Very POLITICAL

Research date: 3 November 2026. Target: The Very Group Limited (Companies House 04730752), operator of Very, Very Ireland and Littlewoods. Findings are reported as data only. No scores, tiers or conclusions are assigned. Evidence older than five years is flagged [pre-2020]. This version extends the earlier audit with a check of the group’s stated customer count and of the structure and consideration of Carlyle’s November 2025 acquisition, in addition to the earlier examiner-directed checks on the Chair, Nadhim Zahawi. ¹

Corporate Communications & Public Stance

Statements. No public evidence identified of any official statement by The Very Group Limited on the Israel-Palestine conflict, either generic calls for peace or declarations of support, in the pages opened in this research. A Wikipedia article on the group reports no Israel/Palestine content, no charity-related political content and no political position ². A dated Business & Human Rights Resource Centre tracker of company responses to Gaza-related boycott calls (entries 2023-2025) names McDonald’s, Starbucks, Carrefour, Puma, Intel and others, but not Very, Littlewoods or Shop Direct ³. The Very Group’s corporate governance page, which describes the board and its sub-committees, and its meet-our-team page, which lists six executives, contain no statement on the conflict ^{4, 5}.

Comparative Silence. No public evidence identified of Very statements on Ukraine, Black Lives Matter, Pride or COVID-19 that could be contrasted with its silence on Gaza; searches on those topics returned no company-specific results. The Very Group’s public community communications that were found concern children’s literacy charity partnerships (see Lobbying, Advocacy, Financing & Logistics) ^{6, 7}.

Market Framing. The Irish competition regulator describes The Very Group as a multi-brand online retailer and financial services provider that owns and operates Littlewoods Ireland and Very Ireland, selling clothing, toys, sports equipment, home and garden goods, appliances, technology, beauty products and jewellery, and its page for the case gives no customer number ⁸. The group’s own 10 November 2025 announcement describes about 2,000 labels sold to 4.2 million customers across everything except food, annual revenue above £2bn, and a “Very Pay” flexible payment product regulated by the FCA ⁹. The group’s FY25 results release of 24 October 2025, covering the 52 weeks ended 28 June 2025, also refers to “our 4.2 million customers” in its notes to editors and reports Group revenue of £2.09bn and adjusted EBITDA of £307.1m; the page does not say whether 4.2 million is an active-customer measure ¹⁰. A 28 March 2023 FF News article on the group’s Freedom Finance partnership refers to the group’s 4.4 million customers, which is an older figure and not a conflicting current statement; it is added here as a dated historical figure and corrects no existing statement in this audit, while the 4.2 million statement is confirmed as the company’s current stated figure ^{11, 10, 9}. No public evidence identified of any region-specific or geopolitical market framing for Israel or the occupied territories ².

Act record (Corporate Communications). The corporate communications on ownership and results are the group’s own: acting entity: The Very Group Limited; recipient/audience: public, trade press and customers; channel: The Very Group’s own corporate newsroom website (theverygroup.com); earliest observation: 24 Oct 2025 (FY25 results release), latest observation: 10 Nov 2025 (ownership announcement, republished in trade press the same day); status: ended as single communications, both still retrievable at the research date; neither contains a reference to Israel or Palestine in the extracted text ^{10, 9, 12}.

Group response to the Chair’s political statements. No public evidence identified of any Very statement, in the pages opened, responding to or distancing the group from Nadhim Zahawi’s January 2026 move to Reform UK or his remarks on Iran; none of the reports of those events mentions Very ^{13, 14, 15}.

Operations in Occupied or Contested Territories

Territorial Presence. No public evidence identified of operations, equipment sales, service contracts, dealerships, subsidiaries or branches of The Very Group in Israeli settlements or other occupied or contested territories. The Companies House record lists UK head-office activity (SIC 70100) and a Liverpool registered office ¹. The Irish regulator’s description of the business covers online retail in the UK and Ireland ⁸.

