Responsible Lobbying Policy

At The Marketing Pod (‘Pod’), ethical responsibility is embedded in our values and in how we operate.

As a provider of public affairs services, Pod may undertake activities that constitute lobbying on behalf of its clients. Through this activity, we help clients communicate relevant evidence and expertise to policymakers and contribute to informed public decision-making.

Pod may also, on occasion, conduct lobbying on its own behalf. Pod will only undertake lobbying that contributes to positive social or environmental impact. Our lobbying must align with our wider sustainability commitments, the B Lab Standards and relevant UN Sustainable Development Goals.

We take our statutory and ethical responsibilities as lobbyists seriously and will comply with all applicable legal, regulatory and professional obligations.

Definition and scope

For this policy, Pod uses the definition of lobbying and advocacy adopted by B Lab, adapted from Transparency International’s Corporate Political Engagement Index.

This policy applies to any lobbying undertaken by Pod, including lobbying carried out as part of the public affairs services we provide to clients. It applies to all employees in every geography in which we operate. It includes indirect lobbying via intermediary organisations.

Evidence-based approach

Pod will base its lobbying on reliable evidence or scientific data appropriate to the subject. This may include official statistics, peer-reviewed research, reputable public data and/or evidence from credible expert sources. We will present evidence accurately and in context. We will not knowingly misrepresent evidence, omit important information in a misleading way or present opinion as fact.

Political contributions and integrity

Pod does not make financial or in-kind contributions to political parties, candidates or political campaigns. Outside of work, employees are free to engage in political activity in a personal capacity, without using company resources or representing the company.

We are committed to complying with UK legislation, including the Bribery Act 2010, the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, and applicable guidance from the Registrar of Consultant Lobbyists, to prevent corruption, bribery, conflicts of interest, or undue influence. Pod will meet all applicable registration and disclosure requirements.

Intermediary organisations

Should Pod work with intermediary organisations, we will consider whether the intermediary’s relevant lobbying positions and conduct align with this policy before engaging or relying on it. We will also consider any material change in its position during the relationship.

Pod will not work with an intermediary whose lobbying involves unlawful conduct, the deliberate use of misleading information, or positions that materially undermine our social and environmental commitments.

Governance, controls and risk management

Everyone working for Pod is responsible for complying with this policy. Ultimate responsibility for its implementation lies with the Co-founders and Directors, with appropriate support from the Senior Leadership Team and PR & Public Affairs Specialist.

Pod implements this policy by making it publicly available and requiring any employee undertaking relevant lobbying activity to follow it.

Pod will regularly review its procedures and the legal, regulatory and B Corp requirements relevant to its activities. Compliance is monitored through these reviews and by considering any concerns or potential breaches raised under Pod’s existing procedures. This policy will be reviewed and updated where those requirements or Pod’s activities materially change.

Any potential breach reported to Pod will be considered in line with our existing procedures and applicable legal requirements. Where non-compliance is identified, Pod will take appropriate action.

Stakeholder concerns and grievance channels

Employees or other parties who become aware of activity that may contravene this policy must report it in accordance with Pod’s publicly available grievance procedure. Pod will consider concerns submitted to it in accordance with the grievance procedure.

Anyone may also report a concern directly to the relevant authority or regulator.