Responsible Marketing and Public Relations

Approved by the CEO on 29 September 2026; version 1.2 approved and effective 9 October 2026. Next review 29 September 2027. Policy owner: Head of Revenue Operations. Executive accountability: CEO. Review cycle: at least annually, and following material regulatory or organisational change.

Green Earth Group communicates honestly, accurately and responsibly. Every external claim is accurate, proportionate to what the organisation actually does, and supported by evidence a reader could ask for. That prevents misleading communication, keeps social and environmental claims reliable, protects stakeholders, and keeps public statements in line with Green Earth's actual activities and performance.

This policy supplements the existing Academy policies and procedures. It replaces no approval route and creates no new authority: nobody gains or loses authority because of it. The approval routes already in the Academy remain the approval routes.

Who and what it covers

• Who: all Green Earth Group entities, and every employee, contractor, freelancer, agency and partner who creates or distributes marketing or public-relations communications on Green Earth's behalf.
• Audience: any external audience, including clients, investors, farmers, partners, regulators, prospective employees and the public.
• Communications, where applicable: websites, landing pages and social-media content; advertising, email campaigns and newsletters; articles, reports, brochures, presentations and case studies; press releases, interviews and public statements; sponsorships, endorsements, influencer collaborations and partnerships; product, service, investment, financial, social and environmental claims; images, video, audio and AI-assisted content published externally.
• Not added: private, factual, one-to-one business communication with no new public, commercial, financial, regulatory or impact claim. The other Academy policies still apply to it, but this policy adds no approval requirement to it.

Terms

• Claim: any statement of fact, result, target or characteristic about Green Earth Group, its products, projects, people or impact, made to an external audience.
• Substantiation: evidence proportionate to the nature and importance of the claim, kept with the content or its approval record.
• Material: capable of changing how a reasonable reader understands the communication or decides to act.
• Specialist function: the post or division with documented authority over the subject of a claim, such as Division 7 for privacy and legal matters.

The rules

1. Accurate and evidenced

• Claims must be accurate, clear and capable of substantiation. Factual claims must be supported by evidence appropriate to their nature and importance.
• A material factual claim is not published unless its substantiation is available at the time of publication.
• Estimates, projections, targets and opinions must be labelled as such. They are never presented as established facts or achieved results.
• Green Earth must not leave out information where that would make the overall communication materially misleading.

2. Proportionate and in context

• Claims must be proportionate to Green Earth's actual activities, results and level of influence. Social and environmental achievements must not be overstated.
• Where material to understanding a claim, the communication must also explain relevant limitations, assumptions, scope, methodology or negative impacts.
• A positive result from one project, location, period or business unit must not be presented as applying to the whole organisation unless evidence supports that.

3. Environmental and social claims

• "Green", "sustainable", "climate positive", "carbon neutral", "environmentally friendly" or equivalent terms may only be used where their intended meaning is clear and the claim can be substantiated.
• Where material, an environmental or social claim should state: what activity, product, service or entity it covers; the period and geographical scope; the evidence, methodology or recognised standard used; important assumptions or limitations; and whether it is an achieved result, a current activity or a future target.
• Certifications, standards, labels and third-party assessments must be described accurately. Their scope and status must not be exaggerated.
• Every green, carbon or impact claim follows the Environmental, Carbon, and Impact Claims Policy in full. That policy holds the detailed requirements; this one does not replace it.

4. Transparent

• Commercial relationships, sponsorships, paid endorsements and other material interests that could influence a communication must be disclosed where required, or where leaving them out could mislead the audience.
• Testimonials, case studies, partner names, client names and performance examples are used only with the necessary permission and an accurate representation of the underlying facts. A named client, farmer, community or partner appears only with the required permission.
• Not permitted: artificial scarcity, fabricated urgency, hidden advertising, deceptive interfaces and other materially misleading practices.

5. Respectful

• Communications must treat people fairly and with respect. Green Earth does not use degrading portrayals, unlawful discrimination, or stereotypes that materially misrepresent individuals or communities.
• Images, stories and personal information about farmers, employees, clients or other individuals may only be used with the required permission and under Green Earth's privacy and consent policies.
• Marketing must not exploit children, financial hardship, limited understanding, or any other circumstance that materially reduces a person's ability to make an informed decision.
• This rule exists to prevent exploitation and unlawful discrimination. It does not require political or ideological messaging, demographic quotas or the promotion of any particular social viewpoint.

6. Privacy and data

• Personal data used for marketing must be processed under the Privacy and Data Protection Policy and applicable law.
• This policy sets no separate legal basis for processing. Questions about consent, legitimate interests, data sharing, retention or individual rights must be handled under the Privacy and Data Protection Policy and, where necessary, reviewed by the responsible Division 7 function.
• Green Earth Group does not sell personal data.

7. Sensitive communications

These need additional care and the applicable Academy approval route:

• financial performance, investment returns, pricing or forecasts;
• legal, regulatory, tax or compliance matters;
• carbon credits, carbon neutrality or other environmental-performance claims;
• named clients, farmers, communities, partners or transactions;
• political matters, public-policy positions or communications with regulators;
• health, safety or other claims that could materially affect stakeholder decisions;
• crisis communications or responses to serious public criticism.

A communication in one of these categories is verified by the responsible specialist function before publication. Where the Academy approval framework requires it, the person responsible for the underlying subject matter must verify specialised claims. Marketing and Creative staff are not expected or authorised to make independent legal, regulatory, financial or scientific determinations outside their documented role.

