Lobbying Policy

Belvoir Farm Drinks Responsible Lobbying Policy

Version 1

1. Purpose and Scope
This Responsible Lobbying Policy (“Policy”) sets out the principles, governance, controls, and risk management practices that guide the Company’s engagement in public policy, advocacy, and lobbying activities. The Policy applies to all directors, officers, employees, and to third parties acting on Belvoir Farm’s behalf worldwide.
Definition of Lobbying For the purposes of this Policy, lobbying means any activity undertaken to influence, directly or indirectly, the development, adoption, modification, or implementation of laws, regulations, public policies, or administrative decisions by governments, legislators, regulators, public officials, or political decision-makers at international, national, regional, or local level.

Lobbying includes, but is not limited to:
•Direct engagement with public officials or their staff –
•Participation in hearings, advisory groups, or working groups
•Engagement through intermediary organizations such as consultants, lobbyists, trade associations, or industry groups
•Lobbying does not include routine compliance activities, responses to factual information requests, or non-influencing communications unless they are intended to shape public policy outcomes.

2. Principles and Commitments
a) Positive Impact Commitment
The Company will engage in lobbying and public policy advocacy only where it reasonably expects to contribute to a positive impact on society and/or the environment. Lobbying activities will be aligned with the Company’s purpose, values, sustainability strategy, and respect for human rights, environmental protection, and inclusive economic growth.

In assessing whether a lobbying position contributes to a positive impact, the Company will consult recognized impact frameworks, including: The outcome sections of the B Lab Standards and/or The United Nations Sustainable Development Goals (SDGs) or comparable internationally recognized sustainability frameworks. This assessment helps ensure that the Company’s lobbying activities are consistent with credible societal and environmental outcomes and long-term public interest.

b) Evidence-Based Advocacy
The Company’s lobbying positions and communications will be evidence-based and grounded in reliable data, scientific data, or both, as appropriate.
For the purposes of this Policy: – Reliable data means information that is evidence-based, replicable, and derived from credible sources, including insights from independent market research. Scientific data means information based on research conducted by qualified scientists and published in reputable, peer reviewed scientific journals. Where evidence is uncertain or evolving, the Company will be transparent about assumptions, limitations, and areas of legitimate scientific or policy debate.

c) Financial and In-Kind Political Contributions
Company does not make political donations to political parties, candidates, or election campaigns unless explicitly approved by the Board and permitted by applicable law.
Any permitted political contributions, financial or in-kind, must be transparent, lawful, recorded accurately, and publicly disclosed where required.
The Company prohibits the use of Company resources for personal political activities.

d) Anti-Corruption and Anti-Bribery
The Company maintains zero tolerance for corruption and bribery in all forms. Lobbying activities must comply with all applicable anti-corruption and anti-bribery laws and the Company’s Code of Conduct, including prohibitions on improper payments, facilitation payments, gifts, or inducements intended to influence public officials.

e) Intermediary Organizations and Trade Associations
The Company may engage intermediary organizations (e.g., consultants, lobbyists, trade associations) where such engagement supports legitimate policy objectives.
The Company will conduct due diligence on intermediaries and require contractual commitments to ethical conduct, compliance with applicable laws, and alignment with this Policy.

The Company will implement controls and monitoring to ensure that positions advocated by intermediaries on the Company’s behalf are consistent with this Policy.
If the Company works with an intermediary organization whose lobbying positions undermine or conflict with this Policy, the Company will:
•Publicly report the Company’s own lobbying position compared with the intermediary organization’s position;
•Provide an explanation of how the Company is actively and positively influencing the intermediary organization’s position; and
•Clearly disclose the Company’s “red lines,” meaning the specific circumstances or thresholds that would cause the Company to cease engagement with the intermediary organization.
•Where misalignment cannot be remediated in line with these red lines, the Company will disengage from the intermediary organization.

f) Policy Review and Approval
This Policy is formally reviewed and approved by the Board of Directors (or a designated Board Committee) at least every two years, or more frequently if regulatory, strategic, or risk considerations require

3. Governance, Control, and Risk Management
a) Accountability
The Managing Director is accountable for enforcing this Policy, supported if necessary by our solicitors, and Internal Audit functions. Ultimate oversight rests with the Board of Directors.

b) Embedding the Policy
The Policy is embedded across the Company through: Integration into the Code of Conduct and related compliance policies; mandatory training for relevant employees and executives; clear procedures for approving and documenting lobbying activities; contractual requirements for third parties acting on the Company’s behalf
– Approval procedure: All lobbying activities need to be approved jointly by the Managing Director and the Marketing Director before publication or despatch, who will then document what has been done and any evidence or any contractual requirements in a lobbying folder on Sharepoint.

c) Risk Identification, Management, and Monitoring
If engaged in lobbying the Company will identify and manage lobbying-related risks by: Conducting periodic risk assessments covering regulatory, reputational, and ethical risks; maintaining registers of lobbying activities and political engagements; monitoring legislative and regulatory developments in key jurisdictions; applying enhanced controls in higher-risk markets or activities.

d) Evaluation of Compliance
Compliance with this Policy and the associated governance and control framework is evaluated through: Ongoing management oversight and compliance reviews; periodic internal audits and, where appropriate, independent assurance; corrective action plans for identified gaps or breaches

e) Raising Concerns and Grievance Mechanism
Stakeholders, including employees, business partners, and the public, may raise concerns about the Company’s business conduct or lobbying practices through established channels, including confidential and anonymous reporting where permitted by law. Concerns will be addressed in accordance with the Company’s grievance procedure. Retaliation against individuals who raise concerns in good faith is prohibited.

4. Transparency and Disclosure
The Company seeks to be transparent about its lobbying activities and will disclose relevant information in accordance with applicable laws, regulations, and voluntary reporting commitments.

5. Breaches and Consequences
Breaches of this Policy may result in disciplinary action, up to and including termination of employment or contracts, and may be reported to relevant authorities where required.

6. Effective Date
This Policy is effective as of the date of Board approval on March 17th 2026 and remains in force until amended or replaced