Tonic Health ECONOMIC

Request ID: 11e63e8f-1490-4806-87de-2a01a1382a61 Research cut-off: 6 October 2026 Target boundary: the UK vitamins and supplements brand at Tonic Health, founded by Sunna van Kampen; the unrelated US healthcare-software business with a similar name is outside scope.

Target identity, ownership and evidence boundary

The operating legal entity is Tonic Nutrition Ltd, company number 12174856, an active UK private limited company with registered office at The Courtyard Shoreham Road, Upper Beeding, Steyning, West Sussex BN44 3TN.¹ It was incorporated on 27 August 2019 [pre-2020].¹ Tonic’s own founder story also dates the brand’s launch to 2019 [pre-2020] under founder Sunna van Kampen.^{2, 3}

The current Companies House PSC register identifies Sunna van Kampen as the sole active person with significant control, holding more than 50% but less than 75% of both shares and voting rights.⁴ Companies House lists Sunna van Kampen and Bradley James Waldron as active directors.⁵ The founder’s Companies House appointments also show prior UK company roles but do not identify an Israeli holding company or family-office vehicle.⁶

Tonic raised £2.8 million in a 2025 Series A, with reported investors including Nigel Wray, Tom Singh, Side by Side Partnership and Rubix Partners.⁷ Side by Side records Tonic Health as a portfolio investment first made in 2025.⁸ Henley Business Angels had previously reported member investment in Tonic in 2022.⁹ Republic Europe’s 2026 secondary transaction materials identify Tonic Nutrition Ltd and a last/indicative valuation of £15.5 million; the transaction was a sale of existing shares rather than evidence of a new parent company.^{10, 11} These public sources do not disclose a complete post-Series-A minority cap table, while the statutory PSC position remains founder control.^{4, 10}

Companies House filing history records statutory accounts, confirmation-statement and share-capital filings continuing into 2026.¹²

Companies House records two outstanding 2025 charges in favour of Flexport Capital LLC, showing a financing relationship but not equity control.¹³

Authoritative-source checks and Israeli-Nexus Floor

The 26 September 2025 OHCHR update A/HRC/60/19 is the current UN database report on businesses involved in specified settlement-related activities; its annexes list the enterprises assessed as involved or no longer involved.¹⁴ Targeted checks of that report did not identify Tonic Health, Tonic Nutrition Ltd or Sunna van Kampen.¹⁴ Targeted checks of the 2025 Special Rapporteur report A/HRC/59/23 likewise did not identify those names.¹⁵

For the rubric’s Israeli-Nexus Floor factors: Tonic was founded through a UK company in 2019 [pre-2020], not as an Israeli-incorporated company.^{1, 2} no public evidence identified of an Israeli headquarters or principal place of management; the statutory registered office is in West Sussex and current industry coverage describes Tonic as a UK supplement brand.^{1, 16} no public evidence identified of Israeli tax residency or Preferred Technology Enterprise status. No public evidence identified of Israeli beneficial control: the sole statutory PSC is British founder Sunna van Kampen with a >50% and <75% position.⁴ The Israeli-origin manufacturing evidence described below is a supply-chain relationship and does not by itself establish Israeli ownership, domicile, tax residence or headquarters.

No public evidence identified that Tonic Nutrition Ltd has acquired or holds a controlling stake in an Israeli operating company. No public evidence identified of an Israeli subsidiary, acquired Israeli brand, Israeli factory owned by Tonic, or Israeli employee base in the company and investment materials reviewed.^{1, 7, 8, 10}

Supply Chain & Sourcing Relationships

Direct supplier relationships

The strongest retrievable product-origin evidence is a Boots-hosted Tonic packaging PDF for Kids Multivitamins / max strength gummies, age 4–12 years. Retrieved on 6 October 2026, the artwork states “Made in Israel for Tonic Nutrition Ltd” and gives Tonic’s UK and German address details.¹⁷ This directly establishes Israeli manufacture for that exact product line, but the artwork does not identify the factory, supplier legal name, production date, batch date or contract term.¹⁷

The public records reviewed do not name the Israeli contract manufacturer. No public evidence identified of a verified direct relationship with Mehadrin, Hadiklaim, Galilee Export, Agrexco successors, or another named Israeli agricultural exporter. Generic Israeli gummy-manufacturer materials were not treated as supplier evidence because they did not name Tonic Nutrition Ltd.