8. Paid third parties and agencies

• Anyone Green Earth pays or rewards to promote it (an agency, freelancer, influencer, partner or platform service) speaks openly as someone paid by Green Earth.
• Every paid third-party posting, seeding, review, comment or outreach discloses the commercial relationship with Green Earth in the content itself, in the form the platform requires.
• An agency or other paid third party never posts as an unaffiliated user, under a persona or fake account, or through accounts that hide who paid for the content.
• Before signing: no agency brief or agency contract is signed until the commissioning post has checked it against this policy. The commissioning post is the head of the Promotion department of the commissioning entity; in Holding, the Creative Director, head of Division 2 Department 4. The contract carries a clause requiring disclosure of the commercial relationship and compliance with the rules of every platform used, and then follows the Contract Review and Approval procedure.

9. When a platform acts

When a platform moderates, restricts or removes Green Earth content, an advertisement or an account, or content an agency posted for Green Earth, the post running that channel reports it to the Head of PR (Holding Division 7 Department 20) the same day.

10. Corrections

A known material error is corrected, clarified, updated or withdrawn promptly. If a published communication contains a material error or creates a materially misleading impression, Green Earth assesses it promptly and takes proportionate corrective action: correcting, clarifying, updating or withdrawing it.

Who approves

All approval and publication decisions under this policy follow the existing Academy policies, including the Content Approval Policy and the Social Media and External Communication Policy.

Public relations and media have one approval point. Press releases, media statements, answers to journalists, interviews, podcasts, panels, quotes, and any statement about the company, its results, its shares or a controversy are approved in writing by the Head of PR (Holding Division 7 Department 20) before release. Share-related or price-sensitive content also needs the Head of Legal and the Compliance Officer of Department 20. Green Earth Group N.V. is listed on Euronext (EARTH); such statements can be price-sensitive and are regulated by market-abuse rules. No other post approves them, including Country Directors and Venture Managers. The Public Relations and Reputation policy sets this out.

This policy does not:

• give the Creative Director, the Head of Revenue Operations or anyone else a new general veto over Green Earth communications;
• change the command lines or authority defined in an approved hat pack;
• authorise Marketing to approve legal commitments, financial terms or specialised compliance claims;
• create a separate disciplinary process;
• require duplicate approval where content has already been approved through the applicable Academy procedure.

The Creative Director may assess matters within the Creative Director's documented responsibility, such as visual identity, creative quality and brand execution. Broader disputes, policy interpretations and material risk decisions follow the established routing lines to the Head of Revenue Operations, the relevant specialist function or the CEO.

Conflicts between policies. Where this policy and another approved Academy policy appear inconsistent, the matter must be escalated through the applicable command line to the Head of Revenue Operations, the relevant specialist function or the CEO. No post-holder resolves such a conflict by unilaterally expanding their own authority.

Who does what

Putting it into effect

This policy takes effect on CEO approval. On approval, the Head of Revenue Operations communicates it to Division 2, to anyone publishing on Green Earth Group's behalf, and to external agencies and partners acting for the group. No existing approval route changes. The one added step is the commissioning post's check of each agency brief and contract before signing (rule 8).

Exceptions

There is no exception to the requirement that a claim be substantiated.

Monitoring

The Head of Revenue Operations reviews, at least annually: corrections and withdrawals issued, complaints received about external communications, and recurring claim risks. Those counts measure whether this policy works. An absence of corrections is not by itself evidence of accuracy.

Breaches and concerns

• A communication that breaches this policy is corrected under rule 10. Repeated or deliberate breach is handled under the existing Academy performance and conduct routes.
• Questions or concerns about marketing communications can be sent through Green Earth Group's applicable contact or complaints channel. Internal concerns can also be raised through the existing Academy reporting and escalation routes.
• Retaliation against anyone who raises a concern in good faith is not permitted.
• Complaints and concerns are handled under the applicable complaints, grievance, privacy or compliance procedure. This policy creates no separate disciplinary process and no separate investigation body.

Records

• This policy must be available to relevant workers in the Green Earth Academy and communicated to employees and contractors involved in marketing or public relations.
• Evidence supporting material social, environmental, financial or performance claims must be kept with the content or in the applicable approval record, under the existing Academy record-retention rules.
• External agencies and partners acting on Green Earth Group's behalf must be informed of the relevant requirements.

Common mistakes

• Presenting a target or projection as if it were achieved.
• Calling something "carbon neutral" or "sustainable" without saying what it covers and on what evidence.
• An agency or influencer posting for Green Earth without saying it is paid.
• Answering a journalist without the Head of PR's written approval.

Related documents

This policy sits above, and does not replace:

• Environmental, Carbon, and Impact Claims: the detailed requirements for green, carbon and impact claims.
• Public Relations and Reputation: press, reputation and public statements.
• Social Media and External Communication: the approval route for social and external channels.
• Content Approval: who approves what before publication.
• Contract Review and Approval: the route every agency contract follows after the check in rule 8.

Review

The Head of Revenue Operations coordinates a review of this policy at least annually, and when material changes occur in Green Earth Group's operations, organisational structure or obligations. Reviews should consider relevant complaints, corrections, recurring claim risks and lessons from implementation. Material amendments require approval from the CEO or executive team.