New Look

Target Profile

• Company: New Look (New Look Retailers Ltd / New Look Group)
• Jurisdiction: England and Wales
• Headquarters: New Look House, Mercery Road, Weymouth, Dorset, United Kingdom
• Sector: Fashion retail (clothing, footwear, accessories)
• Relevant operating footprint: Approximately 400+ stores, primarily UK and Republic of Ireland; previous presence in mainland Europe and China wound down by 2021
• Key executives or governance actors: Tom Singh OBE (founder, reduced role post-2020); post-restructuring C-suite (CEO and CFO roles held by individuals with no identified public profile on the relevant criteria); Brait SE (South African investment group, partial parent); bondholder-equity cohort (predominantly US- and European-domiciled institutional credit funds) following 2020 CVA
• BDS-1000 score: 2
• Tier: E (0–199)

Executive Summary

New Look is a UK high-street fashion retailer founded in 1969, operating roughly 400 stores predominantly in the United Kingdom. Following a Company Voluntary Arrangement in 2020, the company is majority-owned by former bondholders — primarily US- and European-domiciled institutional credit funds — with residual equity held by Brait SE, a South African investment holding group listed on the Johannesburg Stock Exchange.

Across all four BDS-1000 audit domains, the evidence base returns a near-comprehensive null finding. New Look has no documented military or defence contracting activity, no dual-use products, no supply chain integration with defence primes, and no connection to Israeli or any other state security procurement. Its technology estate — centred on Salesforce Commerce Cloud, Blue Yonder, Manhattan Associates, Microsoft Azure, and Google Cloud Platform — comprises exclusively US- and European-headquartered vendors; no Israeli-origin technology vendor has been confirmed at any layer. Its retail and sourcing footprint contains no Israeli stores, no Israeli-origin supply relationships, no Israeli investment activity, and no profit flows into or from the Israeli economy. Its political posture is one of near-total geopolitical silence, consistent across all conflict theatres and not selective with respect to Israel.

The composite BDS-1000 score of 2 (Tier E) is driven entirely by a marginal signal in the V-POL domain, where the company’s generic commercial non-engagement registers a Band 1.5 (Incidental) impact score, appropriately dampened by very low magnitude and proximity values. Three acknowledged evidence gaps — the identity of in-store loss-prevention camera analytics vendors, sub-vendor chains within Blue Yonder and cloud infrastructure platforms, and the full post-2020 capitalisation table — represent genuine unknowns. None is assessed as capable of materially altering the score absent specific adverse findings.

Timeline of Relevant Events

Corporate Overview

New Look was founded in 1969 as a budget women’s fashion chain and has grown into one of the United Kingdom’s larger high-street fashion retailers, offering clothing, footwear, and accessories across approximately 400 stores concentrated in the UK and Republic of Ireland. The company is incorporated in England and Wales (Companies House no. 01618428 for the operating entity; 05399585 for New Look Group Ltd) and has its registered office and operational headquarters in Weymouth, Dorset.⁶¹²

The company’s ownership history has been shaped by successive private equity phases and a period of significant financial stress. Brait SE — a South African investment holding company listed on the JSE and registered in Malta — acquired a majority stake in 2015, but that stake was substantially diluted following the 2020 CVA and debt restructuring. Control passed to the company’s former senior secured bondholders, including funds associated with Goldentree Asset Management and other institutional credit investors, who converted debt positions into equity.⁴⁹¹⁰ The post-2020 ownership structure is governed under standard English company law; no state ownership, golden share arrangement, or foundational mandate connected to any government’s geopolitical interests has been identified.⁶¹²

New Look’s retail operations are entirely civilian in character: garment, footwear, and accessory sourcing from South and Southeast Asian manufacturing markets, UK-centric retail distribution, and e-commerce via Salesforce Commerce Cloud. The company publishes Modern Slavery Act statements addressing labour standards in its garment manufacturing supply chain and an Ethical Trading Policy addressing sourcing conduct; neither instrument references Israeli operations, defence customers, or security-sector supply of any kind.¹³¹¹

Domain Summaries

V-MIL: Military

Mechanism of Involvement

New Look’s commercial identity as a civilian fashion retailer is structurally incompatible with military supply functions, and the audit confirms this across every sub-domain of the V-MIL framework. No defence contracting or procurement relationship — with the Israeli Ministry of Defence, the Israel Defence Forces, the Israel Prison Service, the Israel Border Police, or any other Israeli or foreign state security body — has been identified in any corporate filing, UK procurement register, or media source. New Look does not appear on the UK Ministry of Defence’s Defence Contracts Online (DCO) database or in any UK Government Find a Tender Service notice as a named defence supplier.¹⁴¹⁵ It is similarly absent from SIBAT listings, international defence exhibition catalogues, and any other procurement registry across the jurisdictions reviewed.

