Responsible Lobbying & Government Engagement Policy

This Policy applies to Dogmates Holdings Ltd (trading as Butternut Box) and all its brands, sites, and subsidiaries (directly and indirectly wholly-owned) across the UK and Europe, namely: Dogmates Ltd, Butternut Box GmBH (Germany), Dogmates sp. z o.o. (Poland), Butternut Box (Italy) srl, Dogmates (Ireland) Limited, Dogmates (Netherlands) B.V., Feedwell sp. z o.o, Butternut (Belgium) BV and PsiBufet s.r.o. In this Policy when we refer to the “Company” we are referring to all of the above.

Purpose and scope

This Policy describes how the Company undertakes all lobbying and political engagement activities undertaken by or on behalf of the Company, including direct and indirect lobbying, advocacy, participation in public policy debates, and any engagement with public authorities such as government consultations, calls for evidence, regulatory/legislative consultations, and submissions to policymakers. This Policy applies to the Board and all employees of the Company and its subsidiaries.

Approach to responsible lobbying

Positive impact on society or environment

The Company undertakes lobbying activities in line with a commitment to creating positive impact for both society and the environment. All lobbying and political engagement activities are undertaken only when there is reasonable belief that they can contribute to a positive impact on society and the environment, consistent with the Company’s purpose, values, sustainability commitments and in consultation with the Sustainable Development Goals (SDGs). The Company will not support positions that undermine human rights, environmental protection, climate action, or ethical business conduct.

Evidence-based approach

The Company’s lobbying approach is based on reliable evidence (evidence-based and replicable, using independent insights) and, where relevant, scientific or technical data (research from scientists which has been published in reputable peer-reviewed journals). The Company aims to be accurate and transparent in representations made, to distinguish clearly between fact and opinion, and to correct material errors promptly if they occur.

Anti-corruption and bribery

All lobbying activities must comply with the Company’s Anti-Bribery & Anti-Corruption Policy and all applicable laws. The Company does not offer, promise, authorise, give, or accept bribes or facilitation payments. Gifts, hospitality, travel, or sponsorships involving public officials are prohibited unless lawful, modest, documented, and pre-approved in accordance with internal controls.

Intermediary organisations (trade associations, consultants, coalitions)

Where the Company engages intermediaries (e.g., lobbyists, public affairs consultants, trade associations, or coalitions), the Company will:

• conduct proportionate due diligence before joining/retaining them (including reputation, integrity, and alignment with the Company’s values);

• set clear expectations in contracts or membership terms that activities must be consistent with this policy and applicable laws;

• require transparency on the positions advocated on the Company’s behalf (where feasible), and monitor ongoing alignment;

• escalate, challenge, and seek to change positions that materially conflict with the Company’s commitments; and

• withdraw from an intermediary relationship when misalignment is significant and cannot be resolved within a reasonable timeframe.

Where the Company becomes aware that an intermediary organisation it engages with advances lobbying positions of its own that materially conflict with this Policy, the Company will (where feasible) publicly report: (i) the Company’s position compared to the intermediary’s position, (ii) how the Company is seeking to positively influence the intermediary’s position, and (iii) the Company’s ‘red lines’—the circumstances that would cause the Company to end the relationship or membership.

Political contributions

The Company does not make financial or in-kind contributions to political parties, political candidates, elected officials, or political campaigns, nor does the Company provide gifts, services, or other benefits intended to secure political influence.

Monitoring compliance to this policy

Governance and control framework in practice

The Company embeds this Policy through a proportionate governance and control framework that translates requirements into day-to-day practice. This includes:

• Ownership and decision rights: clear accountability for oversight of lobbying activities, including defined roles for initiating, reviewing, and approving positions and engagements.

• Approval pathways: defined thresholds for when lobbying activities require pre-approval (e.g., new or material policy positions, sensitive topics, engagement with senior public officials, or activity that may create legal or reputational risk).

• Records and transparency: maintenance of appropriate documentation for lobbying activities (e.g., engagement purpose, positions communicated/submissions made, key stakeholders engaged, and related expenditure/fees where applicable).

• Third-party management: proportionate due diligence, contracting expectations, and oversight for any third parties representing the Company or supporting lobbying activities.

• Capability and awareness: guidance and training for employees whose roles may involve lobbying activities, aligned to their risk exposure.

Risk management and ongoing monitoring

The Company identifies and manages risks of non-compliance associated with lobbying activities on an ongoing basis, with particular attention to higher-risk engagements and third-party involvement. Monitoring activities may include:

• periodic review of lobbying-related records and approvals for completeness and adherence to internal requirements;

• check-ins with relevant functions (e.g., Legal / Compliance / Sustainability / Procurement) to confirm that current activities remain aligned with the Policy;

• review of concerns raised through speak-up or grievance channels and escalation of material issues; and

• corrective actions where gaps are identified (e.g., changes to controls, additional training, updates to due diligence, or discontinuation of activities/relationships where necessary).

Evaluating effectiveness of the framework (assurance, review, and improvement)

The Company evaluates the effectiveness of this Policy and the associated governance and control framework at least biennially, and additionally following material incidents, significant changes in applicable requirements, or entry into higher-risk engagements. Evaluation may include:

• management review of a sample of engagements/submissions and supporting records;

• testing whether approval, due diligence, and oversight steps were followed (where applicable);

• review of incidents, complaints, or non-compliance cases and whether remediation was timely and effective; and

• documentation of findings, actions, and timelines, with progress tracked to completion and reported to the Board as part of the policy review cycle.

Speaking up & grievances

All stakeholders have the opportunity to raise questions and/or concerns (anonymously if they choose so) through: internal reporting routes (own manager, People Team, Compliance) or our chosen external whistleblowing provider Spot.

Our mechanisms aim to be legitimate, accessible, predictable, equitable, transparent, rights-compatible and a source of continuous learning, aligned with the UNGP effectiveness criteria.

No reprisal or retaliatory action will be taken against anyone for raising concerns in good faith (or participating in an investigation) under this Policy.

Distribution & Training

This Policy will be made available to all employees via the employee handbook for each market/site. It is communicated at onboarding for management and refresher training is given to managers annually. Training and awareness on this Policy will be provided to relevant employees and, where appropriate, to third parties such as industry associations and intermediaries. This Policy will be communicated at the outset of relevant relationships and refreshed periodically.

Material Lobbying Positions in 2025

We have not financially supported any lobbying efforts.

We submitted evidence for the following:

• We supported GEA’s lobbying efforts with the UK government to narrow the price gap between electricity and gas as part of our commitment to reducing carbon emissions from gas usage at our UK manufacturing site. This supports further implementation of our electricity-based heat recovery technology across our operations.

• We submitted a response to the European Commission’s call for evidence on the proposed Digital Fairness Act as regards consumer subscription contracts.

Board Member Approval: this policy was approved on 1st July 2026 by our Board of Directors, who review and update every 2 years or sooner if there are significant changes to operations, risks, or applicable standards.