New Look ECONOMIC

Supply Chain & Sourcing Relationships

New Look’s current factory-list disclosure states that it sources through 83 suppliers and 283 Tier 1 factories across 14 countries: Bangladesh, Bulgaria, Cambodia, China, Egypt, India, Italy, Morocco, Romania, Sri Lanka, Tunisia, Türkiye, the United Kingdom and Vietnam; Israel is not among the disclosed Tier 1 countries. The company also reports knowledge of 997 beyond-Tier-1 factories and says its disclosure is updated biannually, but the retrieved page does not provide a country-by-country table for those lower-tier sites. ^{1, 2}

New Look’s 2025 sustainability report states that, since November 2023, it has used TrusTrace to map supplier production sites from Tier 1 through Tier 4 and that suppliers with active commitments have been onboarded. This traceability disclosure does not identify an Israeli supplier, manufacturer, agent, distributor, or sourcing relationship. ²

No public evidence identified of direct commercial relationships between New Look and Israeli agricultural aggregators or exporters including Mehadrin, Hadiklaim, Galilee Export, or Agrexco successors. This is consistent with New Look’s disclosed apparel, footwear and accessories business rather than fresh-produce retailing. ^{1, 3}

No public evidence identified of a dedicated Israel-linked import entity, joint venture, subsidiary, or third-party arrangement functioning as an importer of record or bringing Israeli-origin goods into New Look’s supply chain. The produce-cycle question remains structurally inapplicable to New Look’s disclosed retail categories. ^{1, 2, 3}

New Look describes third-party e-commerce partners and franchises as potential downstream channels, while its current strategy refers to selected e-partner relationships in the UK and Europe; neither disclosure names an Israeli partner, franchisee, reseller, or distributor. ^{2, 4} A FY19 statement reported six franchise stores and the discontinuation of its largest Middle East franchise relationship during that year, without naming the partner or identifying Israel as a territory. ⁵

Product Origin, Labeling & Regulatory Compliance

No public evidence identified of settlement-origin products, goods labelled “Produce of Israel,” or goods sourced from the West Bank, East Jerusalem, the Jordan Valley, or the Golan Heights being sold by New Look. ^{6, 7, 8}

No public evidence identified of a New Look enforcement action, customs or DEFRA finding, NGO investigation, or corporate policy specifically concerning country-of-origin labelling for Israeli or settlement-origin goods. The available materials address general supply-chain human-rights, subcontracting, forced-labour, and Xinjiang-related controls rather than Israel or the occupied Palestinian territory. ^{6, 7, 8, 5}

No public evidence identified of a corporate policy specifically addressing goods originating from occupied or contested territories. ^{6, 7}

Investment, Capital & Financial Exposure

New Look Retail Group was reported as co-owned by Brait SE and Alcentra following the 2020 debt restructuring. ^{9, 10} The current verified UK legal chain is New Look Limited to New Look Retailers Limited: Companies House records New Look Limited as the sole active PSC of New Look Retailers Limited, with more than 75% of shares and voting rights and a right to appoint or remove directors. ¹¹

New Look Retailers Limited is active, incorporated in England and Wales on 1 March 1982, and registered at New Look House, Mercery Road, Weymouth, Dorset; its latest filed accounts are for the year ended 29 March 2025 and its latest confirmation statement is dated 10 August 2026. ^{12, 13} New Look Limited is active, incorporated in England and Wales on 5 March 1986, registered at the same address, and classified as conducting head-office activities. ¹⁴ Its PSC register records a statement that it knows or has reasonable cause to believe that no registrable person or registrable relevant legal entity exists in relation to it; that UK PSC-register statement does not identify or rule out all economic or contractual interests held through non-registrable structures. ¹⁵

Brait’s current disclosed economic interest must be distinguished between equity and shareholder funding. At 31 March 2026 it held 8.1% equity, 18.3% participation in priority/existing PIK and shareholder funding, and 0% of the new senior-priority PIK facility; the carrying value was approximately £32 million/R723 million, representing 5% of Brait’s total assets.^{16, 17} The 8.1% reflects warrant dilution from the 17.2% equity participation reported at September and March 2025. It is not an 18.3% interest in every debt tranche.^{18, 17}

The 2020 recapitalisation originated with the cancellation of senior secured notes in exchange for a £40 million non-interest-bearing shareholder loan and 20% of share capital, alongside £40 million of new PIK funding carrying 16.5% annual PIK interest for 80% of share capital. Brait disclosed a pro-rata £7.3 million contribution to each £40 million instrument. ^{19, 20} Brait’s 2025 audited results additionally describe a £50 million PIK facility issued in September 2022, accrued interest, and a £31.6 million PIK facility issued in FY2025 that Brait did not join; the shareholder loan was stated to mature in November 2029 and the secured PIK facility in November 2027. ²¹ Brait’s June 2026 results state that sale of its remaining New Look stake remained an objective rather than a completed disposal. ¹⁶