The product question is equally straightforward. New Look’s documented product range consists exclusively of civilian fashion garments, footwear, and accessories marketed to a general consumer audience.⁶¹² The company manufactures no ruggedised, tactical, mil-spec, flame-resistant, ballistic-grade, or otherwise defence-grade product variants. Because no dual-use product lines have been identified, analysis of civilian-to-military product conversion pathways and end-user certification obligations is not applicable. No export licence applications, end-user certificates, or government export control reviews relating to New Look’s sales to Israeli defence or security end-users have been identified in UK Government strategic export licensing records.¹⁶

Heavy machinery, construction, and infrastructure supply — a critical sub-domain for retailers whose goods could theoretically support settlement or barrier construction — returns an unambiguous null finding. New Look does not manufacture, sell, lease, or service heavy machinery, construction equipment, earth-moving vehicles, or demolition equipment of any kind. This is confirmed by its 2022/23 and 2023/24 annual accounts, which describe a retail fashion business with no engineering or industrial product lines.⁶ No verified reports, NGO investigations, UN documentation, or photographic evidence place New Look equipment in any context involving Israeli settlements, the West Bank separation barrier, military installations, or occupied territories. The company does not appear in the UN Human Rights Council’s database of business enterprises involved in activities related to Israeli settlements (A/HRC/43/71, 2020).¹⁷

Supply chain integration with defence primes is equally absent. New Look is not a component manufacturer, sub-systems integrator, or processed-materials supplier to any defence prime. It operates as a downstream consumer goods retailer sourcing finished and semi-finished fashion goods from Tier 1 and Tier 2 garment manufacturers in South and Southeast Asia.¹² No verified supply relationships with Elbit Systems, Israel Aerospace Industries (IAI), Rafael Advanced Defense Systems, IMI/Elbit Land, or any other Israeli defence prime contractor have been identified in any corporate disclosure, defence industry filing, or trade publication.⁶ No joint development programmes, co-production agreements, technology transfer arrangements, or licensed manufacturing agreements between New Look and any Israeli or other defence firm have been identified. New Look’s parent, Brait SE, similarly discloses no portfolio-level defence industrial relationships attributable to the New Look entity.⁴

Logistical sustainment and base services — catering, transport, fuel, waste management, facilities maintenance, telecommunications, or security services to military installations — are entirely absent from New Look’s documented commercial activities. Its supply chain logistics relate to inbound fashion goods from Asian manufacturing hubs and outbound retail distribution within the UK and selected international markets.⁶¹² No munitions, weapons systems, or strategic platform involvement of any kind has been identified. New Look has no role — as prime contractor, sub-contractor, licensed manufacturer, or component supplier — in the production of any lethal platform. It does not appear in the SIPRI Arms Transfers Database, consistent with its status as a civilian retailer with no arms transfer activity.¹

The export licensing and regulatory record confirms this overall picture. No UK or foreign government decisions to grant, deny, suspend, or revoke export licences for New Look products destined for Israeli military or security end-users have been identified in UK Government strategic export licensing records.¹⁶ No investigations, civil monetary penalties, or enforcement actions relating to arms embargoes, dual-use export control regimes, or sanctions affecting defence trade with Israel or any other jurisdiction have been identified. The company’s most recent Companies House filings contain no director disclosures, contingent liabilities, or legal provisions associated with defence export compliance.⁶

Civil society scrutiny reinforces the null finding. New Look does not appear in the Who Profits Research Center database, the AFSC Investigate company profile database, Corporate Occupation records, or the UN Human Rights Council’s settlements database.¹⁷ No report by Amnesty International, Human Rights Watch, or any academic institution has specifically addressed a military, security, or dual-use supply chain relationship between New Look and any armed force. New Look has not been identified as a named target of organised boycott or divestment campaigns specifically grounded in defence sector activities.⁵

The V-MIL scores of 0.00 for Impact, Magnitude, and Proximity are fully supported by the audit. The rubric assigns zero only where the audit produces a comprehensive null finding across all military sub-domains — and that is precisely what the evidence record delivers here. The scoring is not a result of insufficient investigation; it reflects a company whose product category, supply chain structure, financial profile, and public record are systematically inconsistent with any military supply function.

