No. This product is not soy free as it lists 2 ingredients that contain soy.

Is McVitie's Digestives ChocTops Milk Chocolate Soy Free?

No. This product is not soy free as it lists 2 ingredients that contain soy.
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Ingredients

Wheat flour, milk chocolate (15%) [sugar, cocoa mass, cocoa butter, milk solids, vegetable oil (shea, palm), butter oil (milk), emulsifiers (322 (soy), 476), salt, flavouring], cream filling (13%) [vegetable oil (palm, sunflower), sugar, milk solids, maltodextrin, emulsifier (322) (soy), salt, flavouring], wholemeal wheat flour, sugar, palm oil, water, invert syrup, malt extract (barley), wheat bran, cocoa butter, raising agents (500, 450, 503), milk solids, salt, emulsifiers (481, 322 (soy)), flavouring, pasteurized egg, colour (150a), enzyme.

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Soy Free? McVitie's Digestives ChocTops Milk Chocolate | Spoonful