Lobbying Policy

Gibsons Games Responsible Lobbying Policy

1. Introduction

At Gibsons Games, we believe in using our voice to support social and environmental progress. When we engage in public policy or advocacy, we do so with transparency, integrity, and a clear commitment to positive impact. This policy outlines our approach to responsible lobbying and political engagement, including how we align our advocacy with our values, govern related activities, and remain accountable to our stakeholders.

2. Scope

This policy applies to all lobbying and public policy engagement carried out by Gibsons Games its employees, representatives, and any intermediaries acting on our behalf. It also applies to membership in trade associations, industry groups, or other collaborative policy forums.

3. Our Commitment to Responsible Lobbying

Gibsons Games will only engage in lobbying activities where the purpose is to:

• Contribute to positive social or environmental impact
  

• Support an inclusive, regenerative, and equitable economy
  

• Advance legislation or policies grounded in reliable and/or scientific evidence
  

We will not engage in lobbying that promotes self-interest at the expense of people, communities, animals, or the planet.

4. Use of Political Contributions

Gibsons Games does not provide direct or indirect financial contributions to political parties, candidates, or organisations for the purpose of influencing legislation or regulation. We do not engage in in-kind support such as hosting events, providing services, or donating goods for political purposes.

If this changes, we will disclose the nature, value, and reasoning of all contributions in our annual impact report.

5. Anti-Corruption and Bribery

We have zero tolerance for corruption, bribery, or undue influence in any form. All lobbying and political engagement will be carried out in full compliance with relevant anti-bribery legislation and our internal ethics policies.

6. Engagement Through Third Parties

We may participate in trade associations, industry groups, or coalitions that engage in lobbying. When doing so, we:

• Assess the alignment of those organisations with our own values and lobbying policy
  

• Take action if their positions or activities conflict with our commitments
  

• Apply controls to ensure our membership does not imply endorsement of positions we don’t support
  

7. Governance and Oversight

This policy is reviewed and approved by the Leadership Team

Day-to-day accountability for compliance lies with the Managing Director

We will review and update this policy every 24 months, or sooner if our lobbying activity or risk exposure changes significantly.

8. Risk Management and Monitoring

We monitor our lobbying and advocacy efforts through internal compliance processes, including:

• Risk assessments on new policy positions
  

• Approval pathways for campaigns or statements
  

• Annual reviews of trade association memberships
  

• Conflict-of-interest checks for employees involved in advocacy
  

9. Grievance Mechanism

Any stakeholder—internal or external—may raise concerns about our lobbying activity or political engagement via our grievance procedures. All concerns will be reviewed by the Managing Director and addressed in line with our internal procedures.

10. Public Disclosure

This policy is published on our website at www.gibsonsgames.co.uk and is accessible to all stakeholders. Updates will be publicly announced as part of our impact reporting cycle.

Sign off: Kate Gibson, Managing Director, June 2026