Tonic Health

Key Findings

• Economic: Boots-hosted Tonic Kids Multivitamins packaging states “Made in Israel for Tonic Nutrition Ltd,” establishing an attributable Israeli manufacturing/sourcing relationship for that specific product; the supplier, factory location, contract value, production volume and duration are not publicly established.¹
• Digital: Tonic’s live rewards programme uses Yotpo, a commerce-software company identified as Israeli-founded by the Israel Innovation Authority,² whose disclosures list Yotpo Ltd and Akamai Technologies Israel Ltd among Israel-based processors for merchant end-user personal data; the evidence does not establish that all Tonic customer data is stored in Israel or that Tonic contracts with or pays an Israeli Yotpo entity.^{3, 4, 5}
• Political: No public evidence identified of Tonic or its controlling principal taking an Israel-Palestine political position, lobbying on the conflict, funding Israeli military-welfare or settlement organisations, or mobilising corporate assets for Israeli state or military bodies.⁶
• Not found: No public evidence identified of Israeli military/security contracting, defence supply, settlement operations or a Tonic-owned Israeli subsidiary, facility or workforce; targeted UN and specialist checks did not identify Tonic as a settlement-linked business.^{7, 8, 9, 10}

Target Profile

Key Facts:

• Tonic Nutrition Ltd was incorporated in 2019 and operates the Tonic Health consumer supplement brand.^{11, 13}
• Tonic raised £2.8 million in a reported 2025 Series A; reported investors included Nigel Wray, Tom Singh, Side by Side Partnership and Rubix Partners.¹⁹
• The dated 26 August 2025 register recorded 290,695 shares across 62 holdings, but those historical registered-share figures are not treated as current beneficial-ownership or voting percentages.^{16, 17}
• Tonic’s 2025 articles establish separate A and B ordinary-share classes and conditional governance rights, but the audits found no evidence that those governance provisions themselves created an Israel-related military, digital, economic or political act.²⁰

Executive Summary

Tonic Health is a UK consumer supplement brand operated by Tonic Nutrition Ltd. The strongest verified Israel nexus is economic: a Boots-hosted product-information PDF for Tonic Kids Multivitamins states that the product was “Made in Israel for Tonic Nutrition Ltd.” The evidence therefore supports an attributable manufacturing or sourcing relationship involving an Israeli producer for that product. It does not identify the manufacturer, factory address, contract value, procurement volume, batch date, production period or whether Tonic contracts with the factory directly or through an intermediary.¹

The audits also establish a narrower digital connection. Tonic’s live rewards service uses Yotpo. The Israel Innovation Authority identifies Yotpo as founded in Israel, and Yotpo’s own company page lists a Tel Aviv office.^{2, 21} Its 2026 subprocessor disclosure lists Yotpo Ltd and Akamai Technologies Israel Ltd in Israel among processors authorised to handle merchant end-user personal data. This establishes an Israel-linked processing pathway within the Yotpo service used by Tonic. It does not establish that Yotpo is Tonic’s principal commerce platform, that every Tonic customer record is processed or stored in Israel, or that Tonic’s contract, invoice or payment is with an Israeli Yotpo entity.^{3, 4, 5, 22}

The evidence does not support a military or settlement nexus. No public evidence identified a Tonic contract with the Israeli Ministry of Defence, IDF, Israeli security agencies or defence primes; military or dual-use products; military logistics; weapons components; or Israeli military end-users. Targeted checks of UN settlement-related sources and specialist reports did not identify Tonic as a settlement-linked enterprise. The Israeli manufacturing label states only “Made in Israel” and gives no basis to infer manufacture in the occupied Palestinian territory or an Israeli settlement.^{1, 7, 8, 9, 10}

The political audit likewise identified no public Tonic corporate statement on Israel-Palestine, no qualifying lobbying, anti-BDS activity, political donation, military-welfare donation, crisis mobilisation, state partnership or settlement advocacy. The Israeli manufacturing relationship is therefore treated as commercial supply-chain evidence rather than a political position.⁶

Under the fixed, human-vetted V6.5 scoring, the economic evidence produces the sole positive domain score: Economic 3.60. Military and Digital are 0.00. Political carries an incidental Impact score of 2.00, but with Magnitude and Proximity both at zero its domain score is 0.00. The resulting Complicity Index score is 300, placing Tonic Health in Tier D (Moderate Complicity). This classification is driven by the attributable Israel-made product relationship, while the substantial evidentiary limits and negative findings remain part of the record.