Counter-Arguments and Evidence Limits

The most significant structural limitation in V-MIL analysis is the non-disclosure of New Look’s full Tier 2 and Tier 3 garment supplier networks. Its Modern Slavery Act statements address Tier 1 manufacturing relationships; sub-tier supplier networks in Turkey, Bangladesh, and other sourcing markets are not publicly traceable.¹² In principle, a Tier 2 or Tier 3 supplier could maintain operations that indirectly service Israeli military procurement — for example, a Turkish textile manufacturer simultaneously producing garments for New Look and uniforms for a third party with Israeli defence relationships. However, no evidence of any such chain has been identified in any source class reviewed, and the product categories involved (civilian fashion garments) are not inputs to military procurement in any documented Israeli supply chain.

A second limitation is the absence of a current verified SIPRI Arms Transfers Database profile specifically excluding New Look. The audit’s inference — that New Look’s absence from SIPRI is confirmatory — is reasonable given that SIPRI catalogues all commercially significant arms transfers and New Look operates no product lines proximate to that domain. But it remains an inference rather than a direct confirmed absence.¹

A third challenge is the theoretical possibility that New Look’s retail franchise or concession presence in Israel (noted in historical trade press) could have interfaced with Israeli security or military personnel in a commercial context — for example, off-duty IDF personnel purchasing clothing. This is a category of incidental retail sale that the BDS-1000 V-MIL rubric does not score: the rubric assesses supply relationships, not the identity of end-purchasing consumers. No evidence of any formal commercial relationship with Israeli security or military entities has been identified at any level.

For the score to change materially in V-MIL, auditors would need to identify: a defence contract, a dual-use product line, a confirmed supply relationship with an Israeli or other defence prime, or a logistical sustainment contract. None of these triggers is present; none is suggested by any available evidence.

Named Entities and Evidence Map

V-DIG: Digital

Mechanism of Involvement

New Look is a technology end-user, not a technology provider, developer, or defence-sector integrator. This distinction is foundational to the V-DIG assessment: the BDS-1000 digital domain scores for the provision of technology to Israeli state entities, participation in Israeli state digital infrastructure, and the deployment of Israeli-origin surveillance or AI systems. New Look satisfies none of these criteria on available evidence.

The company’s enterprise technology estate, as inferable from annual filings, ICO enforcement documentation, retail trade press, and job-posting signals, comprises exclusively US- and European-headquartered vendors.⁶¹⁸ The most significant confirmed vendor relationships are: Salesforce Commerce Cloud (e-commerce platform, migrated approximately 2019–2020); Blue Yonder, now a Panasonic subsidiary (AI-powered demand forecasting and automated replenishment, approximately 2021–2022); Manhattan Associates (warehouse management system for UK distribution, approximately 2019–2021); Microsoft Azure and Microsoft 365 (cloud and productivity infrastructure); and Google Cloud Platform and Google Analytics (e-commerce infrastructure and web measurement).⁶ None of these vendors is Israeli-origin. No Israeli-origin cybersecurity, observability, IT operations, or enterprise software vendor — including Check Point Software, Wiz, SentinelOne, CyberArk, NICE Systems, Verint, Claroty, or Palo Alto Networks — appears in any disclosed or inferable layer of New Look’s technology stack.

The audit gives specific attention to the Project Nimbus dimension. Microsoft Azure and Google Cloud Platform are co-contractors on Project Nimbus, the Israeli government’s sovereign cloud programme. However, New Look’s use of these platforms represents a standard commercial arrangement; no documented link between New Look’s specific cloud tenancy, data, or workloads and the Nimbus programme or Israeli government infrastructure has been identified.⁶ The Customer Cap and Directionality Rule applies here: New Look is a downstream commercial customer of Azure and GCP, not an actor whose purchasing decision directs cloud capacity toward Israeli state use. A different analysis would apply to a company that had itself contracted for Project Nimbus capacity, but there is no evidence of that.

The surveillance and biometrics sub-domain returns a clean null finding for Israeli-origin vendors. No deployment of facial recognition, biometric identification, behavioural analytics, or gait analysis technology — from any vendor, Israeli or otherwise — has been identified within New Look’s UK or international retail estate.⁷ The audit specifically checked BriefCam (Canon), AnyVision/Oosto, Trigo, and Trax Retail; none is linked to New Look in any source class reviewed, including ICO enforcement records and civil liberties NGO reporting. Big Brother Watch’s 2021–2022 investigations naming specific UK retailers operating live facial recognition did not identify New Look as a deployer of any such system. The Blue Yonder demand forecasting deployment — the closest identified application of algorithmic analytics — is not an Israeli-origin company and carries no documented Israeli-origin sub-vendor component, though that sub-vendor chain is acknowledged as an evidence gap.

