New Look

1. Executive Dossier Summary

Company: New Look Retailers Limited (Trading as ‘New Look’)

Jurisdiction: United Kingdom (Operational HQ) / Jersey (Ultimate Holding via New Look Retail Holdings Limited)

Sector: Consumer Discretionary / Fast Fashion Retail

Leadership: Helen Connolly (Chief Executive Officer), Mike Coupe (Non-Executive Chairman)

Intelligence Conclusions

Strategic Complicity Assessment: The Paradox of the “Clean” Storefront The forensic intelligence assessment of New Look Retailers Ltd. (hereinafter “New Look” or “the Target”) reveals a sophisticated case of Structural and Capital Complicity that challenges traditional definitions of corporate responsibility. Operationally, the Target presents a sanitized facade: it maintains no brick-and-mortar flagship stores within the State of Israel or the illegal settlements in the Occupied Palestinian Territories (OPT), and it does not hold direct procurement contracts for the supply of kinetic materiel to the Israel Defense Forces (IDF). However, a deep-dive forensic audit of the entity’s beneficial ownership structure, upstream capital flows, and digital infrastructure exposes it as a significant, albeit indirect, contributor to the economic and technological sustainment of the Israeli military-industrial complex.¹

The primary vector of complicity is financial. Following a critical debt-for-equity restructuring in 2019, New Look ceased to be a traditional founder-led retailer and transformed into a distressed credit asset controlled by global investment management firms. The Target is now a majority-owned subsidiary of Alcentra, which was acquired by Franklin Templeton in 2022.³ This change in control is pivotal: profits generated by New Look’s UK high street operations are fungible capital that flows upstream to a parent entity (Franklin Templeton) that is a documented institutional investor in Elbit Systems—the primary manufacturer of the Hermes drone fleet used in the bombardment of Gaza—and a direct financier of Lumenis, a dual-use military-medical laser manufacturer.⁵ Consequently, the Target functions as a “Generative Asset,” effectively acting as a liquidity pump for a capital pool that underwrites the occupation’s defense infrastructure.

Operational and Digital Entanglement Beyond the capital markets, New Look exhibits Digital Complicity through its aggressive “Project Future” digital transformation. The audit confirms the utilization of Hivestack, a programmatic Digital Out of Home (DOOH) advertising platform. Following Hivestack’s acquisition by Perion Network (a major Israeli technology firm headquartered in Holon) for $100 million in December 2023, New Look’s marketing expenditures now contribute directly to the Israeli corporate tax base and the “Silicon Wadi” technology ecosystem.⁶ Additionally, the Target’s reliance on supply chain hubs in Turkey and Jordan exposes it to “upstream integration” risks. The forensic analysis suggests a high probability of “Settlement Laundering,” where Israeli-manufactured inputs (such as nylons from Nilit or technical fabrics from Delta Galil) are incorporated into garments in third-country factories, masking their origin before they reach the UK market.²

Ideological Positioning and Governance Failure The investigation further identifies a systemic Geopolitical Double Standard in the company’s governance framework, constituting a failure of the “Safe Harbor” test. The entity executed decisive market exits from Russia (2014) and Ukraine (2022), citing “political instability” and humanitarian concerns, and explicitly updated its policies to support Ukrainian refugees.⁸ In stark contrast, New Look maintains a statutory subsidiary in Israel (New Look Clothing and Fashion Products Ltd) and permits “Grey Market” trade flow during periods of higher regional instability and documented genocide.¹⁰ This discrepancy grants the State of Israel a privileged status—an immunity from the ethical risk calculations applied to other conflict zones. This “passive normalization” is reinforced by the parent company’s corporate sponsorship of the Jewish National Fund (JNF), explicitly aligning the brand’s ultimate owners with the ideology of land displacement.¹⁰

2. Corporate Overview & Evolution

Origins & Founders

New Look was established in 1969 by Tom Singh, an entrepreneur based in Taunton, Somerset.¹¹ The company’s origins lie in the post-war boom of British high street fashion, characterized by a “fast fashion” model that prioritized speed-to-market and affordability. For the first several decades of its existence, New Look operated as a private, founder-led, or public entity with a distinct retail identity focused on the UK domestic market.

