WE at Solidarity with Palestine Pembrokeshire would like to address issues raised by a recently quoted memorandum (1) by United Kingdom Lawyers for Israel (UKLFI) and copied to Local Authority Councillors and the general public.

Firstly, the intention behind the memorandum is clearly political and commercial in nature, attempting to deny the ‘plausible genocide’ which the International Court of Justice (ICJ) declared on 26 January 2024, (2) and advocate for supporting Israeli interests. And further, the Court affirmed in a ruling on 19 July 2024, Israel’s occupation of the Gaza Strip, West Bank, including East Jerusalem, is ‘…unlawful, along with the associated settlement regime, annexation and use of natural resources.’ The ruling added ‘…Israel’s legislation and measures violated the international prohibition on racial segregation and apartheid.’ (3)

Evidence submitted to the ICJ by the United Nations Under-Secretary-General for Humanitarian Affairs and Emergency Relief Coordinator, Mr Martin Griffiths,

“Gaza has become a place of death and despair. . . . Families are sleeping in the open as temperatures plummet. Areas where civilians were told to relocate for their safety have come under bombardment. Medical facilities are under relentless attack. The few hospitals that are partially functional are overwhelmed with trauma cases, critically short of all supplies, and inundated by desperate people seeking safety. A public health disaster is unfolding. Infectious diseases are spreading in overcrowded shelters as sewers spill over. Some 180 Palestinian women are giving birth daily amidst this chaos. People are facing the highest levels of food insecurity ever recorded. Famine is around the corner. For children in particular, the past 12 weeks have been traumatic: No food. No water. No school. Nothing but the terrifying sounds of war, day in and day out.” (4)

We are now nearly two years later, and the situation is considerably and undeniably worse for the remaining people of Gaza.

That HMG has not fulfilled its obligations under international and national law, specifically the Hague and Geneva Conventions, and remains a direct partner to Israel in its ongoing genocide, war crimes and other crimes against humanity, is an irredeemable shame on it, and us all. The Government and its agencies must be forced to correct this illegal position.

Israel, too, has not accepted the Court’s demand that it take,

“...all measures within its power to prevent and punish the direct and public incitement to commit genocide in relation to members of the Palestinian group in the Gaza Strip. …The Court further considers that Israel must take immediate and effective measures to enable the provision of urgently needed basic services and humanitarian assistance to address the adverse conditions of life faced by Palestinians in the Gaza Strip.” (5)

What is to be done? What are we, as citizens, pensioners and investors, to do?

The group issuing the memorandum, UKLFI, is both a charitable trust (6) and a private company limited by guarantee (7). However, the aims of both seem identical; to quote their mission statement, they ‘use the law to counter attempts to undermine, attack and delegitimise Israel, Israeli organisations, and supporters of Israel’. (8) The government’s Standard Industrial Classification (Nature of Business) code is 94920, which designates that it carries out the ‘activities of political organisations.’ (9) The Charities Commission currently have an active open case investigating the relationship between the charity and its parent organisation, UKLFI Ltd. (10)

UKLFI’s motive is clear, as is its confusion over business law and its applicability to organisations that trade with, or in, entities operating in internationally recognised illegally occupied territories, in this case, the occupied Palestinian territories (OPT). All private sector organisations must align operations with the UNGP – the UN Guiding Principles on Business and Human Rights (11). The ICJ’s ruling affirms this. The UN Office of the High Commissioner has listed corporations that do business in the OPT, which are de facto engaged in business extra-legally, by definition.

Dyfed Pension Fund managers, including BlackRock, have actually increased their holdings in funds and companies that operate in the OPT specifically, and also in Israel, more generally. This is astonishing and morally unconscionable, being in opposition to the Fund’s own ESG and Responsible Investment Policy, which states:

The (DPF) Committee recognises that it has an obligation to respect human rights as outlined within the UN Guiding Principles on Business and Human Rights (UNGPs) and to encourage good practice which protects against violation and exploitation. (12)

If this ‘obligation’ is meaningful, then why the increase, rather than divestment of financial instruments, that not only can, but should, be sold and the funds reinvested elsewhere?

UKLFI urges that ‘Regardless of your stance on the Palestinian or Israeli issues’ (13) The Council should not accept Boycott, Divestment or Sanctions (BDS) because it is ‘detrimental to community cohesion and public safety, and is inconsistent with the Council’s fiduciary responsibilities…’ We would like to draw your attention to the word ‘regardless’: UKLFI are saying: ignore that Israel is engaged in genocide and that it is the Palestinian people who are being targeted, think of your returns, especially given the ‘upward trend of Israel’s stock market.’ We wonder if UKLFI also advocate ignoring the illegal invasion of Ukraine by Russia, as investment opportunities may present themselves during genocide, war and conflict, and to protect the Russian stock market likewise?

We would also like to address the outrageous statement that ‘BDS invariably leads to antisemitic acts…’ and that, by implication, if any Council, such as Ceredigion or Carmarthenshire, engages in any part of BDS, as they have committed to doing, will become responsible for encouraging acts of antisemitism. There is absolutely no evidence that BDS, either directly or indirectly, incites antisemitic or any other racial or religious illegal incitements, and we challenge UKLFI to produce such evidence to substantiate that statement.

In fact, our experience is that social harmony is enhanced, not threatened, by the attempt to tackle all racism, including antisemitism, wherever it occurs. And we would further like to point out that Jewish groups and individuals often lead the call for the boycott, divestment, and sanctions on Israel (14). To deliberately conflate the opposition to the policies of Israel with antisemitism is to purposefully threaten, attack and label those people, Jewish or not, with a vile slur.

BDS is a socioeconomic tool used successfully elsewhere, as during the Apartheid-era in South Africa, and currently against Russia, as a legitimate and legal measure that ordinary people of conscience can apply collectively to pressure bodies that represent them, and in so doing alleviate some of the worst conditions that humanity experiences.

Since the ‘ceasefire’ was issued on 11 October 2025, Israel has continued to conduct attacks on Gaza and obstruct humanitarian aid deliveries, killing over 365 people (15), many of them children. Knowing that the horrific plight of the Palestinian people is not at an end only strengthens our resolve to face down all obstacles to their freedom.