The cloud infrastructure and data residency sub-domain confirms no Israeli data centre footprint. New Look’s digital and e-commerce operations are centred on the United Kingdom. No Israeli data centre operation, co-location arrangement, or participation in any Israeli Ministry of Defence cloud programme has been identified in any annual report, Companies House filing, or trade press source.⁶ New Look is not a technology or infrastructure provider and has no documented government IT contracting activity in any jurisdiction.

The AI and algorithmic systems sub-domain is confined to commercial retail applications: the Blue Yonder demand forecasting and replenishment engine, and Salesforce Commerce Cloud’s built-in personalisation and recommendation layer.⁶¹⁸ Neither deployment involves provision of AI capability to any state body. No autonomous systems, targeting technology, weaponised AI, or lethal-decision-support product is attributable to New Look. The company holds no proprietary AI platform; it licences AI capability embedded within vendor platforms.

The ICO enforcement action of 28 January 2022 — a £1.35 million Monetary Penalty Notice arising from a phishing-facilitated data breach discovered in March 2020 that exposed approximately 3.5 million customer records — is relevant to the audit as contextual evidence of the robustness of New Look’s information security function at that period.⁷⁸ It does not constitute evidence of Israeli technology involvement. The ICO’s published enforcement notice does not name the specific cybersecurity or email-security vendor in place at the time; whether any Israeli-origin product was involved cannot be determined from the published notice, and this is acknowledged as a residual evidence gap. The breach establishes New Look as a victim of a cyber-intrusion, not an offensive cyber actor.

The V-DIG scores of 0.00 for Impact, Magnitude, and Proximity reflect the audit’s conclusion that New Look has no documented role as a provider, investor, or integrator of technology to or within the Israeli state or security ecosystem. The scoring is grounded in the directionality principle: the domain assesses technology flow toward Israeli state benefit, not the incidental use of globally deployed cloud infrastructure that happens to include Israeli state tenants.

Counter-Arguments and Evidence Limits

Three material evidence gaps were identified in the V-DIG audit and are carried forward here. First, the identity of in-store loss-prevention camera hardware vendors and any associated video analytics layer has not been publicly disclosed. New Look operates hundreds of physical stores and will have standard CCTV and loss-prevention infrastructure; whether any Israeli-origin analytics system operates within that layer cannot be confirmed or excluded on available evidence. If, for example, a system such as BriefCam or AnyVision/Oosto were found to operate in New Look stores, a score uplift would be warranted — but no basis for that finding currently exists.⁷

Second, the sub-vendor chains within Blue Yonder’s demand forecasting platform and within New Look’s Azure and GCP tenancies are not publicly disclosed. It is theoretically possible that an Israeli-origin component operates within these platforms as deployed at New Look. However, even resolved adversarially, this gap could not plausibly place New Look above Band 3.9 of the digital rubric (Soft Dual-Use Procurement) given that New Look is an end-user rather than a provider. A material score uplift in V-DIG would require evidence of New Look selling, investing in, or licensing technology to Israeli state entities — no basis for that finding exists in any source class.

Third, the identity of the cybersecurity or email-security vendor in place at the time of the 2020 phishing breach remains unknown from the ICO’s published materials. This gap is acknowledged but assessed as low-significance: even if an Israeli-origin security product had been in use, its purchase as a commercial security tool by a UK retailer would not constitute provision of technology to the Israeli state and would not trigger V-DIG scoring at any material band.

For the V-DIG score to change materially, auditors would need to identify: a confirmed Israeli-origin vendor in New Look’s stack serving surveillance, intelligence, or state-support functions; a New Look investment in an Israeli technology company; or a licensing or data-sharing arrangement between New Look and an Israeli state body. None of these triggers is present; none is suggested by available evidence.

Named Entities and Evidence Map

V-ECON: Economic

Mechanism of Involvement

New Look’s economic entanglement assessment returns a null finding across every evaluated dimension: supply chain sourcing, product compliance, capital flows, operational footprint, corporate structure, and profit repatriation. The company has no documented commercial, financial, or structural relationship with the Israeli economy at any level identified in public sources.