Legal & Regulatory Scrutiny. On 26 September 2025 the UN Human Rights Office published an update of its database of businesses involved in settlement activity, listing 158 enterprises from 11 countries, including the UK, after reviewing 215 businesses and adding 68 and removing 7 against the 2023 list ^{16, 17}. Neither the BHRRC summary nor The National’s coverage names any UK-based company, and The National reports that no retailers are mentioned; no public evidence identified that Very, Littlewoods or Shop Direct is listed ^{16, 17}. Al-Haq stated on 30 September 2025 that the UK is one of 10 host states of listed companies, without naming any UK company ¹⁸. The full list of 158 names was not available to this research, so the absence is limited to the pages opened ¹⁶.

Civil Society & Boycott Campaign History. No public evidence identified of an organised boycott, divestment or sanctions campaign naming The Very Group, Very, Littlewoods or Shop Direct. The BHRRC boycott tracker covering Oct 2023 to Jan 2025 does not name them ³. No public evidence identified of any campaign naming The Carlyle Group Inc. in a search for BDS or divestment calls; the pages returned concerned the movement generally and none opened named Carlyle ³.

Act record (Operations). No act in the territories was documented, so no acting entity, recipient, channel or date range can be stated; the UN database update is a regulator publication dated 26 Sep 2025 that is a current list and is expected to be updated in future cycles according to Al-Haq’s description of a mandated annual update that has been delayed ^{17, 18}.

Internal Governance, Content & Retail Policies

Employee Relations. No public evidence identified of reports, controversies or legal actions concerning HR enforcement over employee speech, political symbols or union activity related to Israel-Palestine at The Very Group; a search on employee Gaza/Palestine actions returned no company-specific results ². The Wikipedia article’s listed controversies are the March 2024 resignation of auditor Deloitte (citing difficulty accessing information on certain financing arrangements within the wider group) and warehouse closures in 2006 and 2018, none related to the region ².

Platform & Editorial Policy. No public evidence identified of independent reports, academic studies or regulatory inquiries on algorithmic moderation, content suppression or editorial stance on the conflict at The Very Group, which the regulator describes as a retailer and financial services provider rather than a content platform ⁸.

Retail & Supply Chain Practices. No public evidence identified of reports or regulatory actions concerning the labelling, sourcing or categorisation of settlement-origin products by Very, Littlewoods or Shop Direct. Searches for settlement-labelling coverage returned general EU and UK labelling material without naming the group ⁸.

Brand Heritage & State Partnerships

Marketing Positioning. [pre-2020] The group traces its roots to Littlewoods, founded in 1923 as a football pools company by John Moores and his brother Cecil, and to Great Universal Stores’ home-shopping business; the Barclay brothers bought Littlewoods in November 2002 for £750 million and the Littlewoods home-shopping arm merged with Shop Direct in 2005 ². No public evidence identified of military heritage, defence-sector ties or state-security origins used in the group’s branding or PR; the Barclay ownership of that era is confirmed as ended in November 2025 ^{9, 2}.

Institutional Ties & Sponsorships. No public evidence identified of accepted state honours, hosted foreign government officials, formal partnerships with state academic or governmental institutions in Israel, or sponsorship of state-backed cultural or public-relations campaigns such as “Brand Israel”. The Chair, Nadhim Zahawi, is described in the group’s own announcement of his appointment as a former Chancellor of the Exchequer and Secretary of State for Education who was then a Conservative MP planning to stand down at the next general election ¹⁹. Previous ministerial office is a personal background fact and not a corporate partnership ²⁰.

Lobbying, Advocacy, Financing & Logistics

Political Lobbying. No public evidence identified of corporate lobbying, leadership roles in geopolitical pressure groups, or PAC-type donations by The Very Group related to regional policy, boycotts or trade legislation. A search of political-donation and lobbying-register sources returned only general material on UK political funding that did not name the group, and the Electoral Commission register was not queried directly ².

Financial Contributions. The Very Group’s documented charity partnerships are domestic literacy charities: Coram Beanstalk, from late 2019 to December 2023, for which the group reports £640,000 raised and support for one-to-one reading for more than 40,000 children ⁷. The National Literacy Trust, a three-year partnership beginning in 2025, with a charity ball on 3 July 2025 at ACC Liverpool ⁶. No public evidence identified of donations or sponsorships to parastatal organisations, settlement groups, the IDF or other military-welfare funds by The Very Group Limited ^{6, 7}.

Crisis Asset Mobilisation. No public evidence identified of The Very Group directing corporate resources, logistics, free services or infrastructure to state, military or state-aligned NGO efforts during the conflict ².

