New Look

Key Findings

• Economic: Franklin DynaTech VIP Fund held 507 Elbit Systems shares valued at $292,899 on 31 December 2025. Its manager uses discretionary stock selection. New Look’s Alcentra-linked investor governance connects this small portfolio exposure indirectly to its owner-manager network; the shares are fund assets, not New Look’s own holdings.^{1, 2, 3, 4, 5}
• Political: The reviewed sources and bounded searches did not substantiate a direct New Look-linked Israel/Palestine statement, donation or advocacy act. The assessment nevertheless applies the political Impact floor because the economic relationship is positive.^{6, 7, 8}
• Ownership: New Look has continuing investor-governance and financing links involving Brait and Alcentra/BSP-related interests, but the reviewed record does not establish that these investors direct New Look’s Israel-related sourcing, sales, or settlement decisions.^{1, 2}
• Not found: No public evidence identified of military/security contracts, tactical-product supply, Israeli-origin surveillance or enterprise-technology procurement, or Israeli state-security technology activity by New Look.^{9, 10}

Target Profile

Key Facts:

• New Look’s current corporate reporting describes a UK-focused retailer with 309 stores, more than 10 million customers, more than 6,500 employees, and £677.9 million revenue for the 52 weeks ended 28 March 2026 on an unaudited basis.¹³
• Its disclosed Tier 1 factory list covers 83 suppliers and 283 factories in 14 countries; Israel is not listed.¹⁴
• The Irish business entered liquidation in February 2025 and ceased to be a subsidiary; stores closed in March 2025.^{2, 15}

Executive Summary

New Look is a British fast-fashion retailer. Its disclosed business consists of apparel, footwear, accessories, physical retail, e-commerce, and associated commercial supply-chain and technology functions. The audits identify UK operational locations, a disclosed global apparel-sourcing network, and selected technology suppliers supporting retail operations. They do not identify a New Look office, store, warehouse, franchise, distributor, tax registration, subsidiary, or published sourcing activity in Israel, the West Bank, East Jerusalem, the Golan Heights, or Israeli settlements.^{14, 16, 13}

The retained economic issue is a small active portfolio investment within the connected owner-manager network. Franklin DynaTech VIP Fund reported 507 shares in Israeli defence company Elbit Systems, valued at $292,899 on 31 December 2025. The fund report identifies Franklin Advisers as its fee-paid manager, and the May 2026 prospectus describes discretionary fundamental stock selection. The position is not passive index replication, but it is also not documented as a New Look asset, Franklin corporate-treasury holding or strategic investment by the retailer.^{4, 5}

The connection rests on the documented Alcentra investor-director relationship at New Look and Franklin’s acquisition and integration of Alcentra/BSP. Brait separately retained 8.1% New Look equity and 18.3% participation in priority/existing PIK and shareholder funding at 31 March 2026, with no participation in the new senior-priority PIK facility. Investor directors and reserved matters establish influence, while the exact current Alcentra fund vehicle and complete beneficial cap table remain unresolved.^{1, 2, 3, 17, 18}

The disclosed sourcing record does not identify an Israeli supplier. New Look reports Tier 1 factories in Bangladesh, Bulgaria, Cambodia, China, Egypt, India, Italy, Morocco, Romania, Sri Lanka, Tunisia, Türkiye, the United Kingdom, and Vietnam; Israel is not among those countries. New Look’s use of traceability tools through Tier 4 does not identify an Israeli supplier, manufacturer, agent, distributor, or sourcing relationship. The audit likewise found no public evidence of settlement-origin goods, Israel-linked imports, Israeli commercial partners, or New Look income attributable to Israel.^{14, 16}

No public evidence identified supports military or digital-complicity claims. New Look is not documented as a defence supplier, tactical-equipment manufacturer, technology vendor, surveillance provider, or participant in Israeli military, intelligence, security, cloud, or Project Nimbus-related activity. Its identified technology use is consistent with an enterprise customer of retail point-of-sale, commerce, support, cloud, customer-data and sustainability-data systems; the audits did not identify Israeli-origin technology within those arrangements.^{9, 10, 19, 20, 21}

The reviewed corporate sources and bounded political searches did not substantiate a direct New Look-linked Israel/Palestine statement, donation, anti-BDS intervention or advocacy role.^{6, 7, 8} The final assessment is BRS 24, Tier E. Its economic value of 0.29 records the small indirect Elbit portfolio relationship; the political Impact floor is 2.0, with no separately evidenced political-act Magnitude or Proximity. This is not a finding that every owner-group connection is absent.