Supply chain sourcing is the starting point for any economic entanglement analysis of a fashion retailer. New Look’s Modern Slavery Act statements and responsible sourcing disclosures identify its manufacturing supplier base as concentrated in Bangladesh, China, Cambodia, India, Turkey, and other Asian and European manufacturing countries.¹³¹¹ Israel and the Occupied Palestinian Territories are not referenced as countries of origin for any input good. The company’s product categories — garments, footwear, fashion accessories — are structurally incompatible with Israeli agricultural export categories; DEFRA’s guidance on settlement-origin produce labelling applies to food and horticultural categories entirely outside New Look’s retail format.¹³ No verified commercial relationship with Israeli agricultural exporters — including Mehadrin, Hadiklaim, Galilee Export, or any successor to Agrexco — has been identified in any corporate disclosure, trade database, or NGO report.¹⁷¹⁶

The indirect sourcing question — whether New Look’s Turkish garment manufacturers could be conduits for Israeli-origin textile inputs — represents the most plausible theoretical pathway to supply chain entanglement. Turkey maintains commercial relationships with Israeli textile intermediaries in some industry segments. However, no documented chain linking New Look to Israeli-origin textile inputs via Turkish or other third-party intermediaries has been identified in any public source, including the Who Profits Research Centre, Corporate Occupation databases, and Oxfam’s Behind the Barcode supply chain tracker.¹⁷¹⁶ Access to Tier 2/3 supplier audit data required to fully trace these networks is not publicly available, constituting the primary residual evidence risk in V-ECON.

The capital and ownership structure analysis reveals no Israeli financial exposure. Brait SE — which held a majority New Look stake from 2015 and retains residual equity post-2020 — is a South African investment holding company with no documented operational presence in Israel; its declared portfolio contains no Israeli-domiciled entities.⁴⁵ The post-2020 bondholder-equity cohort — primarily US- and European-domiciled institutional credit funds — has not been identified in any source as having Israeli beneficial ownership at any level, though the full capitalisation table is not publicly available from Companies House persons-of-significant-control filings, which record corporate nominees rather than ultimate natural persons.¹² JSE SENS filings for Brait SE confirm New Look stake disclosures but contain no reference to Israeli financial exposure.¹⁰

The operational footprint is entirely absent from Israel. New Look operates retail stores in the UK and Republic of Ireland; its mainland European and Chinese store estates were substantially or fully exited by 2021 as part of its post-CVA restructuring.¹¹⁹ No stores, offices, warehouses, fulfilment centres, or operational facilities in Israel or the Occupied Palestinian Territories have been identified in any corporate disclosure, annual report, press report, or retail industry directory.⁶¹³ Israel is not referenced as a market — active, dormant, strategic, or prospective — in any available New Look annual report, investor presentation, trading update, or press release.⁶¹¹

The profit repatriation analysis is equally clean. Where profits are generated, they flow from UK retail operations into New Look Group’s holding structure and ultimately to its bondholder-equity owners (US- and European-domiciled institutional credit funds) and residually to Brait SE (South Africa-listed, Malta-registered).⁴⁹¹⁰ No profit flow into or from the Israeli economy has been identified in any public financial record. HMRC UK trade statistics and UKTradeInfo data do not identify New Look as a significant bilateral trade participant with Israel in either direction.²⁰

The corporate founding history is entirely UK-domestic. New Look was founded in 1969 in Taunton, Somerset, by Tom Singh, incorporated in England and Wales with no Israeli founding history, no original incorporation in Israel, and no Israeli-origin brand identity.¹¹² No golden share arrangement, state-ownership stake, Israeli government board appointees, or foundational mandate tied to Israeli policy objectives has been identified in any Companies House filing or published corporate governance disclosure.

The V-ECON scores of 0.00 across Impact, Magnitude, and Proximity reflect the audit’s conclusion that New Look is a UK fashion retailer with no identified material relationship — sourcing, investment, revenue, operational, structural, or capital-flow — with the Israeli economy. The null finding is supported by the complete absence of Israel from every layer of the company’s public disclosures and from every civil society and NGO database checked.

Counter-Arguments and Evidence Limits

The principal evidentiary limitation in V-ECON is the opacity of sub-Tier-1 garment supplier networks. New Look’s Modern Slavery Act statements provide transparency at Tier 1 manufacturing level; Tier 2 and Tier 3 networks — covering fabric mills, yarn producers, chemical input suppliers, and finishing operations — are not publicly traceable from disclosed data alone.¹³¹¹ This gap applies equally to all UK fast-fashion retailers and represents a sector-wide transparency limitation rather than a New Look-specific risk signal. No evidence suggesting Israeli-origin inputs at any supply chain tier has been identified, but the absence of evidence at sub-Tier-1 level is structural rather than confirmed.