Importer of record structure

No public evidence identified of a Tonic-owned Israeli subsidiary, joint venture or dedicated import entity acting as importer of record. The retained packaging identifies Tonic Nutrition Ltd as the company for which the Kids Multivitamins gummies are made, but it does not disclose the customs importer of record or name the Israeli manufacturer.¹⁷

Seasonal sourcing patterns

No public evidence identified of recurring seasonal procurement from Israeli agricultural suppliers. The verified Israel nexus concerns a manufactured vitamin-gummy product, not seasonal fresh produce.¹⁷

Third-party and indirect sourcing

The retained packaging shows that the Kids Multivitamins gummies are made in Israel for Tonic Nutrition Ltd, but it does not establish whether Tonic contracts directly with the factory or through a sourcing intermediary.¹⁷ no public evidence identified of a named distributor, reseller or white-label intermediary responsible for the Israeli manufacture.

Current third-party marketplace availability in Israel was not treated as proof of Tonic-authorised Israeli distribution because retailer/vendor conduct cannot be attributed to Tonic without evidence of authorisation; the retained target-specific packaging establishes manufacture only.¹⁷

Product Origin, Labeling & Regulatory Compliance

Product-origin evidence

The repaired submission retains one product-origin finding: the Boots-hosted packaging artwork for Kids Multivitamins / max strength gummies, age 4–12 years states “Made in Israel for Tonic Nutrition Ltd.”¹⁷ No public, retrievable source in this submission establishes Israeli origin for Tonic’s Adult Multivitamin, Kids Immunity, Kids Calm, Baby Multivitamin Drops, Energy & Hydration, or the wider range. Tonic’s own current Adult Multivitamin product page confirms that product remains in its range but does not disclose country of origin.¹⁸

Settlement-origin products

No public evidence identified that any Tonic product is manufactured in, sourced from, packed in, or distributed from an Israeli settlement in the West Bank including East Jerusalem, or the occupied Syrian Golan. The retained packaging states only “Made in Israel” and does not provide a factory address, so it is insufficient to infer settlement origin.¹⁷ Tonic and its principals were not identified in the 2025 OHCHR settlement-business database checks described above.¹⁴

Labeling compliance

The retained Kids Multivitamins packaging explicitly states “Made in Israel for Tonic Nutrition Ltd.”¹⁷ no public evidence identified of a DEFRA, customs, Trading Standards or other regulatory enforcement action against Tonic concerning country-of-origin or settlement-origin labelling.

Corporate labeling policy

No public evidence identified of a Tonic corporate policy specifically addressing products from occupied or contested territories. Tonic’s current public brand and product pages describe ingredient/formulation and consumer-health positioning but do not identify such a territorial sourcing policy.^{3, 18}

Investment, Capital & Financial Exposure

Foreign direct investment

No public evidence identified that Tonic Nutrition Ltd owns a factory, warehouse, office, logistics hub, data centre, real-estate asset or subsidiary in Israel or occupied territory. The verified Israel link is manufacture of the Kids Multivitamins gummies; the packaging does not establish ownership of the manufacturing facility.¹⁷

R&D and innovation centres

No public evidence identified of a Tonic-owned R&D centre, innovation lab, accelerator or technology facility in Israel. Current 2026 industry coverage describes Tonic’s product development and UK retail expansion without identifying an Israeli Tonic R&D operation.¹⁶

Parent and beneficial ownership flows

No parent company was identified in the statutory or funding records reviewed. Sunna van Kampen remains the sole PSC, with >50% and <75% of shares and voting rights.⁴ Reported external capital includes the 2022 Henley Business Angels investment and the 2025 £2.8m Series A involving Nigel Wray, Tom Singh, Side by Side Partnership and Rubix Partners.^{7, 8, 9} no public evidence identified that Israeli capital beneficially controls Tonic Nutrition Ltd.

