Lobbying Policy
- Purpose
Fluvio Ltd (“the Company”) is committed to conducting its business with integrity, transparency, and accountability. As an environmental consultancy company, Fluvio Ltd recognises the importance of maintaining independence and avoiding undue influence in public decision-making processes.
Accordingly, Fluvio Ltd does not engage in lobbying activities.
This Policy sets out the Fluvio’s approach to prohibiting lobbying, and defines the governance, control, and risk management practices in place to ensure compliance.
For the purposes of this Policy:
- Lobbying means any direct or indirect communication with public officials, government representatives, regulators, or policy-makers with the intention of influencing legislation, regulation, public policy, or administrative decisions.
- Public Officials include elected representatives, government employees, regulators, and any individual acting in an official capacity on behalf of a public body or authority.
- Third Parties include contractors, consultants, agents, suppliers, or any external organisation or individual acting on behalf of Fluvio Ltd.
- Industry Groups / Associations refers to trade bodies, professional associations, or collaborative forums in which Fluvio Ltd participates.
- Grievance Policy refers to the Company’s formal procedure for raising concerns about business conduct, including unethical behaviour or policy breaches.
- Scope
This Policy applies to:
- All employees, officers, and Directors of Fluvio Ltd.
- Policy Statement
Fluvio Ltd strictly prohibits all forms of lobbying. This includes, but is not limited to:
- Direct or indirect communication with government officials intended to influence legislation, regulation, or public policy
- Engagement of third parties to conduct lobbying on behalf of the Company
- Participation in industry groups or associations where the primary purpose is to influence public policy on behalf of the Company.
Where Fluvio Ltd participates in industry forums or collaborations, it does so solely for knowledge sharing, sustainability advancement, and technical collaboration, and not for lobbying purposes.
- Governance and Accountability
The Board of Directors has overall accountability for this Policy. Specifically:
- Directors are responsible for ensuring the Policy is effectively implemented and enforced
- Directors shall promote a culture of ethical conduct and compliance
- Directors are responsible for day-to-day oversight and ensuring adherence across all business operations.
The Policy is reviewed periodically by the Board to ensure it remains effective and aligned with regulatory expectations and best practice.
- Embedding the Policy
Fluvio Ltd embeds this Policy within its operations through the following measures:
- Inclusion of the Policy in employee onboarding and training programmes
- Regular communication to employees and relevant third parties regarding expectations and obligations
- Integration of the Policy into relevant procedures, including procurement, partnerships, and stakeholder engagement processes
- Clear guidance on acceptable interactions with public officials and participation in external forums.
Employees and representatives are expected to understand and adhere to this Policy as a condition of their engagement with the Company.
- Risk Identification, Management, and Monitoring
Fluvio adopts a proactive approach to identifying and managing risks of non-compliance with this Policy. This includes:
Risk Identification:
- Assessing business activities that involve interaction with public bodies, regulators, or policy-makers
- Reviewing participation in industry groups and external partnerships.
Risk Management:
- Implementing controls and approval processes for engagements with public officials
- Providing guidance and escalation channels for uncertain situations
- Ensuring contractual obligations with third parties prohibit lobbying on behalf of the Company.
Monitoring:
- Periodic internal reviews of relevant activities and engagements
- Oversight by senior management and reporting to the Board where necessary.
- Compliance Evaluation and Assurance
Fluvio evaluates compliance with this Policy and its governance framework through:
- Periodic internal audits or reviews of adherence to the Policy
- Review of incidents, complaints, or breaches related to lobbying activities
- Continuous improvement of controls and procedures based on findings.
Any identified breaches will be addressed promptly and may result in disciplinary action, up to and including termination of employment or contract.
- Raising Concerns and Grievances
Fluvio encourages transparency and accountability. Employees, contractors, clients, and other stakeholders are encouraged to raise concerns regarding:
- Potential breaches of this Policy
- Suspected lobbying activities.
Concerns can be raised through the channels outlined in the Fluvio’s Grievance Policy. Reports may be made confidentially and, where feasible and permitted by law, anonymously.
All concerns will be taken seriously, investigated appropriately, and handled without retaliation against the individual raising the concern.
- Responsibilities
All individuals covered by this Policy are responsible for:
- Understanding and complying with this Policy
- Avoiding any activity that could be perceived as lobbying
- Promptly reporting any concerns or potential breaches
Managers have additional responsibility to:
- Ensure their teams are aware of and comply with this Policy
- Act on concerns and escalate issues where appropriate.
- Review and Approval
This Policy is approved by the Board of Directors of Fluvio Ltd and is reviewed periodically to ensure its continued effectiveness.
Effective Date: 17/04/2026
Approved By: Gary Bilotta (Director) and Matt Turley (Director)