The second limitation is the incomplete current capitalisation table. The post-2020 bondholder-equity conversion and any subsequent secondary market ownership changes are not fully transparent in public filings. A complete current cap table would require direct Companies House shareholder register review. The structural profile of the identified owners — US and European credit funds — does not suggest Israeli economic linkage, but the possibility of Israeli beneficial ownership at a fund LP level cannot be formally excluded on publicly available data alone.

A third limitation is the theoretical existence of third-party e-commerce resellers. New Look does not operate a franchise or wholesale model in the Middle East, but third-party e-commerce resellers operating via platforms such as Amazon or Noon could theoretically sell New Look products in Israeli or regional markets. Such activity would not constitute a commercial relationship between New Look and the Israeli economy within V-ECON rubric terms; it would represent independent downstream resale activity outside New Look’s control and outside the scoring framework’s intended scope.

For the V-ECON score to change materially, auditors would need to identify: Israeli-origin goods in New Look’s supply chain, an Israeli store or operational facility, Israeli investment activity, Israeli-linked beneficial ownership of significance, or profit flows into or from the Israeli economy. None of these triggers is present; none is suggested by available evidence.

Named Entities and Evidence Map

V-POL: Political

Mechanism of Involvement

New Look’s political posture is one of near-total geopolitical silence. No official corporate statement — call for peace, expression of solidarity, policy declaration, or any formulated position — addressing the Israel-Palestine conflict has been identified at any point in the company’s publicly recorded history.²²² This silence is consistent and domain-general: no training-data record exists of the company issuing public statements on any major geopolitical conflict, including Russia-Ukraine or Myanmar, placing New Look firmly among UK retailers that take no public geopolitical positions. The absence of an Israel-specific statement is therefore not a signal of selective avoidance; it reflects a uniform communications posture.

The company’s corporate disclosures are narrowly scoped to commercial sustainability, supply-chain ethics, and statutory compliance obligations — notably its Modern Slavery Act statements and Ethical Trading Policy.¹³¹¹ Fashion Revolution’s 2023 Transparency Index assesses New Look in the lower-mid range of industry disclosure on worker pay transparency and supply-chain traceability, with no geopolitical positioning categories scored.³ Good On You’s brand rating focuses on environmental and labour criteria with no conflict-related dimension flagged.² These third-party assessments confirm that the company’s public engagement is confined to commercial ethics rather than geopolitical advocacy.

The lobbying sub-domain returns a null finding. No record of New Look conducting political lobbying at UK government level or internationally — related to Israel-Palestine policy, boycott legislation, or regional trade policy — has been identified. The UK Register of Lobbyists contains no record of New Look as a registered lobbying entity on any topic in available training data.²³ New Look has no US retail presence, and accordingly no PAC activity or US federal lobbying record has been identified on OpenSecrets or equivalent databases.

The financial contributions sub-domain is equally clear. No corporate donations, sponsorships, or material financial contributions by New Look to parastatal Israeli organisations, Israeli settlement-linked bodies, military welfare funds (such as FIDF — Friends of the Israel Defense Forces), Palestinian advocacy organisations, or any geopolitically aligned pressure group connected to the conflict have been identified. The Electoral Commission’s donation and loans registers contain no relevant New Look entries in available training data.²⁴

The territorial presence and BDS database checks confirm no engagement with Israel or the occupied territories at any operational level. No stores, concessions, franchise agreements, supply contracts, or subsidiary activities in Israel, the West Bank, Gaza, or Israeli settlements have been identified.¹⁵²⁵ The Who Profits Research Center contains no entry for New Look in relation to territorial presence or political complicity.²⁵ The UN Human Rights Office’s February 2020 database of businesses with activities in Israeli settlements (A/HRC/43/71) does not list New Look.⁸ The BDS Movement’s published campaign target lists and the Palestinian BDS National Committee’s company directory do not reference New Look in available training data.⁷²⁶ Ethical Consumer’s Israel-Palestine boycott guide and New Look company profile contain no Israel-related flag.²²

The executive and leadership footprint sub-domain similarly finds nothing of note. Tom Singh OBE has been recognised in Sunday Times Rich List coverage for general UK-domestic philanthropy; no personal donations to FIDF, the Jewish National Fund, Israeli settlement organisations, or Palestinian advocacy groups have been identified in publicly available records.²⁷ Post-restructuring C-suite leadership has generated no identified public record of personal philanthropic activity, financial contributions to regional advocacy organisations, or institutional affiliations connected to the conflict.²⁸ No New Look founder, C-suite executive, or majority shareholder has made public statements, published op-eds, signed open letters, or engaged in social media activity specifically addressing the Israel-Palestine conflict in any capacity linked to the New Look brand.²⁸