The May 2015 transaction announcement distinguishes Brait’s approximately £780 million consideration for approximately 90% of New Look from the approximately £1.9 billion enterprise valuation. ²²

Franklin Resources acquired all outstanding ownership interests in BNY Alcentra Group Holdings, Inc. and its subsidiaries from BNY Mellon on 1 November 2022. ^{23, 24} Franklin announced in January 2026 that Alcentra-branded funds would align under the Benefit Street Partners (BSP) brand, describing shared research, distribution, operations and infrastructure. ²⁵ BSP describes itself as a wholly owned Franklin Templeton alternative-credit platform with approximately US$93 billion in assets under management across credit funds and separately managed accounts as at 30 June 2026. ²⁶

New Look Retail Holdings Limited’s FY2025 accounts identify investor directors Laurence Raven and Stuart MacKenzie as representing the majority shareholders, with equal board votes and a casting vote for the chairman. Reserved shareholder/board matters include borrowing limits, dividends, business acquisitions/disposals, capital changes and senior appointments. Non-employee A shares have voting and dividend rights and are stapled to new-money loans; B/C/D shares lack general-meeting voting rights.²⁷ Brait’s FY2026 report identifies Raven as an Alcentra managing director and dates his New Look board appointment to November 2020; MacKenzie is a TRG partner following its April 2023 acquisition of Ethos.¹⁷ These establish investor representation; the reviewed records do not allocate every current equity, loan, warrant or consent right to an identified Alcentra/BSP client-fund legal vehicle.^{17, 27} Sky’s April 2025 report names Alcentra and Brait as shareholders since 2020, but its description of £30 million as equity from both is qualified by the primary accounts: the March 2025 financing was £31.6 million PIK commitment yielding £30 million cash after discount, with warrants, and Brait did not participate in that tranche.^{17, 27, 28}

Brait’s New Look holding is a corporate investment and shareholder-funding exposure, rather than a passive public-market allocation.^{16, 19, 17} New Look’s investor board representation and reserved matters are disclosed, but the reviewed materials do not identify the beneficial owners and full mandate of each Alcentra/BSP-managed New Look interest or establish capital fungibility with other Franklin-managed funds.^{24, 26, 17, 27}

No public evidence identified in the reviewed owner-group materials of underwriting Israeli sovereign debt or Israel Bonds, purchasing or holding Israeli sovereign or war bonds through the New Look ownership vehicle, or direct lending or trade finance by Brait, Alcentra/BSP, or Franklin Resources to the Israeli state, IDF, Israeli defence primes, OHCHR-listed enterprises, or settlement-active companies. ^{16, 24, 21, 26}

A Franklin DynaTech VIP Fund annual report records 507 Elbit Systems Ltd. shares valued at US$292,899 at 31 December 2025.²⁹ The report identifies Franklin Advisers, Inc. as investment manager, receiving a fee based on fund net assets, and states that fund shares are generally sold to insurance-company separate accounts for variable insurance policies/annuities.²⁹ The May 2026 prospectus describes manager-selected stocks using fundamental research into growth, quality and valuation; this is an active discretionary strategy, not evidence of mandatory passive index replication. The prospectus does not establish the date or instruction for the particular Elbit purchase.³⁰ The recorded securities belong to this fund; the documents do not identify them as New Look assets, Franklin corporate-treasury assets, or a holding of a New Look-related credit vehicle.^{29, 27}

Franklin-affiliated fund disclosures also report 1.59% geographic exposure to Israel for Western Asset High Yield Opportunity Fund at 31 July 2026 and 0.35% for Franklin Premier Income Trust on its current disclosure page; neither cited allocation table identifies the underlying issuer, whether the exposure is sovereign or corporate, or a corresponding Franklin corporate-treasury position. ^{31, 32} By contrast, a Franklin Dividend Tilt ETF prospectus expressly describes a passive/indexing approach and states that its underlying index includes Israeli issuers. ³³ These product-level disclosures do not establish a New Look-related allocation. ^{29, 31, 32, 33}

Brait’s prospectus identifies Titan Fincap Solutions Proprietary Limited and associates as “Titan,” and describes the Titan Group as representing Christo Wiese’s interests in Brait’s parent. ¹⁹ At 18 June 2026, Brait reported that Titan and affiliates held 39.3% of Brait ordinary shares and had irrevocably undertaken to underwrite Brait’s R2.5 billion rights offer and vote in its favour. ¹⁶ This demonstrates influence at Brait level, but does not establish equivalent New Look voting, board-appointment, or operating rights. ^{16, 19}

No public evidence identified quantifying Brait’s, Alcentra/BSP’s, Franklin Resources’, Christo Wiese’s, or Wiese family-office direct Israeli investments, subsidiaries, Israeli sovereign debt holdings, or New Look-specific portfolio exposure beyond the fund disclosures described above. ^{34, 35, 16, 26, 29, 31, 32}