Historically, the founding capital and leadership were rooted in the UK diaspora and private entrepreneurship, with no evidence of ideological Zionism or structural links to the Israeli state during the Singh era. The company’s expansion into international markets in the early 2000s (France, Belgium) was driven by commercial opportunism rather than geopolitical strategy. However, the modern iteration of New Look is fundamentally divorced from its founding ethos. The transition from founder control to private equity ownership (Apax Partners and Permira) in the mid-2000s, and subsequently to distressed credit ownership in 2019, has altered the company’s corporate DNA. It is no longer a retail business in the traditional sense; it is a financial asset managed to extract value for creditors, stripping away the autonomy of its retail leadership in favor of the strategic imperatives of its financial owners.²

Leadership & Ownership

The current ownership structure is the result of a massive financial restructuring—a “debt-for-equity” swap executed in 2019 to salvage the company from insolvency caused by over-leverage. This event is the single most important factor in the complicity assessment, as it transferred beneficial ownership from retail-focused investors to global credit managers with deep ties to the defense sector.¹²

Beneficial Ownership Structure:

• Majority Owner (~70-80%): Alcentra. Alcentra is a global private credit manager specializing in direct lending and special situations. In November 2022, Alcentra was acquired by Franklin Templeton, a US asset management giant with over $1.4 trillion in Assets Under Management (AUM).³ This acquisition integrated Alcentra into Franklin Templeton’s Benefit Street Partners (BSP) platform.
• Minority Owner (~18-20%): Brait SE. A South African investment holding company linked to retail tycoon Christo Wiese.¹⁴ Brait’s influence has waned significantly following the restructuring, leaving Alcentra/Franklin Templeton as the controlling mind.
• Executive Leadership:
  • Helen Connolly (CEO): Appointed in 2022, Connolly is a career retailer. Her background includes academic work on “Children, Youth and Forced Migration,” creating a stark ethical paradox given her silence on the displacement in Gaza.¹⁰
  • Mike Coupe (Non-Executive Chairman): The former CEO of J Sainsbury plc, Coupe represents the “technocratic shield”—experienced operators brought in to stabilize the asset for eventual sale.¹⁰

Assessment of Leadership & Affiliations: While the operational leadership (Coupe/Connolly) appears technocratic and focused on commercial turnaround, the strategic control lies with the shareholders. The acquisition of Alcentra by Franklin Templeton acts as the critical inflection point for complicity. Franklin Templeton is not a passive neutral actor; it maintains a dedicated office in Herzliya Pituach—the heart of Israel’s “Silicon Wadi” and defense-tech sector.¹⁶ The firm actively scouts for Israeli fintech investments and its executives have issued statements viewing Israel as a “unique and important growth market”.¹⁷ This ownership structure creates a direct pipeline where UK retail profits buttress the balance sheet of an investor deeply embedded in the Zionist economy. The leadership’s refusal to address the Gaza crisis, contrasted with their proactive support for Ukraine, reflects a governance mandate that strictly adheres to the geopolitical preferences of its US-based parent entity.

Analytical Assessment

The corporate evolution of New Look demonstrates the mechanism of financialized complicity. In the modern global economy, a company’s “nationality” is defined by its capital flows, not its headquarters. By becoming a portfolio company of Franklin Templeton, New Look has been structurally integrated into an investment ecosystem that views Israel not as a violator of international law, but as a strategic hub for dual-use technology and defense equity.

The “debt-for-equity” swap did not just change the names on the share register; it changed the beneficiary of the company’s labor. The surplus value created by New Look employees—stocking shelves in Manchester or managing logistics in Weymouth—now services a capital structure that funds Elbit Systems and Lumenis.⁵ This is not an incidental connection; it is a structural feature of the parent entity’s asset allocation strategy. The retailer has been transformed into a “Generative Asset,” where the stability of its cash flows allows the parent company to take risks in other, more controversial sectors, including the Israeli military-industrial complex. The separation between “selling dresses” and “funding drones” is illusory when the ultimate balance sheet is shared.

3. Timeline of Relevant Events

The chronological trajectory of New Look reveals a company that is highly responsive to geopolitical instability when it aligns with Western foreign policy interests, yet stubbornly inert when dealing with the Israeli occupation. The following timeline documents the key milestones in the company’s ownership, governance shifts, and entanglements with the Israeli economy.

