO·WASHINGTON - ZURICH Joe Saunders, Deputy Program Director BusinessesFrances Sinha, Human should support and respect the protection of internationally proclaimed human rights. 1. Is Bank Leumi familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? Does the bank have any other policies and procedures pertaining to human rights or international humanitarian law? 2. We understand that Bank Leumi’s 2016 Corporate Social Responsibility Report pledges to promote the principles of the UN Global Compact, including respect for internationally recognized human rights. Does Bank Leumi have additional written policies or guidelines regarding human rights compliance? If so, can you please provide copies of such policies. 3. Does Bank Leumi have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information?. 4. Has Bank Leumi assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A recent report by the nonprofit organization Who Profits cites a number of projects in which Bank Leumi is involved in Israeli settlements in the West Bank. Can you confirm the bank’s involvement in the following projects and provide further details about these transactions?

Providing a loan of up to US$5 million to the Gush Etzion Regional Council in or after May 2016;

Providing a $10.9 million loan to the Mateh Binyamin Regional Council in or after February 2015;

Providing a $2.52 million loan to the Har Hevron Regional Council in or after June 2015;

Accompanying a road pavement, development, and infrastructure project in Givat Ze’ev, according to a 2013 agreement; and

Accompanying a housing project, “Medoragey Hadar,” in Ma’ale Adumim, completed in 2016. 6. In addition, Human Rights Watch’s research indicates involvement by Bank Leumi in additional projects. Can you confirm the bank’s involvement in the following projects? Accompanying stage 4 of a construction project in Alfei Menashe, “Amirei Nof,” according to a June 2015 agreement;

Accompanying a construction project in Beitar Elit, “Atzulat Yehuda”, being undertaken by the Ahid Hasim company. 7. Please provide further information about the overall scope of Bank Leumi’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value.

Sincerely yours,

To:

MIDDLE EAST AND NORTH AFRICA DIVISION Sarah Leah Whitson, Executive Director Mr. Tuvia Sofer Lama Fakih, Deputy Director Eric Goldstein, Deputy Director Spokesperson Joe Stork, Deputy Director Ahmed Benchemsi, Advocacy and Union Bank of Israel Communications Director Via E-mail: XXXXXXXXXXXXX

ADVISORY COMMITTEE Greetings, Asli Bali, Co-Chair Kathleen Peratis, Co-Chair Bruce Rabb, Vice-Chair Gary G. Sick, Vice-Chair Re: Banking Activities in West Bank Settlements Fouad Abdelmoumni Gamal M. Abouali Yasser Akkaoui Hala Al-Dossari Human Rights Watch is preparing a publication analyzing the activities of Salah Al Hejailan Abdul-Ghani Al-Iryani Israeli banks in Israeli settlements in the West Bank in the context of their Ahmed Al-Mukhaini Ghanim Al-Najjar human rights and humanitarian law responsibilities such as those Lisa Anderson Shaul Bakhash detailed in the United Nations Guiding Principles on Business and Human David Bernstein Robert L. Bernstein Rights. In the interests of thorough and objective reporting, we are writing Nathan Brown Paul Chevigny to request information on these issues, to share your understanding of Hanaa Edwar Bahey El Din Hassan the legal framework guiding those activities, and to offer any other Hassan Elmasry Mansour Farhang perspectives you may have. Due to our publications schedule, we request Loubna Freih Georges Aeyal Gross a response by February 25. Amr Hamzawy Asos Hardi Shawan Jabarin Marina Pinto Kaufman Human Rights Watch is an independent, nongovernmental organization Youssef Khlat Ahmed Mansoor that monitors and reports on human rights in 90 countries around the Stephen P. Marks Abdelaziz Nouaydi world. Our Israel and Palestine team researches and reports human rights Nabeel Rajab Vicki Riskin violations by Israel, the Palestinian Authority, and Hamas. Charles Shamas Sid Sheinberg Sussan Tahmasebi Mustapha Tlili In January 2016, Human Rights Watch published a report, Occupation, Inc., analyzing business activities in Israeli settlements located in the Human Rights Watch occupied West Bank. Our research indicates that by supporting, Kenneth Roth, Executive Director Michele Alexander, Deputy Executive facilitating, and expanding settlements, business activity in Israeli Director, Development and Global initiatives Nicholas Dawes, Deputy Executive Director, settlements inherently contributes to and benefits from serious violations Communications Iain Levine, Deputy Executive Director, of human rights and international humanitarian law. For these reasons, Program Chuck Lustig, Deputy Executive Director, we recommend that businesses cease settlement-related activities. Operations Walid Ayoub, Information Technology Director Emma Daly, Communications Director Our current research is examining whether some banks are contributing to Barbara Guglielmo, Finance and Administration Director violations of human rights and international humanitarian law, for Babatunde Olugboji, Deputy Program Director example, by providing services that help maintain and expand Dinah PoKempner, General Counsel Tom Porteous, Deputy Program Director settlements, including financing construction projects, providing James Ross, Legal and Policy Director Joe Saunders, Deputy Program Director mortgages for settlement homes, operating bank branches within Frances Sinha, Human Resources Director

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Businesses should support and respect the protection of internationally proclaimed human rights. settlements, and providing loans and financial services to settlement municipalities. We are requesting further information about your bank in order to get a better understanding of its operations in relation to the West Bank: 1. Is Union Bank of Israel familiar with the UN Guiding Principles on Business and Human Rights? If so, what if any steps has it taken to implement them? 2. Does Union Bank of Israel have written policies or guidelines regarding human rights and international humanitarian law compliance? If so, can you please provide copies of such policies. 3. Does Union Bank of Israel have specific policies regarding its operations as they pertain to or in Israeli settlements? If so, can you please provide such policies and any other related information? 4. Has Union Bank of Israel assessed whether its activities in Israeli settlements have any human rights impacts? If so, please provide the Bank’s perspectives on its human rights impact in the settlements. 5. A recent report by the nonprofit organization Who Profits cites a number of projects in which Union Bank of Israel is involved in Israeli settlements in the West Bank. Can you confirm the bank’s involvement in the following projects and provide further details about these transactions?

Providing guarantees of ILS 970,000 to the Kedumim Local Council in November 2012;

Accompanying a 24-unit housing project carried out by the D. Elispur construction company in Agan HaAyalot in Giv’at Ze’ev;

Accompanying a 120-unit housing project, “Minrav BaGiva”, carried out by the Minrav construction company in Agan HaAyalot in Giv’at Ze’ev; 6. In addition, Human Rights Watch’s research indicates that Union Bank of Israel is accompanying a construction project, “Tzamarot Elkana”, carried out by Naftali Nissan & Sons LTD construction company. Can you confirm the bank’s involvement in this project and provide further details? 7. Please provide further information about the overall scope of Union Bank of Israel’s activities in Israeli settlements in the West Bank, including information about specific projects and their overall financial value. Specifically, we seek information on the scope of mortgages provided by the banks for homes purchased in the settlements and the overall funding the bank provides for construction projects.

Sincerely yours,

Sari Bashi Israel and Palestine Advocacy Director Middle East and North Africa Human Rights Watch Telephone: XXXXXXXXXXXXX Fax: XXXXXXXXXXXXX E-mail: XXXXXXXXXXXXX