ASOS ECONOMIC

Supply Chain & Sourcing Relationships

• ASOS states that its retail buying team operates a sourcing strategy and is not expanding goods-for-resale supplier contacts, while its public supply-chain materials do not identify Israeli suppliers or an Israeli sourcing entity.^{1, 2}

• ASOS’s own-brand supplier code requires legal and responsible-sourcing standards, but does not set out an Israel- or occupied-territory-specific sourcing rule.²

• No public evidence identified of direct sourcing from Mehadrin, Hadiklaim, Galilee Export, Agrexco successors, or other named Israeli agricultural suppliers; recurring counter-seasonal procurement; indirect Israeli-origin sourcing through distributors or resellers; named Israeli agricultural exporters; seasonal Israeli produce sourcing; Israeli-origin white-label goods; or an ASOS-owned Israeli importer-of-record, joint venture, or dedicated import entity.^{1, 2, 3}

• ASOS’s Israel delivery and returns materials provide consumer shipping and returns terms, but do not identify the importer of record, customs declarant, local logistics entity, delivery carrier, customs broker, distributor, local warehouse, or returns provider.^{4, 3, 5}

• Israel Tax Authority guidance describes personal parcel and courier imports, including clearance by Israel Post or a shipping company, but does not identify ASOS as importer of record or allocate that status for ASOS-bound parcels.⁶

Product Origin, Labeling & Regulatory Compliance

• No public evidence identified of ASOS settlement-origin products, “Produce of Israel” labelling issues, customs or DEFRA enforcement, or an ASOS policy specifically addressing products from occupied territories.^{1, 2}

• No public evidence identified of a territory-specific corporate policy governing sourcing or origin labelling for Israel, the West Bank, East Jerusalem, or the Golan Heights.^{1, 2}

• ASOS’s supplier code requires suppliers to meet legal and responsible-sourcing standards, but the examined document does not prescribe a territory-specific Israel/OPT product-origin or labelling rule.²

• The available Israel delivery material is country-level and does not establish whether ASOS serves all postal areas, including settlements in the West Bank, East Jerusalem, or the Golan Heights.^{4, 3, 5, 7}

• ASOS’s country selector displayed no delivery options for “Palestine” when accessed in September 2026; this does not establish delivery availability for any particular address when “Israel” is selected.⁷

Investment, Capital & Financial Exposure

• In March/April 2018, ASOS entered a reported collaboration with Tel Aviv-based Zeekit Online Shopping Ltd. involving virtual-fitting technology in ASOS’s app that displayed garments on models with different body types.^{8, 9}

• Contemporaneous reporting stated that Zeekit confirmed the collaboration to CTech, while a separate report described a strategic cooperation agreement.^{8, 9}

• The publicly available reporting does not establish the arrangement’s value, duration, payments, ownership interest, current status, or any successor relationship.^{8, 9}

• No public evidence identified that the Zeekit relationship continued after July 2024 or November 2024.^{8, 9}

• No public evidence identified of ASOS acquiring an Israeli operating company, holding a controlling stake in one, operating Israeli factories, data centres, R&D centres, or logistics hubs, or holding Israeli sovereign bonds, Israel Bonds, Israel-focused investments, or Israeli real estate.^{10, 11, 3}

• The FY2025 related-undertakings schedule lists controlled entities incorporated in the UK, United States, Germany, France, Australia, Canada, China, the Netherlands, and Jersey, plus minority interests of 7.2% in Needle and Thread Design Holdings Limited and 2.9% in Action Artificial Intelligence Limited; it identifies no Israeli-incorporated group undertaking or Israeli operating subsidiary as at 31 August 2025.³

• William Barker’s reported external appointments include Camelot Capital Partners LLC, Tapi Carpets & Floors Limited, Synnovia Limited, Re:Build Manufacturing LLC, and Slate Auto; the FY2025 disclosure does not identify an Israeli company, Israeli sovereign-financing role, or settlement-linked enterprise among them.³

• A public offer document confirms Camelot/Barker Partnership investment activity in UK industrial business Synnovia, but provides no evidence of an Israeli company, Israeli sovereign financing, settlement-linked enterprise, or Israel-related investment.¹²

• No public evidence identified in targeted searches and reviewed corporate records of material personal or family-office investments, acquisitions, controlled vehicles, Israeli sovereign financing, Israel Bonds activity, or settlement-linked enterprise holdings by Nick Robertson, William Barker/Camelot, or serving ASOS directors and executives.^{13, 3, 14, 12}

• This conclusion is search- and disclosure-scoped: the FY2025 report discloses ASOS share interests and certain external appointments, rather than a comprehensive register of every director’s private investments.³

• Camelot Capital Partners LLC filed SEC Form 13F-HR reports through the quarter ended 30 June 2025, but the underlying information-table attachment was not independently retrievable in the reviewed material; it therefore neither confirms nor disproves an Israeli holding here.^{15, 16}

• ASOS disclosed substantial shareholders known to it at 30 October 2025 as Aktieselskabet af 5.5.2010 (29.01%), Frasers Group plc (21.92%), Camelot Partners LLC (15.39%), and Schroders plc (5.16%); the disclosure identifies no Israeli beneficial owner, Israeli state stake, or Israeli controlling shareholder.³

• The FY2025 report records beneficial ASOS holdings of 18,390,264 shares for William Barker, 2,636,025 for Nick Robertson, 26,538 for José Antonio Ramos Calamonte, and 5,809 for Aaron Izzard as at 31 August 2025, and states that no director had a material interest in a significant contract with ASOS or its subsidiaries during the period.³

• A 24 August 2026 notification records Frasers Group plc with 23.368102% direct voting rights and financial instruments representing a further 4.172875% potential voting rights, identifying Michael Ashley as ultimate controlling person.¹⁷