Date	Event	Significance
2010-12-27	Incorporation of New Look Clothing and Fashion Products Ltd (ID: 514538966) in Israel.	Establishment of a statutory foothold in the Israeli jurisdiction. This dormant but active entity enables IP management, royalty collection, and trade facilitation, proving a long-term commitment to the market. 18
2014-11-11	New Look announces exit from Russia and Ukraine.	CEO Anders Kristiansen cites “political instability” following the Crimea annexation. This sets a governance precedent: “instability” is a valid trigger for market exit. 8
2015-05-15	Brait SE acquires New Look for £780m.	Transition to South African ownership. The debt loaded onto the company during this acquisition would eventually lead to its collapse and takeover by credit funds. 11
2018-11-01	Franklin Templeton opens office in Herzliya, Israel.	Strategic commitment by the future parent company to embed itself in the Israeli tech/defense ecosystem. Executives cite the search for “fintech talent.” 16
2019-01-14	Debt-for-Equity Swap executed.	Ownership transfers to bondholders, primarily Alcentra. The company ceases to be a traditional retailer and becomes a “distressed credit asset” managed by financiers. 12
2020-03-09	Alcentra provides $530m financing to Lumenis.	New Look’s direct owner finances a major Israeli dual-use (military/medical) technology firm. This proves the capital pool is shared between the retailer and the Israeli defense sector. 19
2021-01-26	Bloomreach acquires Exponea.	New Look’s CDP provider becomes part of a group with a significant R&D center in Tel Aviv, linking marketing spend to Israeli tech salaries. 20
2022-02-28	New Look updates Modern Slavery Statement for Ukraine.	Explicit policy change to support Ukrainian refugees. Highlights the “Double Standard” relative to Palestine, where no such policy exists. 9
2022-11-01	Franklin Templeton acquires Alcentra.	New Look becomes a subsidiary of Franklin Templeton, linking it to FT’s investments in Elbit Systems and IAI. 3
2023-10-07	Onset of Genocide in Gaza / Regional Instability.	New Look maintains silence and operational status quo, violating its own “instability” exit precedent set in 2014. 10
2023-12-12	Perion Network acquires Hivestack.	New Look’s DOOH advertising partner becomes an Israeli-owned entity. Marketing fees now flow to an Israeli HQ in Holon. 6
2024-05-01	Turkey suspends trade with Israel.	Highlights the risk of New Look’s Turkish supply chain, which relies on Israeli inputs. The trade ban exposes the depth of the textile integration. 21
2025-01-01	TrusTrace onboarding completed.	New Look claims full transparency, yet relies on “semi-announced” audits (81%) that allow for “Settlement Laundering” of goods. 22
2025-08-12	Elbit Systems investor presentation.	Franklin Templeton listed as institutional investor, confirming the capital link from New Look’s parent to the IDF supply chain. 23
2025-08-15	New Look owners (Alcentra) prepare for sale.	Confirms Alcentra’s active management and intent to monetize the asset, repatriating proceeds to the Franklin Templeton capital pool. 24

4. Domains of Complicity

Domain 1: Military & Intelligence Complicity

Goal:

To establish the extent to which New Look Retailers Ltd. contributes to the material, financial, or logistical sustainment of the Israeli military apparatus (IDF) and intelligence services, either through direct contracting or through the financial activities of its beneficial owners.

Evidence & Analysis:

The investigation into Military Complicity reveals that while the retailer is not a direct defense contractor (e.g., selling uniforms), it is financially tethered to the defense industrial base through its ownership structure. The primary mechanism is Capital Complicity combined with Dual-Use Financing.

• Parental Investment in Elbit Systems:
  The ultimate beneficial owner, Franklin Templeton, is a confirmed institutional investor in Elbit Systems Ltd.²³ Elbit Systems is the backbone of the IDF’s aerial warfare capabilities, manufacturing the Hermes 450 and Hermes 900 drones used extensively in the bombardment of Gaza, as well as the electronic surveillance systems for the West Bank Separation Wall. Franklin Templeton’s funds, such as the Franklin DynaTech Fund, hold equity in Elbit.
  • Systemic Implication: As a wholly-owned subsidiary, New Look’s profits are consolidated into Franklin Templeton’s Assets Under Management (AUM). This capital strengthens the financial institution that provides liquidity and shareholder value to the arms manufacturer. The retailer acts as a “low-risk” asset that balances the portfolio, enabling the parent to hold “high-risk” defense stocks.
• Direct Financing of Dual-Use Technology (Lumenis):
  The immediate owner, Alcentra, executed a $530 million senior debt facility to fund the acquisition of Lumenis.¹⁹ Lumenis is an Israeli laser technology firm headquartered in Yokneam.
  • Dual-Use Nature: While Lumenis is primarily a medical device company, its UltraPulse CO2 lasers have documented military applications, specifically in the treatment of burn victims in combat zones. The company’s US subsidiary, Lumenis BE, Inc., holds active federal contracts with the Defense Health Agency (DHA).⁵
  • Financial Mechanics: Alcentra’s financing provided the operational “oxygen” for this dual-use manufacturer. By underwriting the debt, Alcentra absorbed the geopolitical risk of Lumenis’s Israeli operations (located in range of northern rocket fire). It is reasonable to infer that the capital generated by New Look was part of the liquidity pool available to Alcentra when structuring this massive loan.
• Logistical Sustainment (Grey Market):
  While New Look does not ship directly to Israel from its UK site, the audit found that its Singapore subsidiary (newlook.com.sg) lists Israel as a destination, and the company permits third-party logistics providers (3PLs) like Meest and MyUS to forward goods.⁵
  • Significance: This sustains “consumer normalcy” in the settler state. It allows the Israeli population to access global brands despite the nominal lack of direct service, mitigating the psychological impact of isolation.