Act record (Financing).

• Act: charity partnership; acting entity: The Very Group Limited; recipient: Coram Beanstalk (children’s reading charity); channel: The Very Group’s own corporate newsroom website; earliest observation: late 2019, latest: 19 Dec 2023; status: ended, the release marks completion of the four-year partnership with £640,000 raised ⁷.
• Act: charity partnership and charity ball; acting entity: The Very Group Limited; recipient: National Literacy Trust; channel: The Very Group’s own corporate website; earliest observation: 2025 (event on 3 Jul 2025), latest observation: the page at the research date; status: continuing, as the page says the group supports the trust “for the next three years” and the research did not find an end date ⁶.
• Act: fund-raising by a parent-group entity; acting entity: The Carlyle Group Inc.’s direct lending fund (as named in the release), with the release distributed by its Israeli placement agent Value Advanced Investments; recipient: Israeli qualified private investors (the fund raised about 1.5 billion shekels, about $420 million, across three funds, with Carlyle’s share not broken out); channel: a PR Newswire release from Tel Aviv; date: 18 Feb 2025 (single dated observation); status: unknown at the research date ²¹.

Corporate Structure & Primary Mission

Foundational Mandate. The Very Group Limited is a private limited company incorporated on 11 April 2003 (formerly 2207th Single Member Shelf Investment Company Limited, March U.K. Limited, then Shop Direct Limited from 2008 to 2020) with SIC code 70100, activities of head offices ¹. No public evidence identified of a state-held golden share, a charter tying its mission to state geopolitical goals, or infrastructure functions separate from retail and financial services; the regulator describes it as a multi-brand online retailer and financial services provider ⁸.

Ownership chain.

• The Companies House PSC register shows VGL Finco Limited as the active person with significant control (notified 15 July 2021) holding 75% or more of shares and voting rights and the right to appoint or remove directors, replacing Shop Direct Holdings Limited (6 April 2016 to 15 July 2021) ²².
• The Irish competition regulator records Carlyle’s acquisition, via Bird Bidco Limited, of sole control of VGL Midco Limited, described as the parent of The Very Group Limited. The notification, publication and determination are all dated 7 November 2025, the case is marked completed and cleared as a simplified merger in retail trade, and the page states no consideration ⁸. The pages opened do not reconcile the intermediate holding entities, so VGL Finco Limited and VGL Midco Limited are recorded as they appear in each source ^{22, 8}.
• On 10 November 2025 the group announced the transaction completed, with Carlyle as owner and IMI continuing as a key stakeholder. The announcement gives no price or financial terms, does not mention administration or PwC, and says Carlyle and IMI have supported the business since 2021 and that the Barclay family’s roughly 20 years of involvement ended ^{9, 12, 23}.
• Consideration and structure (examiner question 2). Press coverage dated 9 January 2026 reports that PwC was appointed administrator of VGL Holdco, described as a holding entity separate from the operating business, in November 2025, and that the administration allowed Carlyle, a long-standing creditor, to take control for £1; one report states that Carlyle gained control through the insolvency of the holding company and not of the retailer’s operating business ^{24, 25}. A report dated 23 June 2026 likewise says Carlyle “acquired for £1” the business and that PwC was appointed administrator in November 2025 ²⁶. These are press reports, and no administrators’ document was retrievable, so the £1 is recorded as press-reported and not as an officially stated consideration ^{24, 25, 26}. This confirms the earlier audit statement that the company announcement and regulator page disclose no financial terms, and it corrects any reading of the earlier audit that placed the PwC administration on the business itself: the administered company named in the press reports is VGL Holdco Limited, not The Very Group Limited ^{9, 8, 24}.
• The Companies House filing history of The Very Group Limited for October 2025 to April 2026 shows no notice of administration and no change-of-PSC filing in that period, which is consistent with the administration being of a different company ²⁷. It does show the resignation of five directors effective 7 November 2025, adoption of new Articles on 21 November 2025, share allotments on 12 February 2026, 17 February 2026 and 5 March 2026 with stated capital of GBP 244,062,547, GBP 284,062,547 and GBP 294,062,547, four charges registered on 16 February 2026, and a confirmation statement dated 16 April 2026 ²⁷.
• Five directors resigned on 7 November 2025: Aidan Barclay, Howard Barclay, David Kershaw, Philip Peters and Stuart Winton; the register also shows Benjamin Fletcher resigning on 30 September 2025 and Jacqueline Humphries on 31 December 2025 ^{28, 27}.
• Discrepancy: RTE (16 February 2026) describes IMI as having taken “joint ownership” with Carlyle in November 2025, whereas the primary documents describe Carlyle as owner, Carlyle as acquirer of sole control and IMI as a key stakeholder; the primary documents are preferred and IMI’s percentage stake is not public in any page opened ^{29, 9, 8}.
• Later events: Carlyle put £150m of capital into the group on 16 February 2026 by converting some debt to equity and IMI became a major lender ²⁹. A report dated 23 June 2026 says Carlyle launched a formal sale auction seeking about £2bn, and names Elliott Advisors as having reportedly expressed interest and JD.com as reportedly weighing a bid, and names only the CFO, Edward Fry, as a group officer ²⁶.
• Press coverage of 9 January 2026 describes Carlyle’s earlier “significant capital injections”, including support in 2021 and an additional £85m in 2024, while the Wikipedia article describes a £125 million loan from Carlyle and IMI in February 2024 in exchange for a degree of control; the two descriptions of the 2024 funding were not reconciled in the pages opened ^{25, 2}. The group’s announcement dates Carlyle and IMI support from 2021, and the nature of the 2021 support is not established in the pages opened ⁹. The Wikipedia article also says ownership was spread across many companies with “an ultimate offshore owner” ².

