Public and Political Engagement Policy

1. Purpose

This Public and Political Engagement Policy guides how Green Earth Group N.V. (the "Company") deals with governments, public bodies, political organisations and related stakeholders.

It provides a framework to ensure that all the Company's activities in the public policy arena are legal, ethical and transparent. It sets out the Company's commitment to constructive, responsible and non-partisan engagement in political processes and public policy debates.

2. Scope

This policy applies to the Company and its group companies, and to all their directors and employees. It covers lobbying, political contributions, membership of trade associations, public statements on policy matters and the personal political activities of employees.

3. Definitions

• Lobbying means any communication with public officials, governments or public bodies that is intended to influence legislation, regulation or public policy.
• Political contribution means any payment or other support, in money or in kind, to a political party, politician, candidate, political committee or campaign, including a campaign for or against a referendum or ballot initiative.

4. Guiding principles

• Transparency. The Company discloses its lobbying activities, political contributions, memberships of trade associations and involvement in referendum or ballot-initiative campaigns, as required by law and in line with its voluntary disclosure practices.
• Integrity. The Company acts to the highest ethical standards, complies with all relevant laws and regulations, and avoids any action that could harm its reputation.
• Accountability. The Company's public policy activities are subject to appropriate oversight, and the Company takes responsibility for the consequences of its actions.
• Respect for diversity of opinion. The Company respects the range of views on public policy within its organisation, among its stakeholders and in the wider community. It is open to differing viewpoints and committed to dialogue and understanding.
• Non-partisan engagement. The Company does not favour any political party or candidate over another. It engages on issues that affect its business, employees and stakeholders, and supports policies that align with its business objectives and values.

5. Compliance with laws and regulations

The Company complies with all applicable laws and regulations on public policy and political engagement, including those on lobbying, political contributions and trade associations. All disclosures and reports must be accurate, timely and in line with legal requirements.

Any contact with public officials is also subject to the Anti-Corruption and Anti-Bribery Policy.

6. Political contributions

The Company does not use corporate funds to contribute to political parties, politicians, candidates or political committees, and does not make corporate political donations.

Any exception, such as a contribution to a political organisation that is permitted under applicable law, must be transparent and requires the prior approval of the Chief Executive Officer (CEO) and the Head of Legal. A contribution for or against a referendum or ballot initiative also requires the approval of the management board of the Company (the "Board").

Every approved contribution is recorded and disclosed in line with section 11.

7. Lobbying

The Company engages in lobbying to influence public policy in areas that affect its business. All lobbying must be legal, ethical and transparent, and consistent with the Company's values and policies.

The Company keeps detailed records of its lobbying activities and expenditure so that it can report accurately. It files reports with the relevant authorities as required by law and makes them available to stakeholders on its website.

8. Communication and advocacy

When the Company states its position on a public policy matter or advocates a specific policy outcome, its message must be clear, truthful and consistent with its values and the interests of its stakeholders.

Every public statement on a policy matter requires the prior approval of the Head of PR and the CEO. If there is no Head of PR, the CEO approves alone.

9. Personal political activities of employees

Employees may take part in political activities as private individuals, outside their role at the Company. When they do, they must:

• make sure the activity does not interfere with their work or create a conflict of interest with the Company (see the Conflict of Interest Policy);
• not use company resources, and avoid using company time, for personal political activities; and
• make clear that their political views and actions are their own and not those of the Company.

Employees who are unsure whether a political activity is appropriate should ask their line manager or the Head of Legal for guidance.

10. Training

The Company provides training and resources to employees involved in public policy and political engagement, so that they understand their responsibilities and comply with this policy. Training may cover lobbying law, ethical conduct in political engagement and reporting requirements.

11. Disclosure and reporting

Internal reporting

All public policy and political engagement activities, including lobbying and political contributions, must be documented accurately and reported internally. The CEO and the Board review these reports.

External reporting

In line with legal requirements and its commitment to transparency, the Company publishes relevant information about its public policy and political engagement, including its lobbying activities, political contributions and memberships of trade associations. It publishes this information on its website and files it with the relevant authorities where required.

12. Roles and responsibilities

• The Board oversees the Company's public policy and political engagement; the Chief Executive Officer approves this policy on the Board's behalf. The HSE and Sustainability Committee supports the Board in this oversight.
• The CEO has primary responsibility for managing the Company's public policy and political engagement, and approves political contributions and public statements on policy matters as set out in sections 6 and 8.
• The Head of Legal owns this policy, advises on its application and approves political contributions as set out in section 6.
• The Head of PR approves public statements on policy matters as set out in section 8.
• Directors and employees comply with this policy.

13. Monitoring and reporting concerns

The Company regularly reviews and audits its public policy and political engagement activities to check compliance with this policy and with applicable laws and regulations.

Employees are encouraged to report any suspected breach of this policy to their line manager, the Head of Legal or the Compliance Officer, or through the channels set out in the Whistleblower and Non-Retaliation Policy.

14. Breaches

Breaches of this policy are dealt with promptly and may lead to disciplinary action, up to and including termination of employment.

15. Approval and review

This policy and any changes to it are approved by the Chief Executive Officer on behalf of the Board. The Head of Legal owns the policy and reviews it every year, taking into account good practice, changes in the Company's business or operating environment, and changes in law and regulation.

The Company informs employees and other relevant parties of changes to this policy promptly and provides additional training where needed.

History: first issued on 24 May 2023 by the Company, then named DGB Group N.V., and approved at the 2023 Annual General Meeting.