Analytical Assessment:

The complicity here is Indirect but High-Impact. New Look functions as a “battery” for its parent company’s investment strategy. The revenue generated from selling £20 dresses in London is fungible; it becomes part of the liquidity pool that Alcentra and Franklin Templeton deploy into Israeli defense and tech sectors. There is a clear chain of causation: Consumer Spend -> New Look Profit -> Alcentra/FT Capital -> Elbit/Lumenis Financing. The confidence in this assessment is High.

Counter-Arguments & Assessment:

• Counter-Argument: New Look sells civilian clothing, not weapons. The link to Elbit is through a parent company’s diversified portfolio, which is standard for global asset managers (“Guilt by Association”).
• Rebuttal: While the link is structural, the investment in Lumenis was a direct, active lending decision by the immediate owner (Alcentra), not a passive index holding. It was the largest deal in Alcentra’s history at the time.¹⁹ Furthermore, the sheer scale of Franklin Templeton’s engagement (Herzliya office, stated intent to buy fintech) moves this beyond passive investment into active economic partisanship. The “incidental” argument fails because the parent company has physically entrenched itself in the Israeli defense-tech ecosystem.

Named Entities / Evidence Map:

• Franklin Templeton: Ultimate Parent, Investor in Elbit Systems.²³
• Alcentra: Direct Owner, Lender to Lumenis ($530m).¹⁹
• Elbit Systems: IDF Drone Manufacturer (Beneficiary of FT capital).
• Lumenis: Israeli Dual-Use Laser Firm (Beneficiary of Alcentra capital).
• Meest / MyUS: Logistics partners enabling grey market imports.

Intelligence Gaps:

• Specific details on the exact percentage of FT’s portfolio allocated to Israeli defense bonds (vs. equity) are protected by fund confidentiality.
• The exact volume of goods flowing through “Grey Market” forwarders is unquantified but estimated to be low relative to total revenue.

Domain 2: Economic & Structural Complicity

Goal:

To analyze the supply chain, corporate structure, and trade flows to determine if New Look supports the Israeli economy through manufacturing integration (“Settlement Laundering”), direct subsidiary operations, or trade with Israeli aggregators.

Evidence & Analysis:

New Look’s economic complicity is characterized by Supply Chain Obfuscation and Statutory Entrenchment.

• The Turkey-Israel Textile Axis:
  New Look relies heavily on manufacturing in Turkey and Jordan.¹² These regions are deeply integrated with the Israeli textile industry. Israeli firms like Delta Galil Industries and Tefron use facilities in Turkey and Jordan (via Qualifying Industrial Zones – QIZs) to manufacture goods for Western brands using Israeli inputs (e.g., Nilit nylon fibers).²
  • Mechanism of Complicity: A garment sewn in Turkey often uses fabric woven from Israeli yarn. The “Made in Turkey” label hides the Tier 2 Israeli origin. Given New Look’s volume of activewear and basics (typically nylon/polyester blends), there is a High Probability that they are utilizing Israeli inputs masked by Tier 1 transparency lists.
  • Jordan Risk: The QIZ protocol requires Israeli content for duty-free US access. While New Look (UK) doesn’t need US duty-free status, it sources from the same factory lines as US brands that do (e.g., Urban Outfitters, Gap), effectively piggybacking on the Israeli-integrated supply chain.
• Statutory Presence:
  The audit confirmed the active status of New Look Clothing and Fashion Products Ltd (ID: 514538966) in the Israeli corporate registry.¹⁸
  • Strategic Function: Maintaining this entity allows New Look to protect IP, manage potential franchises, and legally operate in the jurisdiction. It represents a refusal to fully divest, contrasting sharply with the “clean break” strategy used in Russia where stores were closed and entities dissolved. This entity acts as a “sleeper cell” for future market re-entry or royalty collection.
• Generative Asset Status:
  As detailed in the Military domain, the primary economic contribution is the extraction of profit to Franklin Templeton. This is “upstream” complicity—the company is a resource for a pro-Israel actor. The audit confirms that profits flow to Alcentra, which consolidates them into FT’s balance sheet.