Portfolio and fund exposure

No public evidence identified that Tonic Nutrition Ltd itself holds Israeli-domiciled listed securities, Israeli sovereign bonds, Israel-focused funds, settlement-active company portfolios or Israeli defence-company securities. Tonic is a private consumer-health operating company, and its public funding materials concern equity financing of Tonic rather than an investment portfolio.^{7, 8, 10}

Operational Presence & Market Activity

Physical footprint

No public evidence identified of a Tonic-owned office, sales centre, warehouse, retail location or support centre in Israel or occupied territory. The current statutory registered office is in West Sussex.¹ The Kids Multivitamins packaging shows Israeli manufacture but does not show that Tonic owns or operates the producing facility.¹⁷

Employment and tax contribution

No public evidence identified of Tonic employees based in Israel, Israeli payroll, Israeli VAT/tax registration, or Israeli Preferred Technology Enterprise status. The sole PSC is recorded as British and resident in the United Kingdom.⁴

Market positioning

No public evidence identified of Tonic characterising Israel as a strategic sales market, regional hub or material export market. Current company and industry material instead describes a UK-focused consumer supplement business with broad UK retail distribution.^{3, 16, 19}

Third-party cross-border marketplace listings were not treated as evidence of Tonic market entry, because they do not establish an authorised distributor or local Tonic operation; the retained packaging supports only the product-origin finding.¹⁷

Corporate Structure & Foundational Ties

Founding and incorporation history

Tonic Nutrition Ltd was incorporated in the United Kingdom on 27 August 2019 [pre-2020], and Tonic’s own history identifies Sunna van Kampen as founder of the brand in 2019 [pre-2020].^{1, 2, 3} no public evidence identified that the target was founded or originally incorporated in Israel.

Headquarters and domicile

The legal domicile is the United Kingdom and the current registered office is in West Sussex.¹ FEBE’s 2024 company profile described Tonic as London-based, consistent with its UK operating history.¹⁹ no public evidence identified of an Israeli headquarters, dual headquarters or legacy Israeli headquarters.

State and institutional linkages

No public evidence identified of Israeli state ownership, an Israeli government board appointee, an Israeli government contract, or designation of Tonic as Israeli critical national infrastructure. The current statutory ownership/control record is private and founder-controlled.⁴

Structural governance features

No public evidence identified of a golden share, founder-right mechanism, charter restriction or other governance feature tying Tonic Nutrition Ltd to the Israeli state or Israeli policy objectives. Public Companies House records show ordinary UK private-company governance with a founder PSC and directors.^{4, 5}

Profit Repatriation & Economic Contribution

Revenue attribution

No public evidence identified of a geographic revenue figure for Israel. Republic Europe’s 2026 materials provide company-level growth/valuation information but do not disclose Israel-specific revenue.^{10, 11} The Kids Multivitamins packaging establishes manufacturing exposure but does not quantify the value paid to an Israeli manufacturer.¹⁷

Profit flows

No public evidence identified showing profits generated in Israel and repatriated to Tonic, or global Tonic profits repatriated into Israel through Israeli ownership. The available evidence identifies a UK founder-controlled company and one specifically evidenced Israel-made product, without supplier contract value, margin or payment-flow disclosure.^{4, 17}

Economic ecosystem role

No public evidence identified of an Israeli government, industry body or other authoritative source describing Tonic as a key Israeli employer, sector anchor, infrastructure provider or nationally significant Israeli company. The current public company profiles describe a UK supplements brand.^{16, 19}

Additional rubric-specific checks

Acquired Israeli subsidiaries: no public evidence identified of an Israeli operating company acquired or controlled by Tonic Nutrition Ltd.^{1, 7, 10}

Financing the State: no public evidence identified of Israeli sovereign-debt underwriting, Israel Bonds sales, direct lending to OHCHR-listed settlement businesses, or insurance underwriting by Tonic. The company is a consumer supplement business rather than a disclosed financial-sector operator.^{1, 3}