Timeline of Relevant Events

Corporate Overview

New Look Retailers Limited is an active English private limited company operating in specialist clothing, footwear and leather-goods retail, including mail-order and internet retail. New Look Limited is recorded as its sole active person with significant control, with more than 75% of shares and voting rights and the right to appoint or remove directors. New Look Limited’s PSC register states that it knows or has reasonable cause to believe there is no registrable person or registrable relevant legal entity in relation to it; this UK disclosure does not establish the absence of all creditor, investor, or contractual governance rights outside the statutory PSC definition.^{11, 12, 24}

The reviewed ownership record requires distinction between legal control, investor governance, and economic exposure. Brait’s FY2026 reporting confirms a continuing minority holding and funding participation, rather than a completed exit. New Look Retail Holdings Limited’s FY2025 accounts identify Laurence Raven and Stuart MacKenzie as investor directors representing majority shareholders and describe reserved matters involving borrowing, dividends, acquisitions/disposals, capital changes, and senior appointments. These facts establish investor representation and protections, but the audits do not establish investor direction over a New Look Israel/Palestine decision.^{1, 2}

Franklin completed its Alcentra acquisition on 1 November 2022 and announced the final integration under the BSP brand in January 2026. The platform shares research, distribution, operating teams and infrastructure.^{17, 18} This supports the owner-manager connection, but does not make a separately held client fund’s securities the property of New Look or Franklin’s corporate treasury.^{2, 4}

No public evidence identified of a New Look Israeli subsidiary, franchisee, distributor, importer of record, office, store estate, warehouse, employee base, tax registration, or occupied-territory operation. Historical reporting on a 2007 Landmark Group Middle East franchise plan named Saudi Arabia, the UAE, Kuwait, Bahrain, Qatar, Oman, and Jordan, but not Israel; it is a historical plan and not evidence of the current estate.^{16, 25}

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified of contracts, tenders, framework agreements, or memoranda of understanding between New Look and the Israeli Ministry of Defense, IDF, Israel Prison Service, Border Police, or another Israeli security body. New Look does not appear in the reviewed OHCHR settlement-business database, Who Profits company database, or PAX’s review of companies arming Israel.^{26, 27, 28}

New Look’s disclosed business is civilian fashion retail. No public evidence identified that it manufactures or markets tactical, ruggedised, military-specification, or defence-grade products, supplies defence primes, provides base services, or contributes to weapons systems, munitions, military logistics, or military infrastructure. A 2025 apparel and tactical-gear supply-chain investigation did not identify New Look among entities supplying the IDF.^{9, 29}

Counter-Arguments and Evidence Limits

The strongest defence is the company’s civilian character and the absence of identified defence relationships. The audits found no public evidence of military contracts, export licences, defence-sector supply relationships, tactical product lines, or security-end-user certificates. New Look’s disclosed logistics concern ordinary apparel sourcing and distribution, not military cargo or facilities services.^{14, 9}

These are bounded public-record findings. They do not prove that no undisclosed commercial interaction could exist, but no evidence meeting the audit standard was identified.

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

New Look is documented as an enterprise-technology customer, not a technology producer or vendor. Identified deployments include Enactor unified commerce for UK and Ireland stores, a 2025 HP till rollout, and Mac-management/support services described by LeftBrain. Enactor’s announcement identifies Microsoft Azure for Enactor On Demand, but does not identify an Israeli cloud region, Israeli infrastructure, or an Israeli-origin component.^{10, 19, 20, 21}

New Look’s privacy policy and annual reporting describe external hosting, payment, fraud-protection, data-processing, cloud, endpoint-security, and security-operations arrangements. The disclosed materials do not identify an Israeli data-processing location, Israeli legal-access mechanism, Israel-linked data pipeline, Israeli vendor, or New Look participation in Project Nimbus or comparable Israeli-government cloud activity.^{31, 32}

No public evidence identified of facial recognition, biometric identification, Israeli-origin retail surveillance, Israeli cybersecurity vendors, defence/intelligence technology contracts, offensive cyber capabilities, AI systems supplied to Israeli security bodies, Israeli R&D facilities, or Israeli technology-company investments by New Look.^{10, 32}

The separate K2 Alternative Strategies Fund schedule dated 31 August 2025 records a NICE zero-coupon convertible senior note with $237,000 principal and $236,585 value, contractually maturing on 15 September 2025. It does not establish a current 2026 equity stake, strategic technology investment, New Look procurement or data-exposure pathway; actual redemption is not asserted.³³

Counter-Arguments and Evidence Limits

The strongest defence is that the documented stack is ordinary retail infrastructure. Named deployments establish retail POS, commerce, payment, support, and cloud services, but do not establish Israeli-origin technology or Israeli operational use. The 2025 sustainability report’s reference to an Enterprise Data Platform and AI for sustainability measurement does not identify its vendor, host, model, training data, or geography.^{16, 19, 32}

Absence findings are limited to the reviewed sources and identified vendors. Unnamed providers in corporate reporting cannot be treated as proof of a particular vendor’s absence; equally, they cannot support attribution without evidence.