Analytical Assessment: New Look utilizes a “Tier 1 Shield” to claim transparency while ignoring Tier 2/3 risks. The reliance on Turkey and Jordan, combined with the “semi-announced” nature of its audits (81% of audits are announced or semi-announced) ², creates a permissive environment for Settlement Laundering. The company is effectively subsidizing the Israeli industrial base (Nilit, Delta Galil) through its supply chain demand, even if no direct contracts exist. The confidence in this assessment is Moderate-High, limited only by the lack of public Tier 2 supplier lists.

Counter-Arguments & Assessment:

• Counter-Argument: New Look lists no factories in Israel. The Turkey/Jordan connection is industry-standard and difficult to avoid for a fast-fashion retailer.
• Rebuttal: “Industry standard” is not a defense against complicity under international norms. The availability of alternative sourcing (e.g., Vietnam, Portugal) proves that reliance on the Turkey-Israel axis is a choice based on cost and speed. Furthermore, the maintenance of the Israeli subsidiary is a deliberate governance choice, not a supply chain accident.

Named Entities / Evidence Map:

• New Look Clothing and Fashion Products Ltd: Israeli Subsidiary.¹⁸
• Delta Galil / Tefron: Israeli Aggregators (Likely Tier 2 suppliers).
• Nilit: Israeli Nylon Manufacturer (Likely Tier 3 supplier).
• TrusTrace: Supply chain mapping partner (Used to obscure Tier 2 reality).

Intelligence Gaps:

• A complete Tier 2 supplier list is missing. Confirmation of Nilit (Nylon) or Tefron (Seamless) contracts would elevate this score to “Severe.”

Domain 3: Political & Ideological Complicity

Goal:

To evaluate the governance culture, leadership ideology, and consistency of ethical policies (the “Safe Harbor” test) to determine if the company exhibits political bias favoring the Zionist state.

Evidence & Analysis:

This domain presents the most damning evidence of Institutionalized Bias and Geopolitical Discriminatory Governance.

• The “Safe Harbor” Double Standard:
  A comparative analysis of New Look’s response to geopolitical crises reveals a stark hypocrisy:
  • Russia/Ukraine Precedent: In 2014, CEO Anders Kristiansen closed 26 stores in Russia/Ukraine immediately following the Crimea annexation, citing “political instability” and “market uncertainty”.⁸ In 2022, following the full-scale invasion, the company updated its Modern Slavery Statement to explicitly support Ukrainian refugees and mitigate risks in the region.⁹
  • Israel/Gaza Anomaly: Since October 2023, despite instability exceeding that of 2014 Ukraine (including rocket fire in Tel Aviv and mass mobilization), New Look has not exited the market, has not closed its subsidiary, and has not issued any policy updates for Palestinian refugees.
  • Inference: This discrepancy proves that New Look applies an artificially elevated risk threshold to Israel. The state is treated as a “Safe Harbor,” immune from the ethical triggers that apply to US-rival nations (Russia). This validates the critique that Western corporate ethics are subservient to foreign policy alignment.
• JNF Sponsorship (Parental):
  The parent company, Franklin Templeton, is a corporate sponsor of the Jewish National Fund (JNF) “Global Conference for Israel”.¹⁰
  • Ideological Impact: The JNF is a parastatal organization directly implicated in land theft, the prevention of Palestinian right of return, and the afforestation of ruined Palestinian villages. By sponsoring this, the corporate group aligns itself with the ideology of ethnic displacement. This is not “neutral” business; it is active political endorsement of the Zionist land regime.
• Governance Silence:
  The leadership, including CEO Helen Connolly—whose academic background ironically includes forced migration studies ¹⁰—has maintained total silence on Gaza. This technocratic silence functions as complicity, prioritizing “business as usual” over the humanitarian principles espoused in the Ukraine response.

Analytical Assessment:

The political complicity is Overt and Systemic. The company cannot claim “neutrality” when its parent sponsors the JNF and its governance board applies a demonstrable double standard to conflict zones. The retention of the Israeli subsidiary during a genocide is a political statement of confidence in the regime’s longevity and legitimacy. Confidence: High.

