Responsible Lobbying Policy

The Lovat's Approach to Lobbying and Political Engagement

 The Lovat Loch Ness does not undertake formal lobbying activity. Specifically:

• The Lovat does not employ or engage lobbyists, lobbying firms, or public affairs consultants, whether directly or indirectly.
• The Lovat does not make financial or in-kind political contributions to any political party, candidate, campaign or political organisation in the UK or elsewhere.
• The Lovat does not carry out covert, undisclosed or improper attempts to influence government, regulators or public officials on the business's behalf.

The Lovat engages with policymakers, regulators and sector organisations only through transparent and legitimate stakeholder engagement, such as participation in recognised industry discussions, public consultations and compliance-related communications.

Responsible Lobbying Principles

 The Lovat Loch Ness believes that any engagement with policymakers, regulators, industry bodies or public stakeholders should contribute positively to society and/or the environment.

Should the business undertake lobbying or advocacy activity in the future, such activity will:

• Be transparent and conducted responsibly
• Align with The Lovat's sustainability commitments and ethical business principles
• Seek to contribute positively to society, the environment or the wider hospitality sector
• Not be undertaken to obtain improper commercial advantage or influence

Any policy engagement, consultation responses or public positions supported by The Lovat will be based on reliable information, evidence and, where relevant, recognised scientific data.

Industry Bodies and Intermediary Organisations

Caroline Gregory holds a board position with VisitInvernessLochNess (VILN), and The Lovat participates in sector bodies including:

• Hospitality Action
• UK Hospitality
• Hospitality Connect
• Developing the Young Workforce (DYW)
• Hospitality Apprenticeship Scotland (HAS)

Through these relationships, The Lovat may contribute views to public consultations relevant to the tourism and hospitality sector, for example responding to consultations through recognised industry channels.

This is treated as transparent stakeholder and sector engagement rather than lobbying where contributions are made openly through recognised organisations and relate to general sector interests.

Where The Lovat participates in intermediary organisations or sector bodies, the business expects any advocacy activity undertaken by those organisations to be consistent with responsible business principles. The Lovat will consider whether significant positions taken by intermediary organisations align with this policy and will review its participation where substantial inconsistencies arise.

Engagement with Regulators and Public Authorities

The Lovat engages with regulators and public authorities, including organisations such as Highland Council or Ofgem, only in the ordinary and transparent course of business compliance.

Examples include:

• Licensing matters
• Planning matters
• Environmental reporting
• Regulatory compliance discussions

The Lovat does not seek improper influence, preferential treatment or commercial advantage through engagement with public officials.

This approach is supported by The Lovat's Anti-Bribery and Corruption Policy, including controls relating to bribery, gifts, hospitality and facilitation payments.

Political Contributions

The Lovat Loch Ness does not make financial or in-kind political contributions.

This includes:

• Donations to political parties
• Donations to candidates or campaigns
• Sponsorship intended to influence political decisions
• Contributions made indirectly through third parties

Should this position change in the future, any political contribution would require approval from the Directors and would be disclosed transparently.

Anti-Corruption and Ethical Conduct

The Lovat prohibits bribery, improper influence and unethical conduct in all business activities.

All lobbying, stakeholder engagement and external representation must comply with The Lovat's Anti-Bribery and Corruption Policy.

Controls include:

• Prohibiting improper attempts to influence decision makers
• Prohibiting facilitation payments
• Managing gifts and hospitality appropriately
• Ensuring third parties and intermediary organisations are engaged responsibly
• Maintaining transparency in business relationships

Governance, Accountability and Implementation

Caroline Gregory and Sean Kelly, as Directors of The Lovat Loch Ness, are accountable for implementing and enforcing this policy.

They are responsible for ensuring that:

• Any engagement with policymakers, regulators, industry bodies or intermediary organisations is consistent with this policy
• External representation reflects The Lovat's values and commitments
• Any future lobbying or advocacy activity receives appropriate oversight

This policy is embedded through:

• Director oversight
• Compliance with the Anti-Bribery and Corruption Policy
• Transparent engagement with sector organisations
• Existing ethical governance procedures
• Annual review of business conduct policies

Risk Management and Compliance Monitoring

The Lovat manages risks associated with lobbying and political engagement by:

• Prohibiting undisclosed lobbying activity
• Preventing improper influence or conflicts of interest
• Reviewing relationships with intermediary organisations where relevant
• Ensuring external engagement is transparent and appropriately authorised
• Reviewing compliance with this policy through annual governance reviews

The Directors will review any concerns, changes in business practice or emerging risks relating to lobbying and stakeholder engagement and will update this policy where required.

Raising Concerns

Employees, suppliers, guests and other stakeholders can raise concerns regarding The Lovat's business conduct, political engagement or lobbying practices through:

• The Concern Reporting Form
• Direct communication with Caroline Gregory or Sean Kelly
• Grievance Procedure (for employment-related concerns)

Concerns raised in good faith are protected under The Lovat's Non-Retaliation Policy.

All concerns will be reviewed appropriately and investigated where necessary.

Guest and Stakeholder Transparency

The Lovat is committed to transparency with stakeholders regarding its approach to business conduct, sector engagement and sustainability commitments.

Where the business contributes to public consultations or sector discussions, this engagement will be conducted openly and responsibly.

Governance Approval and Review

This policy is owned by Caroline Gregory and Sean Kelly, Directors of The Lovat Loch Ness.