Timeline of Relevant Events

Corporate Overview

Tonic Health is the trading brand examined in the audits; its legal operator is Tonic Nutrition Ltd, a private UK company incorporated in August 2019. The public corporate record identifies Sunna van Kampen as founder, active director and sole active PSC, with Bradley James Waldron also serving as an active director.^{11, 15, 18, 13}

The audits identified external minority investment but no corporate parent. Reported funding included Henley Business Angels members in 2022 and a £2.8 million Series A in 2025. A replacement confirmation statement for the position at 26 August 2025 records a dispersed group of registered holdings in addition to van Kampen’s B shares. Those dated holdings do not establish current October 2026 beneficial ownership, and they do not override the unresolved discrepancy with the current PSC bands reported by Companies House.^{19, 16, 17, 23}

In the ECON audit’s bounded company and investment-source screening, no Israeli subsidiary, Tonic-owned Israeli factory, Israeli office, Israeli employee base, Israeli joint venture or acquired Israeli operating company was identified.^{11, 19, 6} The verified Israeli production relationship instead concerns an external manufacturing source for the specific Kids Multivitamins product represented by the Boots packaging.¹

The separate digital relationship with Yotpo is a vendor relationship.^{3, 2} Tonic’s rewards programme uses Yotpo software, while its core public storefront is Shopify-backed. Yotpo’s Israel-based headquarters and processing entities therefore form part of Tonic’s third-party technology supply chain, but Yotpo is not established as a Tonic subsidiary, controlled affiliate or primary commerce host.^{3, 4, 14}

The later supplements screened conditional governance actors including Lucy Mercey/Joseph Wray, Tom/Anna Singh and AwesomeAction/Peter Tighe, alongside SidebySide, Rubix and Nigel Wray leads. Dated appointment rights and the SBS fund/nominee chain are distinct from proven exercise or beneficial ownership; no blanket portfolio attribution is made. The record leaves private and unnamed-LP exposure unresolved; Rianta’s own disclosure names UK/US fund LP positions without enumerating their underlying investments.^{16, 17, 20, 25, 6}

No franchise relationship involving an Israeli entity was documented in the audits.

Domain Summaries

Military: Military

Mechanism of Involvement

No qualifying military mechanism was established. The Military audit’s bounded company, contract-name and authoritative-source searches found no public evidence identified of contracts, tenders, framework agreements or memoranda linking Tonic Health or Tonic Nutrition Ltd to the Israeli Ministry of Defence, IDF, Israel Prison Service, Border Police or another Israeli state-security body. It likewise found no verified defence-prime supply, tactical product, military component, weapons-system role, military logistics service or export-control record involving an Israeli security end-user. These are findings from that recorded search set, rather than an assertion that the PAX publication proves all possible relationships absent.^{6, 8}

The verified Israeli manufacturing evidence concerns a civilian children’s vitamin product. The relevant packaging states “Made in Israel for Tonic Nutrition Ltd” but identifies no military customer, government customer, defence programme or military application.¹

Counter-Arguments and Evidence Limits

The strongest defence is the character of the documented business itself: Tonic’s public catalogue concerns consumer vitamins, supplements, hydration, immunity, magnesium and related wellness products. Israeli manufacture of a civilian gummy product does not establish military supply.^{14, 1}

Targeted checks of PAX, OHCHR and other specialist sources did not produce a Tonic-specific defence or settlement-related military relationship.^{7, 8, 9} This remains a public-evidence conclusion rather than proof that undisclosed private relationships cannot exist.