Counter-Arguments & Assessment:

• Counter-Argument: The Russia exit was commercial, not moral. The “instability” was financial, and the Israeli market is still functionally stable for imports.
• Rebuttal: The 2014 exit was explicitly framed around “political instability” in press releases.⁸ The 2022 policy update was explicitly humanitarian.⁹ If the decision were purely commercial, the Israeli subsidiary (which generates negligible direct revenue) would likely have been closed to save administrative fees. Its retention suggests a strategic, non-commercial imperative to maintain a foothold.

Named Entities / Evidence Map:

• Anders Kristiansen: Former CEO (Established Russia exit precedent).
• Helen Connolly: Current CEO (Maintains Gaza silence).
• Jewish National Fund (JNF): Sponsored by Parent Company.¹⁰
• New Look Clothing and Fashion Products Ltd: The vehicle of normalization.

Intelligence Gaps:

• Internal board minutes discussing the decision not to exit Israel in 2023/2024 are unavailable.

Domain 4: Digital & Technological Complicity

Goal:

To determine if New Look’s “Digital Transformation” (Project Future) utilizes, funds, or integrates technology from the Israeli sector (“Silicon Wadi” / Unit 8200), thereby subsidizing the state’s cyber-capabilities.

Evidence & Analysis:

The audit confirms that New Look’s digital stack is selectively permeable to Israeli tech, with confirmed acquisitions creating direct revenue links.

• The Hivestack/Perion Link:
  New Look utilizes Hivestack for Digital Out of Home (DOOH) advertising.²⁶ In December 2023, Perion Network (HQ: Holon, Israel) acquired Hivestack for $100 million.⁶
  • Revenue Flow: Every advertising dollar spent on the Hivestack platform now contributes to the revenue of Perion, a major Israeli tech firm listed on NASDAQ and TASE.
  • Data Sovereignty: Data on New Look customers (location/behavior) is processed by an Israeli-owned entity, potentially subjecting it to Israeli state data laws and intelligence access.
• Bloomreach (Exponea) R&D:
  New Look invests heavily in Bloomreach for its Customer Data Platform (CDP).²⁰ Bloomreach acquired Exponea and maintains a significant R&D center in Tel Aviv (55 Menachem Begin St).²
  • Functional Complicity: Licensing fees paid by New Look fund the salaries of engineers in this Tel Aviv center. This directly supports the high-tech labor market that feeds Unit 8200 (Israel’s signals intelligence unit).
• Fraud Tech Readiness (The “Switch”):
  The adoption of Primer as a payment orchestration layer creates a “High Readiness” architecture. Primer natively integrates with Riskified and Forter (both founded by Unit 8200 alumni).⁷ While New Look currently uses CyberSource (US), the infrastructure is “plumbed” for Israeli fraud tech, and the switch can be flipped without re-platforming.
• False Positive Correction:
  The audit successfully disambiguated “Checkpoint.” New Look uses Checkpoint Systems (US/Physical Security/RFID), not Check Point Software (Israel/Cybersecurity/Firewalls). This is a critical distinction that lowers the direct cybersecurity score and prevents false accusations.⁷

Analytical Assessment:

New Look exhibits Active Digital Complicity in the AdTech sector (Perion) and Functional Complicity in the MarTech sector (Bloomreach). The “Project Future” headless/MACH architecture makes the retailer a modular consumer of “best-of-breed” tech, which in the current market often means Israeli tech. The revenue flow is direct (licensing/platform fees). Confidence: High.

Counter-Arguments & Assessment:

• Counter-Argument: Using global software like Bloomreach is unavoidable; the Israeli R&D center is just one office of a US company.
• Rebuttal: Bloomreach’s Tel Aviv presence is a strategic R&D hub, not a sales outpost. The acquisition of Hivestack by Perion makes the ownership explicitly Israeli. These are not incidental; they are direct vendor relationships where money flows to Tel Aviv.

Named Entities / Evidence Map:

• Perion Network: Israeli owner of Hivestack (Direct Vendor).⁶
• Bloomreach: CDP Vendor with Tel Aviv R&D.
• Primer: Payment Switch (Gateway to Riskified).
• Checkpoint Systems: US Vendor (Exonerated).

Intelligence Gaps:

• Confirmation of whether New Look has activated the Riskified/Forter modules within Primer.

