HSBC Holdings plc

HSBC represents a significant financial sector target due to its scale as Europe's largest bank by assets ($3.1 trillion) and its documented financing relationships with defence contractors and Israeli infrastructure. While less consumer-facing than Barclays, HSBC's Section 172 exposure, institutional shareholder base, and ESG instability create distinct pressure opportunities.

Key Leverage Points

• Section 172 Legal Exposure: As a UK-headquartered company, HSBC directors have statutory duties under the Companies Act 2006 to maintain 'reputation for high standards of business conduct.' Financing companies whose weapons are documented in operations the ICJ terms a 'plausible genocide' creates documented legal exposure for directors.
• ESG Function Instability: The October 2024 restructuring removed the Chief Sustainability Officer from the executive committee, followed by Celine Herweijer's departure in December 2024. The bank pushed back its net zero operations target by 20 years. This signals ESG deprioritisation that institutional investors may challenge.
• Infrastructure Financing Visibility: The €1 billion Tel Aviv light rail financing provides a concrete, recent example of direct support for Israeli state infrastructure during the conflict period. Israeli officials' characterisation as a 'vote of confidence' undermines HSBC's neutrality claims.
• AGM Vulnerability: Climate activists have disrupted AGMs since 2022, with the bank now considering virtual-only meetings to avoid protests. This demonstrates vulnerability to sustained pressure and could extend to Gaza-focused campaigns.
• Historical Precedent: HSBC divested from Elbit Systems in 2018 following War on Want campaign pressure, proving the bank responds to coordinated advocacy. However, subsequent reinvestment in Elbit shares (per 2024 reports) demonstrates need for sustained monitoring.

Evidence Summary

War on Want documents HSBC holding over £831 million in shares in defence companies supplying Israel, including £180 million in BAE Systems, plus significant holdings in Boeing, Caterpillar, and Raytheon. The Don't Buy Into Occupation coalition identifies HSBC among the largest European creditors to companies involved in illegal Israeli settlement activities. In July 2023, HSBC provided €1 billion financing for the Tel Aviv Purple Line light rail, which the Israeli Transport Minister publicly celebrated as a 'vote of confidence' in the Israeli economy. HSBC also maintains banking operations in Israel through HSBC Israel, serving Israeli corporates and high-tech firms. The bank's own policy claims to prohibit financing weapons manufacturers, creating a documented gap between policy and practice.

Engagement Strategy

Pursue a three-track strategy focused on HSBC's institutional character: (1) Institutional shareholder engagement targeting pension funds and asset managers with ESG mandates, highlighting the contradiction between HSBC's stated policies and documented defence investments, and the removal of sustainability leadership from executive decision-making; (2) Section 172 documentation producing analysis of how defence financing and settlement-linked company relationships violate directors' statutory duty to maintain high standards of business conduct; (3) AGM intervention building on existing climate activist disruption to include Gaza-focused shareholder questions and resolutions. The 2018 Elbit divestment demonstrates HSBC's responsiveness to sustained campaign pressure, but subsequent reinvestment shows the need for ongoing accountability mechanisms.