Controlling principals: Sunna van Kampen is the sole statutory PSC; no public evidence identified in the sources reviewed of a material personal or family-office investment by him in an Israeli operating company that can be attributed under this audit rubric.^{4, 6} Bradley James Waldron is an active director; no public evidence identified in the sources reviewed of an attributable Israeli investment by him.⁵

Group attribution: No parent or controlled Israeli group entity was identified. Minority investors reported in the 2025 funding round were not treated as Tonic-controlled entities, and their unrelated conduct was not attributed to Tonic.^{7, 8}

Constructive notice / post-19 July 2024 and post-November 2024: The Boots-hosted Kids Multivitamins packaging PDF was retrievable on 6 October 2026 and states “Made in Israel for Tonic Nutrition Ltd.”¹⁷ The artwork does not disclose a production date, batch date, artwork revision date, or supplier-contract term. No public evidence identified from this source set proves that the Israeli manufacturing relationship continued, renewed, or generated new production after 19 July 2024 or November 2024.¹⁷

Settlement nexus: no public evidence identified of operations, sales, sourcing, distribution or revenue specifically in or from Israeli settlements. The manufacturing address is not publicly established in the sources reviewed, and the 2025 OHCHR database does not identify Tonic or its controlling founder in the targeted checks.¹⁴

Evidence gaps

The Israeli contract manufacturer’s legal name and production-site address remain unidentified. No public manufacturing agreement, customs record, importer-of-record filing, procurement value, production-batch date or supplier-payment figure was found. The full minority cap table after the 2025 Series A is not disclosed in the sources reviewed. No public geographic revenue split, Israeli tax filing, Israeli employee count, occupied-territory sourcing policy or settlement-specific product record was identified.

Dated ownership and governance supplement

The replacement confirmation filing records 62 registered holdings totalling 290,695 shares: 190,695 A Ordinary and 100,000 B Ordinary. On that dated share count, Sunna van Kampen held 100,000 B shares, a historical share-count ratio of 34.4003%; Tom Singh and Anna Singh together held 25,727 A shares, 8.8502%; Lucy Mercey and Joseph Wray together held 26,002 A shares, 8.9448%; AwesomeAction Limited held 17,292 A shares, 5.9485%; Side By Side Partnership held 8,450 A shares, 2.9068%; and Rubix Venture Partners held 1,625 A shares, 0.5590%. These percentages are calculations against the 290,695-share total in that filing and are not current October 2026 voting, beneficial-ownership or control percentages.²⁰

The dates require separation. The Companies House filing index identifies the confirmation statement as at 26 August 2025 and the replacement filing index date as 6 May 2026; the replacement PDF records receipt on 24 April 2026 and original-document registration on 22 October 2025.^{20, 21} The current Companies House PSC record supplied by the root reports Sunna van Kampen in the greater-than-50%-and-less-than-75% bands for shares and voting rights, while the dated confirmation share register gives 100,000 of 290,695 registered shares, or 34.4003%. The supplied primary evidence does not reconcile those records, and no exact October 2026 ownership or voting percentage is inferred.^{20, 22}

The articles were adopted on 23 June 2025 and filed on 21 July 2025. They treat A and B as separate ordinary-share classes ranking pari passu subject to stated exceptions. Article 7.3 provides one vote per Equity Share on a poll and contains no B-share vote multiplier.^{23, 21} The same articles define BSI Shareholders as Lucy Mercey and Joseph Wray and give them jointly one BSI Director appointment right while the specified holding condition continues; this is a joint right to one appointment, not two individual appointment rights or an individual absolute veto.²³

Article 22.4 provides a director-appointment route for an Investor other than BSI holding, together with the permitted associated holdings specified by the articles, at least 5% of issued Equity Shares. The articles expressly provide aggregation treatment for Tom Singh with Anna Singh and for Ranjit Munro with Kuldip Singh Dhillon. On the dated 290,695-share register, Tom and Anna’s 25,727 shares exceed 5%, whereas Ranjit Munro and Kuldip Singh Dhillon’s combined 10,234 shares represent 3.5205%. Continuing holdings, status under the separate Shareholders’ Agreement, delivery of any appointment notice and actual exercise of any right are not established by these filings.^{20, 23}