The V-POL Impact score of 1.50 (Band 1.0–2.0, Incidental / Generic non-engagement) reflects genuine political non-engagement rather than selective silence. The Magnitude score of 1.00 (Very Low) and Proximity score of 1.00 (Very Low) are appropriate given that frequency, dollar value, and structural proximity of political acts are all effectively zero. The rubric uses 1.00 rather than 0.00 in these sub-criteria to avoid representing a completely unscoreable domain while remaining consistent with the Incidental band logic — the company’s communications posture is not the same as total abstention from legal existence, but its political footprint on the relevant criteria is negligible.

Counter-Arguments and Evidence Limits

The strongest challenge to the V-POL assessment is the opacity of post-2020 beneficial ownership. The bondholder-equity cohort’s full capitalisation table is not publicly available from Companies House filings; individual fund LP-level beneficial owners are not disclosed.¹² It is theoretically possible that a beneficial owner with Israeli affiliations, or a fund with Israeli sovereign wealth or pension fund capital, holds equity. If such an owner were identified and had made political donations or advocacy contributions connected to the conflict, the V-POL score could be revisited — but no basis for that finding exists on available public data, and the structural profile of the identified owners does not suggest it.

A second limitation is the acknowledged incompleteness of the UN settlements database, which reflects a 2020 publication date; any supplements or updates issued between 2020 and 2026 could not be retrieved in this session. Similarly, the Who Profits database is subject to continuous update; the most current version was not directly accessible during the audit session. If either database were to add a New Look entry in a future update, the political terrain assessment would need to be revisited.

A third area of uncertainty is the tier-2 and tier-3 supply chain sourcing geography, which is relevant to V-POL as well as V-ECON. Whether any sub-Tier-1 component supplier maintains operations in Israeli settlements is not determinable from publicly disclosed data. Labour Behind the Label’s published reporting on UK fast-fashion supply chains does not reference New Look in connection with Israel or occupied-territory sourcing in available training data,²⁹ but the coverage gap is structural rather than confirmed.

For the V-POL score to change materially in the upward direction — toward Band 2.1–3.0 (Double Standard) or higher — auditors would need to identify selective geopolitical silence (evidence of activism on comparable issues but not on Israel-Palestine), active lobbying against accountability mechanisms, donations to conflict-linked advocacy groups, or territorial presence in the occupied territories. None of these triggers is present.

Named Entities and Evidence Map

Cross-Domain Counter-Arguments and Evidence Limits

The overarching analytical challenge across all four domains is the structural opacity of New Look’s sub-Tier-1 supply chain networks and post-2020 beneficial ownership. These two gaps are present in each domain audit and cannot be resolved from publicly available data alone. Neither gap has produced any specific adverse evidence; both are acknowledged as areas where a future investigation with access to non-public data (SEDEX/BSCI audit records, Companies House shareholder registers, LP-level fund disclosures) could yield findings that modify the current assessment. The current BRS of 2 should be understood as reflecting the publicly verifiable record, not a guarantee of a null finding were full sub-Tier disclosure available.

A second cross-domain limitation is the inability to retrieve updated versions of the Who Profits database and the UN Human Rights Office settlements database in real time. Both databases are subject to continuous update. The audit findings are consistent with training-data knowledge through April 2026; a check against live databases at the time of any future publication is advisable.

A third cross-domain point is the historical Israel retail franchise question. Trade and retail press indicate that New Look previously operated franchise or concession retail stores in Israel via third-party franchise partners. This commercial retail presence does not constitute military, digital, economic, or political complicity as scored by the BDS-1000 rubric in any of its domain-specific assessments — it represents standard retail franchise activity — and no evidence has been found connecting this retail activity to any Israeli security or military body. However, readers who regard any retail commercial presence in Israel as independently significant should note that this franchise relationship appears to have wound down; no current Israeli retail operations are identified in any available source.

Named Entities and Evidence Map

BDS-1000 Score

The V-MIL, V-DIG, and V-ECON domains each score 0.00 across all three criteria, reflecting comprehensive null findings. The V-POL domain registers a Band 1.5 Impact score (Incidental — generic commercial non-engagement), with Magnitude and Proximity each set to 1.00 (Very Low). The rubric applies these low but non-zero M and P values because the company’s silence is not the same as total abstention from legal existence; it is a deliberate commercial communications posture. However, the frequency, dollar value, and structural proximity of political acts are effectively zero, which keeps the V-Domain score at 0.21.

