About Responsible lobbying policy

Canongate is committed to ensuring our business is a force for good. In terms of policy advocacy we want to ensure that what we do supports an equitable, just, inclusive and regenerative society. This policy applies to all lobbying and advocacy activities undertaken by our employees in our name.

All advocacy and lobbying efforts must adhere to the following principles:

• Positive impact. We will only lobby for policies that would bring a positive benefit to society or the environment.
• Reliable data. Our policy position will be based on reliable evidence, including scientific data where relevant.
• No political donations. We will not donate, either in kind or financially, to any political party.
• Anti-corruption and anti-bribery. We will adhere to our Anti-corruption and anti-bribery policy and stress-test all lobbying activities against this policy before committing to them.
• Engagement with other organisations. Prior to engaging an intermediary organisation for the purposes of any lobbying activity, we will ensure that their principles and ambitions are in alignment with Canongate’s own. If we are not aligned we will attempt to influence their lobbying position. If we cannot reach alignment with them, we will not engage the organisation for lobbying. If we discover at any time that they have acted in contravention of our policies or principles we will end the engagement.

We will report and update annually on our website:

• The latest version of our responsible lobbying policy.
• Material lobbying and advocacy activities.
• Our Anti-corruption and anti-bribery policy.
• Engagement with other organisations on lobbying activities.
• Any payments made to lobbying bodies.
• Any activities we have identified as not aligned with our policies and principles.

• This policy is reviewed and approved annually by the Board of Directors.
• The Executive Board are accountable for enforcing this policy.
• This policy will be maintained on the website, is included in our shared policy folder and will be part of the onboarding and introduction to the business for new employees.
• A review of proposed activity will be signed off by the Executive Management Team as part of their monthly meeting and prior to engagement. When a lobbying or advocacy activity ends, the person most responsible for the activity will deliver a short report to the Executive Management Team to ensure compliance and capture any lessons learned.
• Any employee or stakeholder may escalate any concern about non-compliance with this policy as part of grievance, whistleblowing or company risk escalation procedures.