The articles define Investors and Major Investors by reference to a separate Shareholders’ Agreement, so the articles alone do not establish the complete individual membership of those contractual categories. Their Investor Majority definition concerns more than 50% of shares held by Major Investors rather than more than 50% of the company.²³ Board quorum ordinarily includes the Founder Director and BSI Director to the extent appointed, but article 24 contains interested-director and adjourned-meeting exceptions, so the provision does not establish an absolute individual veto. Article 24.6 separately gives the eligible Founder Director a second or casting vote on tied board votes; this is a board right and does not create a B-share super-vote under article 7.3.²³

The written resolution circulated on 1 April 2026 authorised the directors to allot up to 6,524 additional A Ordinary shares and disapplied the relevant pre-emption provision for that authorised allotment. The filing was registered on 14 May 2026. The resolution is authority to allot, not evidence that all or any of those 6,524 shares were actually issued, paid for or added to the current capital denominator.²⁴

These ownership and governance records establish dated holdings and conditional governance rights only. They do not themselves establish a qualifying political/welfare, military-output, digital-technology or economic-capital/operations act by any shareholder, investor or related person, and they do not establish that any conditional appointment right was exercised. Absence of such evidence from these particular filings is not evidence that no such act or exercise exists elsewhere.^{20, 23, 24}

Article 10.1 requires written majority class consent for variation or abrogation of special class rights, with combined-class treatment when classes are treated alike and exceptions under articles 10.2, 10.3 and 17.6. Sunna’s sole registered B holding makes this a relevant dated formal-right protection, not a universal transaction veto. The articles define SBS as the SidebySide EIS Venture Fund acting through WCS Nominees Limited, represented by The SidebySide Partnership International Limited; that definition does not alone reconcile all registered-holder labels or establish an observer seat, individual veto or beneficial percentage.^{20, 23}

Fresh ECON screening of newly documented governance actors

Companies House confirms Lucy Penelope Mercey as a current director of Brendon Street Investments Limited (01066133; appointed 11 April 2025) and Juno Investments Limited (07659145; appointed 27 April 2026).^{25, 26} Brendon Street’s PSC is Juno; Juno’s current PSC is Royal Bank of Canada, recorded with 75% or more of shares/votes “with control over the trustees of a trust”, while Nigel Wray’s Juno PSC entry ceased on 29 October 2024.^{27, 28} Those records do not identify Lucy Mercey, Joseph Wray or another individual as trust beneficiary, so no beneficial economic ownership is inferred through that chain.^{27, 28}

Companies House identifies Joseph Peter William Wray as a director and >50%<75% shares/votes PSC of Boot Room Hospitality Limited (15529393); MBN says Joe Wray and Will Samler used Boot Room to acquire the MBN brand/assets in May 2024.^{29, 30, 31} The root-supplied Tonic snapshot names its holder only as Joseph Wray, without a unique identifier establishing that cross-identity, so Boot Room remains a candidate identity and its assets are not attributed to the Tonic holder.^{29, 32}

Rianta says it advises Tom Singh and his family, invests directly across the UK, Europe and US, and that the family has unnamed LP positions in UK and US venture funds.^{33, 34} Its UK establishment is BR009421 of Guernsey company FC027615; Tom Singh and Anna Singh are not listed among the current FC027615 officers.^{35, 36} Fresh searches found no named Israeli operating company, Israel-focused fund, Israeli state-financing instrument or settlement asset attributable to Tom or Anna in the opened source set; unnamed/private LP exposure remains unresolved.^{33, 34, 36}

Peter Noel Tighe is a current director of AwesomeAction Limited (11166287) and was a Tonic director from 7 April 2020 to 1 March 2021.³⁷ The root-supplied 2026 Tonic resolution signature for AwesomeAction is not treated as ownership/control evidence.³⁸ Fresh exact-name/entity searches found no qualifying Israeli company/fund/state-financing/settlement-asset exposure for Peter Noel Tighe or AwesomeAction in the opened source set.³⁷

Earlier named-investor screening - retained bounded findings

Searches of SidebySide, Rianta/Singh and Rubix found no public evidence identified in opened sources of a current Israeli operating-company, Israel-focused fund, sovereign-financing or settlement-linked holding; Rianta’s unnamed LP positions leave indirect exposure unresolved.^{39, 40, 41}