• A 14 September 2026 notification records The Goldman Sachs Group Inc. with a total notified ASOS position of 3.054092%, principally through securities lending; this does not establish an Israeli beneficial owner or Israeli control of ASOS.¹⁸

Operational Presence & Market Activity

• ASOS currently presents Israel as a delivery destination and offers standard delivery on its Israel-specific customer-service page, supporting cross-border consumer sales availability.⁴

• As accessed in September 2026, ASOS’s Israel-specific delivery page offered standard delivery for £9.53, free above £38.11, with a stated delivery date, and its Israel returns page stated “Return From: Israel.”^{3, 5}

• These current pages establish continuing country-level direct consumer-sales availability and a return process as of September 2026, but do not quantify Israeli sales, orders, revenue, customers, or returns volume.^{3, 5}

• The delivery page does not establish a physical Israeli office, warehouse, retail store, employee base, local tax registration, or settlement-delivery coverage.⁴

• In 2022, ASOS reported delivery lead-time constraints “particularly to Australia and Israel,” which evidences then-current Israel delivery operations but does not disclose Israel-only sales or volumes.¹⁹

• In 2019, ASOS reported launching local currencies in Israel, Saudi Arabia, and the UAE; this confirms an Israel-directed customer-proposition change but does not identify a local entity or disclose Israel-only sales.²⁰

• ASOS reported in FY2021 that sales growth in Israel was strong and that Israel represented an increasingly significant proportion of its Rest of World segment.¹¹

• The FY2021 report does not disclose Israel-only revenue, orders, customer numbers, workforce, tax paid, subsidiaries, warehouses, or investment figures, and it does not establish whether the reported market characterisation continued after FY2021.¹¹

• FY2025 reports one operating segment and discloses revenue only for the UK (£1,211.8m), EU (£819.3m), US (£257.7m), and Rest of World (£189.0m), totalling £2,477.8m; Israel is not separately reported.³

• FY2025 identifies Barnsley, UK and Berlin, Germany as distribution centres and Dallas, Texas as a returns centre, but does not identify an ASOS-managed warehouse, returns centre, or other site in Israel or occupied territory.³

• No public evidence identified of ASOS-operated offices, support centres, warehouses, retail sites, workforce figures, tax registration, or a controlled local importer in Israel or the occupied territories.^{10, 11, 4, 3}

• No public evidence identified of Israel-specific volume or sales disclosures, local importer arrangements, a settlement-delivery exclusion policy, or a specific settlement delivery.^{4, 6, 3, 5, 7}

Corporate Structure & Foundational Ties

• ASOS plc is an active English public limited company, number 04006623, incorporated on 2 June 2000 and registered at Greater London House, Hampstead Road, London, NW1 7FB.¹⁰

• ASOS’s registered SIC activity is “Activities of head offices,” and its predecessor names were Winsupply Public Limited Company and AsSeenOnScreen Holdings plc.¹⁰

• ASOS.com Limited is a UK private company whose PSC register identifies ASOS Intermediate Holdings Limited as holding at least 75% of shares and voting rights, with the right to appoint or remove directors.²¹

• ASOS plc’s PSC information is unavailable because its voting shares have been admitted to trading on a UK regulated market since 6 July 2018, making it exempt from the PSC-information requirement.²²

• ASOS reported 119,821,456 issued ordinary shares as of 1 December 2025, each with equal voting rights and no transfer restrictions.²³

• ASOS’s current board comprises Natasja Laheij (Chair), William Barker (Deputy Chair), José Antonio Ramos Calamonte (CEO), Aaron Izzard (CFO), José Manuel Martínez Gutiérrez (Senior Independent Director), Christine Cross, Wei Gao, Marie Gulin-Merle, Jon Kamaluddin, Nick Robertson, and Anna Maria Rugarli as non-executive directors, with Rishi Sharma as General Counsel and Company Secretary.¹³

• ASOS states that its Board is responsible for the long-term success of ASOS, its subsidiaries, and all its businesses, and identifies Audit, Nomination, Remuneration, and Sustainability committees.²⁴

• The FY2025 schedule identifies ASOS Germany GmbH as employer of Germany-based supply-chain staff, ASOS US, Inc. as employer of US marketing staff, payment-processing entities in France, Australia, the United States, UK and Netherlands, and discontinued ASOS (Shanghai) Commerce Co. Limited; none is described as Israeli or as operating from the occupied Palestinian territory or Golan Heights.³

• No public evidence identified that ASOS was founded in Israel, is Israeli-tax-resident, holds Israeli Preferred Technology Enterprise status, is Israeli-controlled, maintains an Israeli headquarters, or has Israeli state ownership or government appointees.^{10, 13, 11, 3}

• No public evidence identified of Israeli government contracts, critical-infrastructure designation, golden shares, founder-share arrangements, or governance mechanisms structurally linking ASOS to the Israeli state.^{10, 13, 11, 3}

Profit Repatriation & Economic Contribution

• ASOS disclosed Israel within its aggregate Rest of World segment in FY2021 rather than as a separately quantified market.¹¹

• Israeli revenue, profit, tax paid, customer volume, and economic contribution are not publicly stated in the examined FY2021 annual report.¹¹

• FY2025 continues to aggregate any Israel-related activity, if included, within Rest of World and does not separately report Israel-only revenue, GMV, orders, tax, profit, customers, workforce, or profitability.³

• No public evidence identified of profits flowing to Israel through Israeli domicile or ownership, or of disclosed Israeli-market profit repatriation to ASOS’s UK group.^{10, 11, 3}

• No public evidence identified of a public government or industry designation characterising ASOS as a key Israeli employer, sector anchor, or infrastructure provider.^{10, 11, 3}