IMI. International Media Investments is described as a subsidiary of the Abu Dhabi Media Investment Corporation controlled by Sheikh Mansour bin Zayed Al Nahyan, classed by State Media Monitor as state-managed and publishing no audited accounts ³⁰. IMI’s October 2025 stake in the events company MARI is reported without any Israel reference in the text ³¹. The group’s announcement describes IMI as a privately owned media group headquartered in Abu Dhabi ⁹.

Act record (Acquisition). Act: acquisition of sole control of VGL Midco Limited; acting entity: The Carlyle Group Inc., indirectly through Bird Bidco Limited; counterparty: the holding structure formerly controlled by the Barclay family, with VGL Holdco Limited reported as the administered entity; channel: the Irish competition regulator’s case page (ccpc.ie) and the group’s own newsroom (theverygroup.com); earliest and latest dated observation: 7 Nov 2025 (regulator determination) and 10 Nov 2025 (announcement); status: completed, as the regulator marks the case completed and the later filings and press show Carlyle in control and preparing a sale ^{8, 9, 26}.

Named-entity record (searched by name; domain: Israel-Palestine political, communicative and structural footprint).

• The Very Group Limited (target): searched; no Israel-Palestine statement, operation, listing or campaign found ^{2, 3}.
• VGL Finco Limited (immediate PSC, 15 Jul 2021 to present): searched by name; the results returned ownership-chain data only and no Israel-related finding ²².
• VGL Midco Limited (parent per the Irish regulator): searched by name together with Finco; no Israel-related finding ⁸.
• Bird Bidco Limited (Carlyle acquisition vehicle): searched by name together with Finco; no Israel-related finding ⁸.
• VGL Holdco Limited (holding company reported as placed in administration in November 2025): searched by name for the administration; the results concern the administration and sale only, and no Israel-related finding was made ^{24, 25}.
• PwC (administrator of VGL Holdco Limited, reported): searched within the administration queries; no Israel-related finding ^{24, 26}.
• The Carlyle Group Inc. (owner since November 2025): searched on Israel, BDS and UN-report topics; the only Israel-related finding is the Feb 2025 fund-raising release, and no boycott or divestment campaign was found ^{21, 8}.
• International Media Investments (IMI) (key stakeholder, lender): searched; no Israel-related finding in State Media Monitor or the MARI report ^{30, 31}.
• Sheikh Mansour bin Zayed Al Nahyan (controller of IMI’s parent per State Media Monitor): searched only within IMI queries; none found ³⁰.
• Abu Dhabi Media Investment Corporation (IMI’s parent): searched only within IMI queries; none found ³⁰.
• Aidan Barclay (director 2003 to 7 Nov 2025; former interim Chair): searched with Israel-donation terms; none found ^{28, 19}.
• Howard Barclay (director 2003 to 7 Nov 2025): searched with Israel-donation terms; none found ²⁸.
• Nadhim Zahawi (director since 13 Sep 2024; announced non-executive Chair 13 May 2024): searched on Israel, Gaza and Iran topics; findings are set out under Executive & Leadership Footprint ^{28, 19, 15}.
• Reform UK (Zahawi’s political party from 12 Jan 2026): searched for Israel and Gaza statements by Zahawi; none found, and party-level items are recorded under Executive & Leadership Footprint as context only ^{13, 32, 33}.
• Robbie Feather (Group CEO): searched with Israel, Gaza, Palestine and Ukraine terms; none found ^{34, 5}.
• Edward Fry, Nicholas Beighton, Timothy Franklin, Richard Mayfield, Paul O’Donnell (current directors): not searched individually on these topics within the research budget; the current officer list is the source for their roles ²⁸.
• Elliott Advisors and JD.com (reported bidders, June 2026): not searched individually; recorded only as reported interest ²⁶.

