V-ECON Audit — New Look (New Look Retailers Limited / New Look Group)

Audit Phase: V-ECON Target Entity: New Look Retailers Limited (Companies House no. 01618428) / New Look Group (Companies House no. 05399585) Prepared: 2026-05-01 Scope: Economic entanglement assessment covering supply chain, product compliance, capital flows, operational footprint, corporate structure, and profit repatriation.

Supply Chain & Sourcing Relationships

Direct Supplier Relationships

New Look is a UK-based fast-fashion clothing, footwear, and accessories retailer. Its disclosed sourcing markets — Bangladesh, China, Cambodia, India, Turkey, and a range of other Asian and European manufacturing countries — reflect a product base (garments, footwear, fashion accessories) that is structurally incompatible with Israeli agricultural export categories ¹². No verified commercial relationship with Israeli agricultural exporters — including Mehadrin, Hadiklaim, Galilee Export, or any successor entity to Agrexco — has been identified in any corporate disclosure, trade database, or NGO report ³⁴. Product categories such as Medjool dates, avocados, citrus, fresh herbs, and potatoes are absent from New Look’s retail format entirely ¹.

Importer-of-Record Structure

New Look operates its sourcing through New Look Retailers Limited and associated group subsidiaries ⁵. Its Modern Slavery Act statements and responsible sourcing disclosures identify a manufacturing supplier base concentrated in South and Southeast Asia and Turkey, with no reference to Israel or the Occupied Palestinian Territories as a country of origin for any input good ¹². No importer-of-record entity for goods originating in Israel or the Occupied Palestinian Territories has been identified in Companies House filings, Modern Slavery Act statements, or any accessible trade database ⁵².

Seasonal Sourcing Patterns

No public evidence identified of recurring seasonal procurement from Israeli suppliers in any product category. New Look’s seasonal buying cycles relate to fashion apparel collections sourced from the manufacturing markets listed above ¹².

Third-Party & Indirect Sourcing

New Look’s disclosed garment supplier base includes Turkish manufacturers. 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 ¹². The Who Profits Research Centre and Corporate Occupation databases do not list New Look as a company with documented ties to Israeli or settlement-origin supply chains ³⁴. Oxfam’s “Behind the Barcode” supply chain tracker similarly returns no findings relating New Look to Israeli sourcing ⁶. Access to Tier 2/3 supplier audit data (e.g., SEDEX, BSCI) required to fully trace Turkish intermediary networks is not publicly available and constitutes an evidence gap.

Product Origin, Labeling & Regulatory Compliance

Settlement-Origin Products

New Look sells clothing and fashion accessories, not food produce or agricultural goods. DEFRA guidance on the labelling of produce originating from Israeli settlements ⁷ applies to food and horticultural product categories and is not applicable to New Look’s primary retail lines. The Who Profits and Corporate Occupation databases contain no listings for New Look in connection with settlement-origin goods or Israeli agricultural supply chains ³⁴. No NGO investigations, DEFRA citations, or customs audit findings relating to New Look and settlement-origin goods have been identified in any public source.

Labeling Compliance

Country-of-origin labelling for clothing in the UK is governed by HMRC rules separate from DEFRA’s food-produce guidance ⁸. New Look’s disclosed compliance activity addresses Modern Slavery Act obligations and broader ethical trading standards rather than settlement-origin or geopolitical sourcing restrictions ¹². No enforcement actions, government advisories, or regulatory proceedings relating to New Look and Israeli-origin or settlement-origin product labelling have been identified in any public record.

Corporate Labeling Policy

No public evidence identified of a specific corporate policy at New Look addressing sourcing from or labelling of goods originating in occupied or contested territories. New Look’s responsible sourcing statements address labour standards, environmental metrics, and supply chain transparency, with no reference to geopolitical sourcing restrictions ¹². The Ethical Consumer company profile for New Look does not identify settlement-origin product sourcing as a concern ⁹.

Investment, Capital & Financial Exposure

Foreign Direct Investment

No evidence of direct capital investment by New Look within Israel or the Occupied Palestinian Territories — including acquisitions, manufacturing facilities, distribution centres, data infrastructure, logistics hubs, or real estate — has been identified in any corporate filing, annual report, or press disclosure ¹⁰⁵.

R&D & Innovation Centres

No evidence of R&D facilities, technology partnerships, innovation labs, or accelerator programmes operated by or jointly with New Look within Israel has been identified in any available corporate or press source ¹⁰¹.