The composite BRS formula weights V-POL as the maximum domain, adds 20% of the sum of all other domain scores (zero), divides by 16, and multiplies by 1,000, yielding a BRS of approximately 1.94, rounded to 2. This places New Look firmly in Tier E (0–199) — the lowest tier — consistent with a company with no identified material relationship with the Israeli state or its security apparatus.

Confidence, Limits, and Open Questions

Overall confidence: High. The BRS of 2 is assessed with high confidence across three of four domains (V-MIL, V-DIG, V-ECON) and with high confidence in the Incidental band assignment for V-POL. The null findings are the result of a comprehensive multi-source audit, not insufficient investigation.

Residual evidence gaps:

• Sub-Tier-1 supply chain: Tier 2/3 garment supplier networks are not publicly traceable. No Israeli-origin input has been identified, but the absence cannot be formally confirmed at sub-Tier-1 level.
• In-store camera analytics vendor: The specific vendors supplying in-store camera hardware and any associated video analytics layer for New Look’s store estate have not been publicly disclosed. An Israeli-origin analytics system at this layer cannot be confirmed or excluded.
• Blue Yonder and cloud platform sub-vendor chains: Sub-vendor components within the Blue Yonder demand forecasting platform and within New Look’s Azure and GCP tenancies are not publicly disclosed. No adverse finding is indicated, but the chain is unverified.
• ICO breach vendor identity: The cybersecurity vendor in place at the time of the 2020 phishing breach is not named in the ICO’s published Monetary Penalty Notice. Assessed as low-significance to V-DIG scoring.
• Post-2020 capitalisation table: The full beneficial ownership structure at individual fund or LP level is not publicly available. The structural profile of identified owners does not suggest Israeli linkage, but formal exclusion is not possible on public data alone.
• UN and Who Profits database currency: Both databases are subject to continuous update. The audit reflects training-data knowledge through April 2026; a live database check at time of publication is advisable.

Open questions:

1. Have any supplements to the UN HRC A/HRC/43/71 settlements database been issued between 2020 and 2026 that name New Look?
2. Does New Look’s in-store CCTV and loss-prevention infrastructure incorporate any Israeli-origin analytics platform?
3. What is the complete current beneficial ownership at LP level of the bondholder-equity cohort that controls New Look post-2020?
4. Are there any active or historical wholesale agreements supplying Israeli third-party retailers that are not captured in public corporate disclosures?

Recommended Actions

For researchers and civil society organisations: The three highest-value investigative actions — given current evidence gaps — are: (1) a direct request to New Look for disclosure of its in-store security technology vendors; (2) a review of Companies House shareholder register entries for New Look Group Ltd (no. 05399585) to verify the full post-2020 beneficial ownership structure; and (3) a check of live Who Profits and OHCHR settlement database records against New Look at time of publication. These actions could resolve the principal open questions at low investigative cost.

For institutional investors conducting ESG screening: The current BRS of 2 (Tier E) does not provide a basis for exclusion under standard BDS-aligned or conflict-complicity screening frameworks. The null findings across V-MIL, V-DIG, and V-ECON are robust on available evidence. The residual supply chain opacity (Tier 2/3 networks) represents a standard fast-fashion ESG disclosure gap rather than a conflict-specific risk signal. No special monitoring or escalation action is indicated on current evidence. Standard annual review of updated NGO databases and any future Modern Slavery Act statement disclosures would be sufficient maintenance diligence.

For procurement and contracting bodies: No basis has been identified for exclusion or enhanced due diligence of New Look on conflict-complicity grounds. The company presents no documented military, digital, or economic entanglement with the Israeli state or its security apparatus. Standard supplier ethical-trade audit procedures are appropriate.

Score-change triggers to monitor: The BRS of 2 should be reassessed if any of the following are identified in future investigation: (a) a confirmed Israeli-origin vendor in New Look’s technology stack serving surveillance or state-support functions; (b) confirmed Israeli-origin goods at any tier of the supply chain; (c) Israeli beneficial ownership of significance in the post-2020 equity structure; (d) addition of New Look to the UN HRC settlements database or Who Profits database; or (e) any New Look political statement, lobbying activity, or financial contribution connected to the Israel-Palestine conflict.

End Notes