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

Tonic operates an e-commerce business whose visible core storefront is Shopify-backed. Its live rewards programme uses Yotpo for loyalty, points, reviews, referrals and rewards.^{3, 14}

The Israel Innovation Authority identifies Yotpo as founded in Israel; Yotpo’s official company page lists a Tel Aviv office.^{2, 21} Its June 2026 subprocessor disclosure states that the list applies to merchant end-user personal data and identifies Yotpo Ltd in Israel and Akamai Technologies Israel Ltd in Israel among authorised processors. Because Tonic exposes a live Yotpo rewards service to shoppers, the audits concluded that there is a verified Israel-linked processing pathway within that service.⁴

This relationship did not meet the V6.5 threshold for a qualifying Digital frame. In the Digital audit’s bounded target/supplier searches, no public evidence identified Tonic supplying technology to Israeli state, military, intelligence, police or settlement customers; operating surveillance or biometric systems; participating in Project Nimbus; developing military AI; or owning Israeli R&D infrastructure. This reports the recorded source screen and does not establish exhaustive absence of undisclosed arrangements.⁶

Counter-Arguments and Evidence Limits

Yotpo is a third-party customer-engagement vendor rather than Tonic’s core business. The evidence does not establish that all Tonic data is stored in Israel, that Yotpo is Tonic’s primary host, or that Tonic uses optional AI functions marketed by Yotpo.^{3, 4}

The economic attribution of the Yotpo relationship is also unresolved. Yotpo’s merchant terms cover Yotpo Ltd and affiliates, while public billing information contemplates multiple group entities and Shopify-mediated billing, as documented in the Billing FAQ.²² No public evidence identified a Tonic-specific order form, invoice, Israeli payee, Israeli bank payment or Israel-attributable licence amount.⁵

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

The strongest and score-driving evidence is the Boots-hosted package artwork for Tonic Kids Multivitamins, which states “Made in Israel for Tonic Nutrition Ltd.” This is direct product-origin evidence establishing that a Tonic-branded consumer product was manufactured in Israel for the target company.¹

The audits therefore treated the relationship as an attributable manufacture-for/import-sourcing economic connection. The examiner-adjudicated V6.5 bands are fixed at Impact 3.60, Magnitude 7.00 and Proximity 7.50, producing a Economic domain score of 3.60.

The magnitude value applies the rubric’s standard-instance baseline because the record establishes no affirmative diminished-scale fact; it is not a claim of measured large volume. The proximity value reflects Tonic’s causal position as the named commercial principal for the manufacture-for act, without asserting proven direct factory privity.

The evidence does not identify the Israeli manufacturer, factory, sourcing intermediary, contract value, order volume, sales share or relationship duration. It also does not establish that Tonic owns the manufacturing facility, maintains an Israeli subsidiary, employs staff in Israel or receives Israel-specific revenue.¹

No settlement origin was established. The label says only “Made in Israel,” and the manufacturing address is unknown. Tonic was not identified by the audits’ targeted checks of the September 2025 OHCHR settlement-business database; nonappearance is not clearance of Tonic or its unidentified supplier.⁷

Counter-Arguments and Evidence Limits

The most significant limitation is temporal and quantitative. The packaging PDF was retrievable in October 2026 but is itself undated. It therefore does not establish when the depicted product was manufactured, whether the relationship continued after 19 July 2024 or the November 2024 ICC warrants, how long the sourcing relationship lasted, or its commercial value.¹

The audit also found no public evidence that other Tonic products share Israeli origin. Israeli origin was not established for Adult Multivitamin Gummies, Kids Immunity, Kids Calm, Baby Multivitamin Drops, Energy & Hydration or the broader range. The finding therefore remains product-specific.¹

There is also no evidence supporting a settlement attribution. Without a factory address, supplier identity or other territorial evidence, the product cannot be classified as settlement-made.^{1, 7}

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

No qualifying political mechanism was verified in the Political audit’s recorded corporate-page and separate actor/donation/lobbying searches. The audit found no public evidence identified of an official Tonic position supporting Israel or Palestinians, addressing Gaza, supporting or opposing BDS, or otherwise taking a corporate stance on Israel-Palestine.⁶

Those bounded searches identified no public evidence of Tonic or controlling principal Sunna van Kampen lobbying on Israel-Palestine, anti-BDS legislation, sanctions or settlement policy. The audit likewise found no verified donations to the IDF, FIDF, JNF/KKL, reservist funds or settlement organisations, and no mobilisation of Tonic cash, products, logistics or services for Israeli state or military bodies.⁶

