Points of consideration:

1.F-35s are not mentioned in the whole review. 

There is not one reference to F-35s in the whole document. Invest NI never mention or accept that NI-based companies they have funded currently participate in the F-35 supply chains. Our report lays out numerous meetings with BAE Systems and other NI-based companies where F-35 contracts are mentioned. 

2. The timescale under review

The timescale considered by the Review too narrow and excludes companies that Invest NI knew had F-35 related contracts. The terms of reference of the review only include investments made by Invest NI after October 7th 2023. Given that Act Now’s report clearly demonstrates how Invest NI knew of NI-based companies involvement in the F-35 programme before October 7th 2023 and actively sought out a relationship with BAE Systems so that NI-based companies could enter into their F-35 supply chain, there is high probability that financial assistance provided by Invest NI helped those companies enter into the supply chain. Even though those companies did not receive money during Israel’s current bombing campaign, that does not exclude the strong possibility that they continued to supply F-35 components and as such, that public money supported the production costs for those companies to manufacture those components. 

3. “Purpose” vs “Outcome”

Invest NI have implicitly accepted that the public money may have inadvertently supported the manufacture of arms and components for supply to Israel. In their review, Invest NI concluded that "the review has confirmed that no project supported by Invest NI was for the purpose of supporting the manufacture of arms or their components, for supply to Israel.” The insertion of the word “purpose” suggests that there is an implicit acceptance that capital investment funding may have inadvertently helped these companies to enter into F-35 supply chains - for example, new machinery, labour development and research and development. 

Ruling out that no public money had the purpose to support the manufacture of arms or components to Israel does not exclude the outcome that it did. The focus on assessing the purpose of the grant funding rather than the outcome that those funds created significantly differs from the parameters set by Minister Caoimhe Archibald in her original request to Invest NI: “a review of investments to establish if Invest NI funding was used to manufacture arms or their components for supply to Israel.” The reason for Invest NI’s decision to assess cases by purpose over outcome is revealed in section 12: “It is not possible for Invest NI or its client companies to fully track or determine the final destination of exported goods once they enter complex global supply chains. Over the lifecycle of a product, client companies may engage with multiple customers and export destinations, which can evolve over time.” This is exactly why Invest NI can only argue that it was not the “purpose” of this funding to manufacture arms or their components for Israel as they cannot rule it out as an outcome of the funding. This is a significantly different conclusion to the one that the Minister makes in her statement - “the review is categorical - Invest NI does not support the manufacture of arms or their components for Israel.” If Invest NI cannot give guarantees, then nothing about this review is categorical.

4. Manufacturing costs and Production costs

Invest NI has not addressed the key point in Act Now’s report that public money may have supported the production costs for NI-based companies to supply components for the F-35 programme and/or helped them to enter into these supply chains. Manufacturing costs are solely the expense of making the product while production costs are much wider and overall costs - for example, buildings and overheads. Invest NI refuses to consider production costs because it would implicate their possible role in supporting F-35 production. While we accept Invest NI’s analysis that it cannot legally support the manufacturing costs of a business, the review does accept that it supports production costs. In section 5, Invest NI states they are able to offer financial assistance to support capital investment projects under EU Regional Aid provisions. This capital investment may have been key for these companies to develop their factories which increased their capacity or capability to enter into F-35 supply chains. As revealed and evidenced in Act Now’s ‘Invest NI, F-35s and Israel: Public Money for War Crimes?’ report, Invest NI not only offered these four companies important financial support to help develop their factories, labour force and more; but also provided key administrative support to win contracts - including ones related to F-35s - and support with strategic plans. Although Invest NI can rightly conclude they have not supported any manufacturing costs of arms and components for the supply to Israel, they cannot categorically rule out the strong possibility of supporting the production costs as these are much wider and longer-term - such as building, machinery and other overheads.

October 2025