Operational Presence & Market Activity

No public evidence identified of New Look offices, stores, warehouses, support centres, franchisees, licensees, employment, tax registration, or occupied-territory operations in Israel. ^{36, 37, 3, 4}

New Look’s current corporate site states that it serves more than 10 million customers across the UK, operates 309 stores, generated £677.9 million total revenue for the 52 weeks ended 28 March 2026 on an unaudited basis, and employs more than 6,500 people. It does not identify Israel as a market. ³

New Look identifies support-centre locations in London for Creative, Digital and Product functions and Weymouth for Corporate Services, as well as two distribution centres in Newcastle-under-Lyme, Staffordshire, with more than one million square feet of capacity. These disclosures support UK-based operational functions but do not establish an Israeli office, warehouse, employee base, tax registration, or franchise. ³⁷

New Look’s current strategy describes a national store estate, digital channels, and selected e-partner relationships in the UK and Europe. No public evidence identified of current Israeli market activity in that material. ⁴

New Look’s international footprint has contracted: its Irish branch entered liquidation in February 2025, affecting 26 stores and 347 workers, and its international e-commerce websites were closed. ^{38, 36, 39} The company has also been reported as pursuing UK store closures amid restructuring and reduced sales. ^{40, 41, 38}

Corporate Structure & Foundational Ties

New Look was founded in 1969 in Taunton, Somerset, United Kingdom, by Tom Singh, using a £5,000 parental loan, and was not founded or incorporated in Israel. ^{42, 43} Its current corporate site describes New Look as a British retailer serving UK customers. ³

Tom Singh retired from New Look in 2019 and has continued philanthropic and investment activity, including advisory involvement with the British Asian Trust. ^{42, 43} No public evidence identified in the reviewed record of Israel-linked philanthropic or investment activity by Singh. ^{42, 43}

New Look Retailers Limited’s registered office is New Look House, Mercery Road, Weymouth, Dorset, United Kingdom; this registered-office record does not itself establish the location of all group headquarters functions. ^{12, 13} No public evidence identified of an Israeli headquarters, principal-place-of-management function, tax residency, Preferred Technology Enterprise status, Israeli state ownership, acquired Israeli operating subsidiary, controlled Israeli manufacturer, or Israeli state/infrastructure linkage for New Look. ^{14, 3}

New Look’s corporate board page identifies Chairman Mike Coupe, CEO Helen Connolly, CFO Richard Collyer, and non-executive directors Laurence Raven, Stuart MacKenzie, Colin Henry and Robin Terrell. ^{44, 45} The currently listed directors of New Look Limited include Richard Collyer, Helen Connolly and Clare Dobbie. ⁴⁶ No public evidence identified of defence-industry, Unit 8200, IDF, or Israeli-settlement-organisation affiliations for the listed New Look board or executive-team members. ^{44, 45}

No public evidence identified of governance features such as golden shares, founder shares, or charter restrictions tying New Look to the Israeli state. ^{11, 15}

Sanctions, Watchlist & Advocacy-Database Screening

No public evidence identified of New Look, New Look Retailers Ltd, New Look Retail Group, Brait, Alcentra/Franklin Templeton/BSP, or Christo Wiese in the OHCHR Database of Business Enterprises under Human Rights Council resolutions 31/36 and 53/25, as updated in September 2025. ^{47, 48}

No public evidence identified of a Who Profits entry for New Look, an AFSC Investigate company profile for New Look in the available all-companies index, or New Look appearing in the available “Don’t Buy Into Occupation” 2024 or 2025 report materials. ^{49, 50, 51, 52} These are document- and database-scoped findings, not proof that no unreviewed record exists.

The reviewed evidence supports Brait’s continuing minority capital and funding relationship with New Look, the reported Alcentra shareholder relationship, and disclosed investor directors and reserved matters.^{16, 17, 27, 28} It does not establish direction by those investors of New Look’s sourcing, sales, Israel-related activity or settlement-related decisions, nor a New Look interest in the securities of separate Franklin-managed funds.^{26, 29, 17, 27}

Profit Repatriation & Economic Contribution

New Look’s current reporting presents UK-facing customer, store, employee, and aggregate-revenue figures, while its international online operations have been wound down and its Irish store estate liquidated. ^{38, 36, 39, 3}

No public evidence identified of revenue attributed to Israel, profits flowing to or from Israel, Israeli payroll or tax payments, or a role for New Look in the Israeli economic ecosystem. ^{37, 3, 4}

No public evidence identified of any government designation, sector report, or industry assessment characterising New Look’s role in the Israeli economy. ^{47, 48, 49, 50, 51}

Brait’s 30 April 2025 announcement expressly states that it retained shareholder protections and its New Look board position despite not joining the new financing.⁵³