This is the story of a company that did not exist in April 2020 — and that, according to the Australian Tax Office equity report, ranked in the top 600 companies in Australia by income for the financial year ending 30 June 2022. That income figure: $737 million. Higher than Diageo, L'Oreal and Sydney Tools.
2San Pty Ltd describes itself as "a trusted global Tier 1 supplier of high-quality innovative healthcare products and solutions that clean, test and protect." It came to prominence through the supply of Rapid Antigen Tests to Central and State governments in Australia during the pandemic.
The Company and Its Owners
2San operates across Australia, Denmark, the United Kingdom and the United States. It is jointly owned across four jurisdictions:
Covid Contracts: What Has Been Found
Government contracts awarded to 2San have been identified across Australia and the UK, from incorporation through to 30 June 2022:
The total maximum value of these identified contracts, from incorporation through to 30 June 2022, is approximately $72 million. That is a significant figure. It is also, as a fraction of $737 million, deeply insufficient as an explanation.
The $665 Million Question
"To be in the top 600 companies in Australia after one full year of trading is remarkable. It is a story which requires an explanation."
Brethren Exposed Investigation — July 2024The import data supports this further. The increase in Medical Equipment exports from Denmark to Australia during the relevant period is significant — 2San may account for as much as 25% of imports from Denmark in this sector during those years. The Danish entity was supplying goods that were then sold in Australia, but the identity of who was buying $665 million worth of those goods remains the unanswered question at the centre of this investigation.
Following publication of this investigation, a reader identified CoShield (coshield.com) as the likely "unknown company" referenced above — a company that appears to have been the undisclosed purchaser accounting for the revenue gap. Notably, CoShield's staff page was removed from its website directly after the ATO raid at UBT's Sydney Olympic Park premises in March 2024. CoShield is connected to Caleb Hall, the Global CEO of UBT and a continuing director of GAP Global Pty Ltd. This remains reader-sourced intelligence, not independently verified by Brethren Intelligence, but is noted here as a significant lead.
Regulatory Issues: The TGA's Response
2San's rapid growth attracted regulatory attention. Two significant interventions by the Therapeutic Goods Administration (TGA) have been recorded.
In August 2022, 2San Pty Ltd was fined $66,600 for allegedly failing to provide ongoing evidence to support the performance of its Covid-19 rapid antigen tests.
In July 2024, 2San entered into an enforceable undertaking with the TGA following findings of unlawful import and supply of medical devices. Under this undertaking, 2San is required to:
Mark Hewlett and the UKHSA Connection
The Story Continues
The story of 2San is not a completed investigation — it is an ongoing one. A company that did not exist in April 2020 reported $737 million in income in its first full year of trading, hired the executive team responsible for the UK's Covid procurement programme, attracted two TGA interventions, and had its most closely associated company apparently remove its staff page immediately after the ATO raided the PBCC's central business hub. The full picture of how that $737 million was generated has not yet been established.