The Israeli-made product is a commercial fact. In the absence of additional evidence, the audits did not treat sourcing from Israel as proof of political endorsement or a state partnership.^{1, 6}

Counter-Arguments and Evidence Limits

Tonic’s documented public campaigning concerns consumer health, nutrition and wellness-industry practices rather than Israel-Palestine. The audit found no reliable geopolitical comparator that would justify a “comparative silence” or double-standard finding.^{13, 6}

The fixed score nevertheless assigns Political Impact 2.00, classified as incidental. Magnitude and Proximity are both 0.00, so the resulting Political domain score is 0.00. This is the neutrality-floor rule: positive ECON sets political Impact to its floor only, without converting commercial sourcing into unsupported political conduct.

Named Entities and Evidence Map

Counter-Arguments

The strongest defence available from the audited record is that the verified Israel nexus is narrow. The principal evidence is a single Tonic-branded product label stating that the product was made in Israel. The audits did not establish Israeli ownership of Tonic, an Israeli subsidiary, a Tonic-owned Israeli factory, Israeli employees, Israeli state contracts, settlement production, military supply or political advocacy.^{1, 7, 8, 6}

The product-origin evidence also has important unresolved dimensions. The supplier and factory are unidentified; the document is undated; production volume, spend, sales share and duration are unknown; and the record does not prove that manufacturing continued after the legal milestones examined by the audits. Nor can the finding be extended to Tonic’s entire range.¹

The Yotpo relationship provides a documented Israeli technology connection, including an Israel-linked end-user-data processing pathway. But Yotpo operates as a third-party loyalty vendor within a broader stack whose core storefront is Shopify. Public evidence does not identify the Yotpo entity contracting with Tonic, the invoice issuer, payment destination or licence value, and therefore does not establish a Tonic-specific payment flow to Israel.^{3, 4, 5}

Finally, targeted settlement, military, political and civil-society checks produced material negative findings. Tonic was not identified in the settlement-business materials reviewed; no military or defence relationship was found; and no organised boycott campaign or Israel-Palestine political programme attributable to Tonic was established.^{7, 8, 6, 9, 10} Those findings materially constrain the interpretation of the positive economic evidence.

Complicity Index Score

Method: V6.5.

• V_MAX: 3.60 Avg_OTHERS: 0.00
• BRS Score: 300 Tier: D (Moderate Complicity)

V_MAX is driven entirely by Economic, where the examiner-adjudicated evidence establishes a Tonic-branded product manufactured in Israel for Tonic Nutrition Ltd. The military and digital domains have no mechanically eligible scoring frame, while Political’s neutrality-floor Impact contributes zero domain score because no separate political act supports positive Magnitude or Proximity.

The method is scale-free and evidence-only: Impact represents the character of the verified activity, Magnitude its scale, and Proximity its directness. The scores above are the fixed, human-vetted V6.5 result and are not recalculated in this dossier.

Methodology Note

• Evidence in this dossier is restricted to facts established by the four completed Military, Digital, Economic and Political audits. Unverified identity links, speculative investor exposure and unresolved private arrangements are not hardened into findings.
• V6.5 is scale-free: Impact (I) reflects the type or consequence of the documented activity, Magnitude (M) reflects its scale, and Proximity (P) reflects the directness of the target’s connection.
• Temporal qualification matters. Verified, concrete cessation or exit can diminish present activity; an undated source proves neither post-notice continuation nor cessation and receives no automatic historic discount.
• Entity attribution is non-transitive. Conduct by retailers, vendors, investors, lenders, minority shareholders, related people or similarly named organisations is not attributed to Tonic without evidence satisfying the audit’s attribution boundary.
• Settlement operation, where established, may engage both Economic and Political. Here, no settlement location or settlement-linked Tonic operation was verified, so no such dual attribution is made.
• The BDS priority guide and PAX report were checked for named inclusion only; neither is treated as proof of every target-specific negative finding. The broader negative findings report the bounded source/query records accompanying the domain audits.^{26, 8, 6}
• Where targeted checks found no supporting material, the audits use “No public evidence identified.” This means no qualifying evidence was found in the researched public source set; it is not proof that undisclosed conduct is impossible.