Executive & Leadership Footprint

Personal Philanthropy & Financing. No public evidence identified of personal donations, family-foundation grants or fundraising by Very’s executives or current directors to regional advocacy groups, parastatal organisations or military-welfare funds (FIDF, JNF/KKL and similar). Searches for donations to Israel-related causes by Aidan Barclay and Howard Barclay returned no relevant results ²⁸.

Public Advocacy & Statements: 18 October 2023. Nadhim Zahawi, the group’s non-executive Chair, spoke to The National on 18 October 2023, about two hours before the Al-Ahli Arab Hospital strike, and before his Very role was announced. He said a lasting settlement was needed so that “innocent Palestinians don’t have to die in such horrific circumstances”, described the Hamas attack as a “horrific scene of murder, maiming and mayhem by fundamentalists who do not speak for the Palestinian people”, said Gaza could be rebuilt with investment, called the Abraham Accords an “antidote” to fundamentalism and suggested neighbouring Arab states could provide peacekeepers ²⁰.

Public Advocacy & Statements: Commons debate of 16 October 2023. No public evidence identified, in retrievable pages, of the wording attributed to Zahawi in the 16 October 2023 Commons “Israel and Gaza” debate (“I want to add my voice to all those who stand with Israel and her inalienable right to defend herself against an unspeakable crime”); the official Hansard record and its mirror sites could not be retrieved, so the quotation is neither confirmed nor refuted, and the Wikipedia biography of Zahawi quotes no parliamentary statement on the subject ³⁵.

Public Advocacy & Statements: Iran, February to March 2026. Middle East Eye, in an article published on 28 February 2026, reports that Reform’s Nadhim Zahawi said the UK should offer the US “our full support with this operation” after the US-Israeli strikes on Iran; the article paraphrases the post, gives no time for it and describes him as a “Reform MP” ¹⁵. Left Foot Forward (March 2026) reports that “Reform’s Nadhim Zahawi also said that the UK should join the US and Israel’s bombing of Iran” ³⁶. A post by the Green Party leader Zack Polanski dated 10 March 2026, reproduced by The London Economic, quotes Zahawi as saying “The USA [has] our full support with this operation”, with the square brackets showing an edited quotation from a hostile third party ³⁷. The original X post was not opened, so its exact wording and timestamp are unverified, and none of the three reports mentions Very ^{15, 36, 37}.

Status at Very on 28 February 2026. The Companies House officer list, retrieved on 3 November 2026, shows Zahawi as an active director of The Very Group Limited, appointed 13 September 2024, with no resignation date, so the register shows him as a director on 28 February 2026 and at the research date, and it lists no officer with the role title Chair ²⁸. A news report dated 10 November 2025 on the Carlyle takeover says Zahawi, appointed in May 2024, “remains chairman”, which is the latest dated source opened that gives him the Chair title ³⁸. The Chair title on 28 February 2026 and at the research date is not directly confirmed in the pages opened: the Wikipedia biography says that in May 2024 “he became the Non Executive Chairman of The Very Group” without saying whether he still holds the role, and the group’s corporate governance page and meet-our-team page name no Chair ^{35, 4, 5}. No public evidence identified that he left the role or was replaced ^{26, 28}.

