RESPONSIBLE LOBBYING POLICY
1. Introduction and Purpose
I am Kooky Ltd ("Kooky") is a committed and certified B Corporation and part of a global movement working to benefit people and the planet.
Changing the food industry takes more than great products—it takes great policy too. We know that collaborating with governments and policymakers can help create lasting, systemic change across food and agriculture. That's why we only advocate for policies that are good for people, good for the planet, and aligned with our values.
At Kooky, we follow B Lab's definition of lobbying and advocacy, which includes activities carried out by or on behalf of an organised group to:
- Communicate directly or indirectly with public officials, political decision-makers, or their representatives to influence public decision-making.
- Attempt directly or indirectly to influence public opinion—beyond normal advertising and marketing—with the aim of impacting public decision-making.
This Responsible Lobbying Policy applies to all directors, officers, employees, and third parties acting on the Company's behalf worldwide.
2. Principles and Commitments
2.1 Positive Impact Commitment
We 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 our 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, we will consult recognised impact frameworks, including:
- The outcome sections of the B Lab Standards.
- The United Nations Sustainable Development Goals (SDGs) or comparable internationally recognised sustainability frameworks.
This assessment helps ensure that the Company's lobbying activities are consistent with credible societal and environmental outcomes and the long-term public interest.
2.2 Evidence-Based Advocacy
Our 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, we will be transparent about assumptions, limitations, and areas of legitimate scientific or policy debate.
2.3 Financial and In-Kind Political Contributions
Kooky 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, accurately recorded, and publicly disclosed where required.
Kooky prohibits the use of company resources for personal political activities.
2.4 Anti-Corruption and Anti-Bribery
Kooky maintains zero tolerance for corruption and bribery in all forms. Lobbying activities must comply with all applicable anti-corruption and anti-bribery laws and our Code of Conduct, including prohibitions on improper payments, facilitation payments, gifts, or inducements intended to influence public officials.
2.5 Intermediary Organisations and Trade Associations
Kooky may engage intermediary organisations (such as consultants, lobbyists, and trade associations) where such engagement supports legitimate policy objectives.
We conduct due diligence on intermediaries and require contractual commitments to ethical conduct, compliance with applicable laws, and alignment with this Policy.
We implement controls and monitoring to ensure that positions advocated by intermediaries on our behalf remain consistent with this Policy.
If Kooky works with an intermediary organisation whose lobbying positions undermine or conflict with this Policy, we will:
- Publicly report Kooky's own lobbying position compared with the intermediary organisation's position.
- Explain how Kooky is actively and positively influencing the intermediary organisation's position.
- Clearly disclose our "red lines"—the circumstances or thresholds that would cause Kooky to cease engagement with the intermediary organisation.
Where misalignment cannot be resolved in line with these red lines, Kooky will end its relationship with the intermediary organisation.
3. Governance, Control, and Risk Management
3.1 Accountability
Aline Burgmann, Founder of Kooky, is accountable for enforcing this Policy, supported by the Legal, Government Affairs, and Internal Audit functions. Ultimate oversight rests with the Board of Directors.
3.2 Embedding the Policy
This Policy is embedded across Kooky 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 our behalf.
3.3 Risk Identification, Management, and Monitoring
Kooky identifies and manages 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.
3.4 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.
3.5 Raising Concerns and Grievance Mechanism
Stakeholders, including employees, business partners, and the public, may raise concerns about Kooky'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 Kooky's grievance procedure. Retaliation against individuals who raise concerns in good faith is prohibited.
4. Transparency and Disclosure
Kooky 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 2 July 2026.