Parent & Beneficial Ownership Flows

Brait SE (registered in Malta, listed on the Johannesburg Stock Exchange) acquired a majority stake in New Look in 2015 ¹¹¹². Following New Look’s Company Voluntary Arrangement (CVA) and debt restructuring in September 2020, Brait’s equity stake was substantially diluted and operational control passed to the company’s former senior secured bondholders, a group of institutional investors that included funds associated with Goldentree Asset Management and other US- and European-domiciled credit funds ¹³¹⁴. As of the most recent publicly available records (2023–2024), New Look Group is majority-owned by this bondholder-turned-equity cohort ¹⁰¹⁵. The precise current beneficial ownership structure at the individual fund or LP level is not fully disclosed in Companies House persons-of-significant-control filings, which record corporate nominees rather than ultimate natural persons or fund domiciles ¹⁵.

Brait SE is a South African-domiciled investment holding company with no documented operational presence in Israel ¹¹¹². Its declared portfolio — New Look, Virgin Active, and Premier FMCG — contains no Israeli-domiciled entities ¹¹¹². No evidence that Brait SE or the current bondholder-owners hold separate direct investments or subsidiaries within the Israeli economy has been identified ¹¹¹²¹⁶.

Portfolio & Fund Exposure

No public evidence identified of holdings by New Look or its parent or controlling entities in Israeli-domiciled companies, Israeli sovereign bonds, or Israel-focused investment funds. The JSE SENS filings for Brait SE confirm New Look stake disclosures but contain no reference to Israeli financial exposure ¹⁶.

Operational Presence & Market Activity

Physical Footprint

New Look operates retail stores primarily in the United Kingdom and Republic of Ireland. The company previously maintained a store estate in mainland Europe and China; both were substantially or fully exited by 2021 as part of its post-CVA restructuring and strategic reset ¹³¹⁷¹⁸. 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 ^1011718.

Employment & Tax Contribution

No evidence of New Look employing staff, operating a payroll, or holding tax or regulatory registration status within the Israeli jurisdiction has been identified in any public filing or corporate disclosure ¹⁰⁵.

Market Positioning

Israel is not referenced as a market — active, dormant, minor, strategic, or prospective — in any available New Look annual report, investor presentation, trading update, or press release ¹⁰¹¹⁷. New Look does not operate a franchise or wholesale model in the Middle East region. No evidence of wholesale agreements supplying Israeli third-party retailers has been identified, though third-party e-commerce resellers cannot be fully traced from publicly available data alone.

Corporate Structure & Foundational Ties

Founding & Incorporation History

New Look was founded in 1969 in Taunton, Somerset, England, by Tom Singh ¹⁸. The company has no Israeli founding history, no original incorporation in Israel, and no Israeli-origin brand identity. It was incorporated in England and Wales ⁵¹⁸.

Headquarters & Domicile

New Look’s legal domicile and operational headquarters is Weymouth, Dorset, England (registered office: New Look House, Mercery Road, Weymouth) ⁵. No dual or legacy headquarters in Israel exists ⁵¹⁸.

State & Institutional Linkages

No state ownership stakes, Israeli government board appointees, government contracts with Israeli state entities, or designation as critical national infrastructure in Israel have been identified in any Companies House filing, annual report, or public disclosure ¹⁰¹⁵. No public evidence identified.

Structural Governance Features

No golden shares, founder shares, or charter restrictions tying New Look’s operations or mission to the Israeli state or its policy objectives have been identified in Companies House filings or published corporate governance disclosures ¹⁰⁵¹⁵. The post-2020 corporate structure reflects a standard UK private-equity-held retail group governed under English company law, with bondholders holding equity via a standard holding-company layer ¹³¹⁴¹⁵.

BDS & Advocacy Designations

The BDS National Committee’s retail-sector campaign material does not identify New Look as a named campaign target ¹⁹. Ethical Consumer’s company profile for New Look does not cite Israeli economic entanglement as a rated concern ⁹.

Profit Repatriation & Economic Contribution

Revenue Attribution

No revenue attributed to Israel as a market has been disclosed in any available New Look financial filing or trading update. Israel is not identified as a revenue territory, customer geography, or commercial opportunity in any annual report, investor communication, or analyst briefing ¹⁰¹⁷.

Profit Flows

Where profits are generated, they flow outward from UK retail operations to New Look Group’s holding structure and ultimately to its bondholder-equity owners — primarily US- and European-domiciled institutional credit funds — and, residually, to Brait SE (South Africa-listed, Malta-registered) ^11121314. No profit flow into or from the Israeli economy has been identified in any public financial record or press account. HMRC UK trade statistics and UKTradeInfo data do not identify New Look as a significant bilateral trade participant with Israel in either direction ²⁰.

Economic Ecosystem Role

No publicly available assessment, industry report, or government designation characterises New Look as significant within any sector of the Israeli economy. No public evidence identified.

End Notes