Reform UK membership. STV News reports that Zahawi, the former Conservative chancellor, joined Reform UK on 12 January 2026 at a press conference in central London, saying Britain needed to stop “drinking at the last chance saloon” and “really does need Nigel Farage as prime minister” ¹³. The New Arab dates the move to Monday 12 January 2026 ¹⁴. Neither report mentions Very, and the Companies House register shows him still a Very director after that date ^{13, 14, 28}. No public evidence identified of any Zahawi statement on Israel or Gaza after 12 January 2026; his only found post-defection statements concern Iran ^{15, 36}.

Reform UK party-level context (not Very acts). Novara Media, an advocacy-leaning outlet, reported on 9 July 2026 that Reform deputy leader Richard Tice visited Israel in September 2025 on funding from Reform Friends of Israel, and that a November 2025 delegation including then party chairman David Bull was funded by Israel’s foreign ministry through the firm Conexión Israel for more than £50,000; the article does not mention Zahawi and both trips predate his joining ³². Ynetnews quotes Tice in Israel: “We’ve got to get rid of Hamas”, without mentioning Zahawi ³³. These items concern Reform UK figures and are recorded only because Zahawi has been a Reform member since 12 January 2026 ^{32, 33, 13}.

Board Memberships & Affiliations. Zahawi was announced as the group’s non-executive Chair on 13 May 2024, replacing interim Chair Aidan Barclay, with a mandate on sales, profit growth and shareholder strategic options, and Companies House records his appointment as director on 13 September 2024 ^{19, 28}. Robbie Feather was promoted from retail managing director to Group CEO on 9 April 2024, succeeding Lionel Desclée; he previously led Fenwick and held roles at Sainsbury’s Argos ³⁴. Companies House shows seven current directors: Nicholas Beighton (29 Aug 2024), Robert Feather (26 Apr 2024), Timothy Franklin (12 Sep 2022), Edward Fry (1 Oct 2025), Richard Mayfield (26 Sep 2022), Paul O’Donnell (6 Aug 2024) and Zahawi (13 Sep 2024) ²⁸. No public evidence identified that any of them holds a seat or role in a pro-Israel or anti-BDS advocacy organisation or in a state-aligned Israeli academic institution; Zahawi’s party membership of Reform UK is a political party affiliation and is not such an organisation ^{28, 34, 19, 13}.

Constructive notice (post-19 July 2024 and post-November 2024). No public evidence identified of Very corporate political conduct on Israel-Palestine after the ICJ advisory opinion of 19 July 2024 or the ICC warrants of November 2024 ². Zahawi’s Palestine-related statement found (18 October 2023) predates both and he became a registered director on 13 September 2024 ^{20, 28}. His reported Iran remarks of about 28 February 2026 post-date both events, were made while he was a registered Very director, concern Iran rather than Palestine and are not attributed to Very in any report opened ^{15, 28}.

Settlement nexus. No public evidence identified of sponsorship of settlement events, donations to settlement entities or public endorsement of the settlement enterprise by The Very Group or the principals named above ^{3, 16}.

Act record (Executive).

• Act: public interview statement; acting entity: Nadhim Zahawi, in a personal capacity (he was a former Chancellor and MP and not yet Chair of Very); recipient/audience: readers of The National, an Abu Dhabi-based news publisher, with audience size not public in the page; channel: The National’s own news website; earliest and latest observation: 18 Oct 2023 (single article); status: ended as a single communication, with no later related statement on Gaza found and the article’s continued availability observed at the research date ²⁰.
• Act: social-media post on Iran; acting entity: Nadhim Zahawi, in a personal capacity as a Reform UK member and, per the register, a Very director; recipient/audience: the US government and the public, with follower numbers not public in the pages opened; channel: X, as reported by Middle East Eye (the original post was not opened); earliest and latest dated observation: 28 Feb 2026 (Middle East Eye publication date), with the 10 Mar 2026 Polanski post as the later quotation of the wording; status: unknown, since whether the post remains online was not established ^{15, 37}.
• Act: change of political party; acting entity: Nadhim Zahawi; recipient: Reform UK; channel: a press conference in central London, reported by STV News and The New Arab; date: 12 Jan 2026; status: continuing, as no report opened shows him leaving the party and the register shows him still a Very director ^{13, 14, 28}.