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Political Engagement Policy

Introduction

This disclosure sets out the LRC Group’s approach to political engagement, including lobbying, public policy activity, and political contributions as per our Political Engagement policy. It ensures that all such activity is conducted ethically, transparently, and in full compliance with applicable legislation in the jurisdictions where we operate. The Policy reinforces LRC’s commitment to remain politically neutral while maintaining constructive relationships with governments, regulators, and stakeholders in support of its legitimate business interests. This Policy covers political engagement in all jurisdictions where LRC operates, including interactions with public officials, political parties, trade associations, regulators, and advocacy groups.

  • The LRC Group does not support any political party or candidate.
  • We do not make political donations, whether in cash or in kind, without formal approval by the CEO.
  • Any political engagement undertaken on behalf of the Group must;
  • All political engagement must comply with the Anti-Bribery and Corruption Policy, AML/CFT Policy, and Code of Conduct. Under no circumstances may political engagement be used to improperly influence decisions or obtain a business advantage.

Acceptable Political Engagement

Permissible forms of political engagement include;

  • Responding to government consultations
  • Participating in trade associations and industry groups
  • Meeting with public officials to inform policymaking
  • Submitting evidence to parliamentary or governmental committees

All such engagement must;

  • Be pre-approved by the Compliance function
  • Be documented and reported for audit purposes
  • Avoid any perception of undue influence or impropriety

Political Donations

The LRC Group does not make political donations to parties, candidates, or political organisations in any jurisdiction. Exceptions (e.g. sponsoring a non-partisan political event) require;

  • Written approval by the CEO
  • Legal review
  • Full disclosure to stakeholders, where required by law

Lobbying and Advocacy

  • All lobbying activities, including engagement with public officials or policymakers, must be transparent, lawful, and approved in advance by the CEO, COO or Head of Compliance.
  • Employees must register lobbying activities where required by law and ensure that all declarations are accurate and timely.
  • Any engagement that involves legislative or policy influence must adhere to the Group’s Anti-Bribery and Corruption Policy and Data Protection Policy.
  • LRC will maintain a central log of all lobbying interactions to support transparency and compliance audits. Where relevant, lobbying activities will be registered in accordance with the EU Transparency Register (2024 update) and the UK's Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (Lobbying Act 2014), as applicable.

Industry Associations and Third Parties

We may be members of trade or industry associations that engage in political advocacy. We expect these organisations to operate transparently and ethically. We regularly review our memberships to ensure alignment with our values and disclose material memberships in our annual reporting.

Employee Political Activity (Personal Capacity)

LRC respects the rights of employees to participate in lawful political activities in a personal capacity. However, such participation must not conflict with the employee’s role or LRC’s interests.

  • Employees must not use LRC’s name, logo, or resources in connection with personal political activities.
  • Any potential conflicts of interest arising from personal political involvement must be disclosed to Compliance under the Conflict of Interest Policy.
  • Senior staff and public-facing employees should exercise additional caution to avoid the perception that their personal political opinions represent those of LRC.

Record-Keeping and Audit

  • A central log of all political engagement activities will be maintained by the Compliance function.
  • This log is reviewed annually.
  • Reports may be made publicly available as part of our ESG or corporate responsibility reporting.

Data Protection and Confidentiality

  • All personal data collected or processed in connection with political engagement—such as contact details for public officials or lobbying registers—must be handled in compliance with the UK and EU GDPR and the LRC Group Data Protection Policy.
  • Only authorised personnel may access or disclose such data, and information must be stored securely.

Whistleblowing and Reporting

  • Any employee who suspects a breach of this Policy or an attempt to exert improper political influence should report the matter confidentially as per the Whistleblowing Policy.
  • Reports may be made anonymously and will be investigated in accordance with the EU Whistleblower Protection Directive (2019/1937), the UK's Public Interest Disclosure Act 1998 (PIDA) and applicable local legislation.
  • LRC strictly prohibits retaliation against any individual who raises a concern in good faith.

Record Keeping and Retention

  • All records of political engagement, lobbying activities, approvals, and related correspondence shall be retained securely for up to five (5) years in accordance with applicable GDPR legislation. Records will be reviewed periodically and deleted or anonymised when no longer required.
  • Access to such records will be limited to authorised Compliance and Legal personnel.

ESG and Transparency Commitment

  • LRC’s political engagement practices form part of its broader ESG and Sustainability framework. The Group is committed to transparent reporting of material engagement activities in its annual ESG disclosures and to continuous improvement in governance standards.
  • Political engagement must always reflect LRC’s ethical standards, integrity, and accountability obligations.

Oversight and Review

The CEO has ultimate oversight of our political engagement activities. This disclosure and our internal Political Engagement Policy are reviewed annually to ensure compliance with evolving legal requirements and stakeholder expectations.