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

New Look’s disclosed supply chain covers 83 suppliers and 283 Tier 1 factories across 14 named countries, none of which is Israel. It reports knowledge of 997 beyond-Tier-1 factories and use of TrusTrace from Tier 1 through Tier 4, but its public disclosure does not provide a complete country-by-country lower-tier map. No public evidence identified of Israeli suppliers, Israeli agricultural exporters, Israeli import entities, settlement-origin goods, Israeli distributors, or Israel-specific franchise relationships.^{14, 16}

The retained economic score reflects the active Elbit investment within the connected owner-manager network, not merely Brait’s financing of a UK retailer. Alcentra’s New Look shareholder relationship and investor-director representation, followed by Franklin’s acquisition/integration of Alcentra/BSP, establish the relevant connection.^{1, 2, 3, 17, 18}

Franklin DynaTech VIP Fund reported 507 Elbit Systems shares worth $292,899 at 31 December 2025. Its fee-paid manager, Franklin Advisers, selects equities using fundamental research; the position is therefore distinguished from a mandatory passive index allocation. The fund report describes insurance-company separate-account investors. These are client-fund securities, not demonstrated New Look or Franklin treasury assets.^{4, 5}

Counter-Arguments and Evidence Limits

The strongest defence is that New Look’s own disclosed commercial record is UK- and non-Israel-focused. Israel is absent from its named Tier 1 factory countries, its corporate market profile does not identify Israel, and no public evidence identified links New Look revenue, taxes, payroll, procurement, stores, or supply-chain activity to Israel or settlements.^{14, 16, 13}

The investment is small and indirect. The disclosed $292,899 position supports very low Magnitude; the record does not establish a large strategic allocation or unchanged current holdings. The separately held client fund and distinct New Look operating group support portfolio-level Proximity, while Alcentra investor governance prevents treating the connection as wholly absent. Missing cap-table precision does not erase the established relationship, and no common ownership of the fund’s underlying securities is inferred.^{1, 2, 3, 4, 5} Brait’s proposed sale remains an objective rather than a completed exit.¹

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

The positive economic relationship requires political Impact of at least 2.0 under the rubric’s neutrality rule. Here no separately supported political-act scale, audience or direct conduct establishes non-zero Magnitude or Proximity; Political therefore remains 0.00. This floor is distinct from a finding of strict neutrality.

No public evidence identified of a New Look corporate statement, press release, current-leadership comment, lobbying position, political donation, anti-BDS advocacy, or geopolitical pressure-group role concerning Israel/Palestine, Gaza, the October 2023 escalation, the ICJ advisory opinion, or ICC arrest warrants.^{6, 7, 8}

No public evidence identified of New Look operations in Israel or occupied territory, or of New Look inclusion in the reviewed OHCHR settlement-business database. The company also does not appear in the reviewed Ethical Consumer Palestine boycott list. These are document-scoped findings and do not constitute proof that no unreviewed record exists.^{34, 26, 35}

A 2014 article identifying “Christo and Rina Wiese” as Christian Friends of Israel contacts does not establish that the named Christo Wiese was Brait’s shareholder, document a donation, or establish a New Look connection. The audits retain this as an unresolved same-name lead, not attributable evidence.³⁶

Counter-Arguments and Evidence Limits

The strongest defence is the absence of a verified attributable political act. The audits did not substantiate a New Look-linked donation, advocacy act, Israel/Palestine statement, settlement relationship, or state partnership. New Look’s historical exit from Russia and Ukraine and Pride-related communications concern other subjects and cannot establish an Israel/Palestine position; the Russia/Ukraine exit occurred in 2014, not as a response to the 2022 invasion.^{6, 37}

The no-hit findings are bounded by the reviewed searches and records. They do not constitute an audit of every worldwide donation, lobbying, or advocacy database. The unresolved Wiese reference must not be attributed to Brait or New Look.

Named Entities and Evidence Map

BDS-1000 Score

Method: V6.5.

• V_MAX: 0.29 Avg_OTHERS: 0.00
• BRS Score: 24 Tier: E (Minimal/No Complicity)

V_MAX is driven by the small active Elbit holding through the connected owner-manager network: I-ECON 4.0 identifies indirect portfolio flow, M 1.0 reflects the modest disclosed position, and P 3.5 reflects the separately held client fund and indirect relationship. This gives Economic 0.29. The conditional political Impact floor is 2.0; its zero Magnitude and Proximity reflect the lack of a separately substantiated political act. The final 24/E replaces the prior published V5.1 163/E after rejecting unsupported historical political attribution and adding the newly verified economic finding.^{1, 2, 3, 4, 5}

The V6.5 result combines Impact, Magnitude and Proximity under the stated formula. It distinguishes documented facts from attribution judgments and retains source limitations. A low score is not a certification that every possible connection has been excluded.

Methodology Note

• Evidence is limited to the four supplied domain audits and their cited documentary record.
• Impact (I) assesses the activity type; Magnitude (M) assesses scale; Proximity (P) assesses directness of the evidenced connection.
• Magnitude explicitly adjusts for scale; Proximity adjusts for the structural relationship. Evidence quality is recorded separately from those axes.
• Verified cessation can reduce current Magnitude or change Proximity; an intended disposal or a dated holding alone does not establish a completed exit. No automatic time decay is applied.
• Entity attribution is controlled: investor, manager, shareholder, creditor, affiliate, and separately managed fund positions are not automatically attributed to New Look.
• Settlement operations, if established, would be assessed across both Economic and Political; “No public evidence identified” is used where the audits’ completed checks found no qualifying evidence.