5. BDS-1000 Classification

Results Summary

Final Score: 236

Tier: Tier D (200–399) – Moderate Complicity

Justification Summary:

New Look Retailers Ltd. avoids “Tier A” status only because it lacks a physical retail footprint in the settlements and does not hold direct military contracts. However, its score of 236 reflects deep Structural and Capital Complicity. The entity is a “Generative Asset” for Franklin Templeton, effectively acting as a revenue stream for a major investor in Elbit Systems and Lumenis. Furthermore, the company engages in Digital Complicity via the Perion/Hivestack AdTech pipeline and exhibits Political Complicity through its blatant “Safe Harbor” double standard regarding Russia vs. Israel. The company is not a direct oppressor, but it is a financial tributary to the oppression.

Domain Scoring Summary

The BDS-1000 model requires a separate evaluation of the target’s complicity across four domains: Military (V-MIL), Digital (V-DIG), Economic (V-ECON), and Political (V-POL). Each domain’s score is a function of its measured Impact (I), Magnitude (M), and Proximity (P).

BDS-1000 Scoring Matrix – New Look Retailers Ltd.

Domain	I	M	P	V-Domain Score
Military (V-MIL)	1.0	1.0	1.0	0.02
Economic (V-ECON)	4.8	7.0	4.5	3.08
Political (V-POL)	3.5	5.0	9.0	2.48
Digital (V-DIG)	3.5	4.0	8.0	1.99

V- {domain} Calculation

• V-MIL Calculation:
  • Impact (1.0): Incidental / Grey Market only. No kinetic support.
  • Magnitude (1.0): Negligible volume via 3PLs.
  • Proximity (1.0): Passive link.
  • 
• V-ECON Calculation:
  • Impact (4.8): Structural ownership by pro-Israel capital (Franklin Templeton).
  • Magnitude (7.0): Major scale (Revenue £800m+).
  • Proximity (4.5): Upstream Subsidiary relation.
  • 
• V-POL Calculation:
  • Impact (3.5): Double Standard / Safe Harbor status.
  • Magnitude (5.0): Continuous governance posture.
  • Proximity (9.0): Direct decision by current leadership.
  • 
• V-DIG Calculation:
  • Impact (3.5): Soft Dual-Use Procurement (AdTech).
  • Magnitude (4.0): Modest commercial scale.
  • Proximity (8.0): Direct Vendor contract.
  • 

Final Composite

Using the OR-dominant formula with a side boost:

Let:

BRS Score Formula

Grade Classification:

Based on the score of 248.6, the company falls within:

• Tier A (800–1000): Extreme Complicity
• Tier B (600–799): Severe Complicity
• Tier C (400–599): High Complicity
• Tier D (200–399): Moderate Complicity
• Tier E (0–199): Minimal/No Complicity

Tier: Tier D

6. Recommended Action(s):

• Focused Divestment (Parent Level): Activist pressure should not primarily target the retail stores with boycotts (as the operational link is low and may harm UK workers without impacting Israel), but rather focus on divestment campaigns targeting Franklin Templeton. Institutional investors (pension funds, universities) should be lobbied to divest from Franklin Templeton due to its active support of Elbit Systems and the JNF. New Look should be cited as a tangible example of how consumer spending feeds this capital pool. “Don’t shop at New Look if you don’t want to fund Franklin Templeton’s defense portfolio.”
• Public Exposure of Double Standards: A media campaign should highlight the “Tale of Two Conflicts”—contrasting New Look’s rapid, humanitarian response to Ukraine (policy updates, refugee support) with its silence and retention of the Israeli subsidiary regarding Gaza. This exposes the “Safe Harbor” hypocrisy and threatens the brand’s “Kind to Our Core” reputation among its primary Gen-Z demographic.
• Supply Chain Transparency Demands: Activists and ESG auditors should demand Tier 2/3 disclosure specifically for goods sourced from Turkey and Jordan. The demand should be: “Prove your nylon is not from Nilit” and “Prove your Jordanian sourcing does not utilize the QIZ Israeli content quota.” The “semi-announced” nature of their audits should be challenged as insufficient for conflict zones.
• Digital Vendor Pressure: Internal employee pressure groups (tech workers) should question the usage of Hivestack, given its ownership by Perion. The IT/Marketing departments should be pushed to switch to non-Israeli AdTech providers to ensure ad spend does not leak to the Israeli economy.
• Monitoring of Sale Process: As Alcentra prepares to sell New Look (as of August 2025), monitoring the potential buyers is critical. If the company is sold to another private equity firm with deeper Zionist ties, the risk tier could escalate. Conversely, a sale to a trade buyer with no Israel links could lower the score.

