1. Our Lobbying Commitments

1.1 Positive Impact Only

Bold Bean Co will only lobby where we genuinely believe our engagement will contribute to a positive impact on society or the environment. We will not use our public voice to pursue outcomes that benefit us commercially unless those outcomes also deliver clear benefits for people and the planet. Our focus areas include:

• Soil health and regenerative agriculture
• Policies supporting a shift towards plant-based protein
• Climate and environmental regulation in food production
• Fair trade conditions for legume farmers
• Food labelling and transparency
• Inclusive access to high-quality, sustainably produced food

1.2 Evidence-Based Positions

Our lobbying positions are grounded in reliable evidence and, where available, peer-reviewed scientific data. We will consult authoritative sources (including IPCC, FAO, and Rothamsted Research), be transparent about the evidence underpinning our positions - including where it is contested or evolving - and update our positions when new evidence materially changes our understanding. We will not misrepresent or selectively cite evidence, and will disclose any commercial relationship where we have funded relevant research.

1.3 Political Contributions

Bold Bean Co does not make financial contributions - direct or in-kind - to political parties, election campaigns, or candidates in any jurisdiction. This covers monetary donations, sponsored events, hospitality for elected officials beyond what is permitted by law, and charitable donations made at the request of a public official where a business benefit is implied. Where we pay membership fees to trade bodies, we will take reasonable steps to ensure those fees are not used for party-political activity.

1.4 Anti-Corruption and Bribery

We maintain a zero-tolerance approach to bribery and corruption, in full compliance with the UK Bribery Act 2010 and equivalent legislation in all jurisdictions where we operate. No employee, contractor, or representative of Bold Bean Co will offer or accept any advantage - financial or otherwise - to influence a policy outcome. Gifts and hospitality in public-affairs contexts must be reasonable, transparent, and consistent with our Gifts and Hospitality Policy. Facilitation payments are prohibited in all circumstances. Suspected breaches must be reported immediately through the mechanism in Section 3.3. All staff with public-affairs responsibilities receive mandatory training on these requirements.

1.5 Intermediary Organisations

Membership of trade associations, industry coalitions, or NGOs can constitute indirect lobbying and is subject to the same standards as our direct engagement. Before joining or renewing, we review the body's lobbying positions for consistency with this Policy. Where we disagree with a position, we will use our membership voice to advocate for change; if unsuccessful on a material issue, we will consider withdrawing and will explain publicly why. We publish an annual register of all such memberships on our website, noting any significant policy divergences and our response. Any agency or consultant lobbying on our behalf must agree in writing to comply with this Policy as a condition of appointment.

2. Governance

2.1 Ownership, Approval and Accountability

This Policy is owned by the Bold Bean Co Board of Directors, which reviews and approves it as it sees fit. The review considers whether the Policy remains fit for purpose, any incidents or concerns raised, and the outcomes of compliance monitoring.

The Board delegates day-to-day accountability to the Senior Leadership Team (SLT), who are responsible for approving new lobbying engagements, maintaining the intermediary register, and escalating material breaches to the Board. The SLT maintains the Policy, coordinates training, and reports to the Board as necessary.

2.2 Embedding the Policy

We put this Policy into practice through:

• Training - this Policy is available in our company handbook.
• Registers - an internal register of direct lobbying activities (objectives, officials engaged, evidence base, outcomes) reviewed as applicable; and a public register of intermediary memberships published on our website.
• Contracts - public-affairs agencies and trade-body memberships include clauses requiring Policy compliance and a right to terminate for breach.
• Code of Conduct - this Policy is published externally at boldbeanco.com/policies.

3. Risk Management and Compliance

3.1 Identifying and Managing Risk

The SLT conducts a lobbying risk assessment when they deem it necessary, identifying activities, relationships, and jurisdictions that present the greatest risk of non-compliance across reputational, legal, and financial dimensions. Controls are documented for each risk; residual risks rated high are escalated to the Board. Due diligence on intermediary memberships and agencies includes a review of their lobbying policies, repeated at renewal. Staff are encouraged to flag concerns at any time - all are logged and tracked to resolution.

3.2 Evaluating Compliance

Compliance is evaluated through three mechanisms:

• Regular reporting by the SLT to the Board, covering active lobbying activity, intermediary memberships, and any concerns or incidents.
• Self-assessment against this Policy and associated operating procedures, reported to the Board as needed.
• Independent review following a material incident, with findings reported to the Board and recommendations addressed within a defined timeframe. Our B Corp reassessment provides an additional external check.

3.3 Raising Concerns

Anyone - employee, contractor, supplier, or member of the public - who has a concern about Bold Bean Co's lobbying activities or business conduct can raise it with their line manager, any member of the Senior Leadership Team, or our Head of People. Concerns can also be raised anonymously through our whistleblowing channel, or formally through our Grievance Procedure. All concerns are investigated promptly and impartially. Retaliation against anyone raising a concern in good faith is a disciplinary offence.

4. Scope, Definitions and Related Policies

This Policy applies to Bold Bean Co and all subsidiaries, to all employees and officers regardless of seniority or contract type, and to any third party acting on our behalf in a public-affairs capacity.

Lobbying: Any direct or indirect communication with a public official, government body, regulator, or political party with the intent to influence legislation, regulation, policy, or the exercise of a public function.

Intermediary organisation: Any trade association, coalition, certification body, NGO, or think tank through which Bold Bean Co may, directly or indirectly, seek to influence public policy.

In-kind contribution: Any non-monetary support of value provided to a political party, candidate, or campaign, including goods, services, staff time, or use of facilities.

This Policy should be read alongside our Anti-Corruption and Bribery Policy, Code of Conduct, Gifts and Hospitality Policy, Grievance Procedure, Whistleblowing Policy, and Supplier Code of Conduct. Where policies conflict, the more stringent requirement applies.