Examiner-directed check - Yotpo contracting, billing and Israel-attributable economic flow

Tonic’s live Rewards page currently exposes an operational loyalty and referral programme: shoppers can earn points for purchases and reviews, receive birthday rewards, progress through Member/Insider/Champion tiers, redeem points for products and participate in a refer-a-friend offer. The page also loads multiple widget assets from cdn-widget-assets.yotpo.com. This verifies a current Yotpo-linked loyalty implementation, but the public Tonic page does not disclose an Order Form, invoice, supplier legal entity, licence fee, payment route or contract value.⁴²

Yotpo’s current merchant Terms of Service, updated 22 March 2026, define the client as the person or legal entity licensing the services and define “Yotpo” collectively as “Yotpo Ltd. and its affiliates.” Loyalty and Referrals is one of the products covered. The terms state that applicable services, fees and usage limits are determined by an Order Form or may be presented within the Yotpo or Shopify application. The same terms refer generally to payment to “Yotpo” and, for businesses outside the United States, specify English and Welsh governing law and London jurisdiction. They do not state that a UK merchant using Loyalty necessarily contracts with, is invoiced by, or remits payment to Yotpo Ltd. in Israel.⁴³

Yotpo’s current Loyalty & Referrals pricing shows a free plan, a Pro plan starting at $199 per month and custom-priced Premium and Enterprise plans. Current feature packaging places VIP tiers and free-product redemption in Premium; Tonic’s live programme visibly has spend-based tiers and product redemptions. Those similarities do not establish Tonic’s contracted tier or price: they cannot exclude a legacy package, individually negotiated arrangement, bundle, migration or later change in Yotpo’s public feature packaging.^{42, 44}

Yotpo’s own Billing FAQ makes the missing merchant-specific evidence material. It says billing details for annual prepaid premium customers are based on the signed contract, billing frequency is determined by the contract, and past invoices are available only through the customer’s billing portal/email. It also states that billing information for Shopify-platform customers may be processed through the Shopify App Market. Separately, the FAQ publishes document links for banking/tax materials for several group entities, including Yotpo UK, Yotpo Inc. and Yotpo Ltd. The existence of an Israeli Yotpo Ltd. bank route therefore does not establish that Tonic uses it; the same public billing materials contemplate other Yotpo entities and payment channels.⁴⁵

Yotpo’s corporate and processing disclosures likewise do not resolve the merchant counterparty. Its June 18, 2026 subsidiary/subprocessor disclosure identifies Yotpo Ltd. as the Israel headquarters and Yotpo UK Limited as a UK sales branch containing sales and customer-success teams, alongside US, Australian, Bulgarian and Canadian group entities. The same disclosure lists Israeli entities among processors used in service delivery.⁴⁶ Yotpo’s June 2026 Privacy Policy separately states that Yotpo Ltd. is headquartered in Israel and Yotpo UK Limited is established in the UK, and that personal data may be processed in Israel and other jurisdictions.⁴⁷ Companies House confirms Yotpo UK Limited is an active UK private company.⁴⁸ These facts establish group structure and an Israel-linked service-processing footprint; they do not establish which entity contracted with or billed Tonic, nor that Tonic licence revenue was booked or remitted to Israel.

No public evidence identified in this focused search ties Tonic’s current Yotpo use to an Order Form with Yotpo Ltd. in Israel, an invoice issued by an Israeli entity, payment to an Israeli bank account, a disclosed Israel-attributable licence-revenue amount, or another Tonic-specific monetary flow to Israel. The contracting entity, invoice issuer/payee, payment channel and currency, contracted product tier, licence value, contract dates and any intercompany revenue allocation remain publicly unknown. A Tonic-specific Order Form, invoice, Shopify app-billing record or equivalent merchant account record would be needed to establish that economic attribution. Israel-linked processing entities remain relevant to the existing digital-supply-chain evidence but are not, by themselves, evidence of an Israeli contracting/billing entity or payment by Tonic.