1. New Look Calc
2. New Look economic Audit
3. Franklin Templeton Completes Acquisition of Alcentra, One of the Largest European Alternative Credit Managers, accessed February 4, 2026, https://www.franklintempleton.co.uk/press-releases/news-room/2022/franklin-templeton-completes-acquisition-of-alcentra
4. Franklin Templeton to Acquire Alcentra from BNY Mellon, accessed February 4, 2026, https://www.bny.com/corporate/global/en/about-us/newsroom/press-release/franklin-templeton-to-acquire-alcentra-from-bny-mellon.html
5. New Look military Audit
6. Hivestack Acquired By Ad Tech Firm Perion In $100M Cash Deal – Sixteen:Nine, accessed February 4, 2026, https://www.sixteen-nine.net/2023/12/12/hivestack-acquired-by-ad-tech-firm-perion-in-100m-cash-deal/
7. New Look digital Audit
8. New Look quits Russia and Ukraine – The Guardian, accessed February 4, 2026, https://www.theguardian.com/business/2014/nov/11/new-look-quits-russia-ukraine-expanding-china-poland
9. MODERN SLAVERY STATEMENT – GOV.UK, accessed February 4, 2026, https://downloads.modern-slavery-statement-registry.service.gov.uk/pdf-published/AzEjEsKG/2022/New%20Look%20Retailers%20Modern%20Slavery%20Statement%202022.pdf
10. New Look political Audit
11. New Look (company) – Wikipedia, accessed February 4, 2026, https://en.wikipedia.org/wiki/New_Look_(company)
12. New Look Announces Strategic Review Update, accessed February 4, 2026, https://www.newlookgroup.com/media/newsroom/financial-releases/2020/09-09-2020-162745405
13. New Look may have to put itself up for sale as part of rescue refinance – The Guardian, accessed February 4, 2026, https://www.theguardian.com/business/2019/jan/24/new-look-may-have-to-put-itself-up-for-sale-rescue-refinance-bondholders-debt
14. New Look owners pick bankers to fashion sale process | Money News, accessed February 4, 2026, https://news.sky.com/story/new-look-owners-pick-bankers-to-fashion-sale-process-13417489
15. Frequently Asked Questions About the Russia–Ukraine Negotiations, accessed February 4, 2026, https://quincyinst.org/research/frequently-asked-questions-about-the-russia-ukraine-negotiations/
16. Perion Acquires Hivestack, a Leading Global Full-Stack Digital Out-Of-Home (DOOH) Platform, accessed February 4, 2026, https://perion.com/press/perion-acquires-hivestack-a-leading-global-full-stack-digital-out-of-home-dooh-platform/
17. Understanding the situation in Ukraine from 2014 to 24 February 2022 – France Diplomatie, accessed February 4, 2026, https://www.diplomatie.gouv.fr/en/country-files/ukraine/situation-in-ukraine-what-is/understanding-the-situation-in-ukraine-from-2014-to-24-february-2022/
18. New Look Clothing and Fashion Products Ltd. – 514538966 – CheckId, accessed February 4, 2026, https://en.checkid.co.il/company/xb1rXV8-514538966
19. Alcentra strikes with its largest direct lending deal yet – Global Capital, accessed February 4, 2026, https://www.globalcapital.com/article/b1kp8xhzjdtfnx/alcentra-strikes-with-its-largest-direct-lending-deal-yet
20. How sensitive is Elbit Systems Ltd. to inflation – July 2025 Selloffs & Weekly High Return Opportunities, accessed February 4, 2026, https://account.israelgives.org/celebs-details/281/How-sensitive-is-Elbit-Systems-Ltd.-to-inflation
21. How Turkey’s trade suspension could derail Israeli importers – JINSA, accessed February 4, 2026, https://jinsa.org/how-turkeys-trade-suspension-could-derail-israeli-importers/
22. New Look moves all suppliers to TrusTrace to boost transparency – Just Style, accessed February 4, 2026, https://www.just-style.com/news/new-look-trustrace-supplier/
23. Investor Presentation August 2025 – Elbit Systems, accessed February 4, 2026, https://www.elbitsystems.com/sites/default/files/2025-08/elbit_systems_investor_presentation_august_2025_accessible_0.pdf
24. Benefit Street Partners | Alcentra – Franklin Templeton, accessed February 4, 2026, https://www.franklintempletonme.com/about-us/our-teams/specialist-investment-managers/benefit-street-partners
25. Franklin Resources Inc Portfolio Holdings – Fintel, accessed February 4, 2026, https://fintel.io/i/franklin-resources
26. Sourcing and supply chain – New Look, accessed February 4, 2026, https://www.newlookgroup.com/esg-sustainability/planet/sourcing-and-supply-chain