Responsible Lobbying Policy

01Scope

This policy applies to all activities in which KEES or its representatives engage with professional bodies, industry groups, chambers of commerce, or any other organisations that may seek to influence public policy, regulation, or industry standards.

Kiro Tamer, Director of KEES and Chartered Environmentalist, holds membership with the following organisations on behalf of KEES:

• Institute of Sustainability and Environmental Professionals (ISEP)
• Energy Managers Association (EMA)
• Brighton Chamber of Commerce
• Greater Brighton Energy Forum

This policy covers all current and future memberships of this nature across all KEES activities.

02Why we engage and how we use evidence

KEES does not engage in direct lobbying of government ministers, officials, or regulators. Our membership of professional and industry bodies is for professional development, to stay current with regulatory and technical developments, and to contribute to the wider sustainability and energy management community.

Where KEES participates in these organisations, it does so in a technical capacity, sharing expertise, attending forums, and contributing to knowledge-sharing that supports the industry's transition to a more sustainable and efficient future. Our contributions are grounded in our core purpose: helping industry reduce its environmental impact, improve health outcomes, and achieve compliance.

All technical positions and contributions made by KEES are based on recognised industry data, peer-reviewed research, and established standards including ESOS regulations, ISO 50001, and relevant UK and international environmental legislation.

03Political contributions and integrity

Political contributions

KEES makes no financial or in-kind contributions to political parties, political candidates, political action committees, or ballot measures. This position is absolute and will not change without a formal decision by the Director and a corresponding update to this policy.

Bribery, corruption, and conflicts of interest

KEES does not engage in direct lobbying and therefore does not face the typical conflict-of-interest risks associated with it. However, KEES is committed to ethical conduct in all engagements:

• No facilitation payments or improper gifts are offered or accepted in connection with any engagement with external organisations.
• If any engagement creates or risks creating a conflict of interest, Kiro Tamer will declare the interest and recuse himself from any related decision.
• These obligations are consistent with the requirements of the Bribery Act 2010.

04Trade associations and membership bodies

KEES is currently a member of the following organisations:

• Institute of Sustainability and Environmental Professionals (ISEP)
• Energy Managers Association (EMA)
• Brighton Chamber of Commerce
• Greater Brighton Energy Forum

How we check their positions align with our policy

Kiro Tamer reviews the published positions and policy submissions of member organisations on a regular basis. This includes attending member forums, sessions, and events to stay informed of positions being taken and to contribute a technical perspective where appropriate. Where a member organisation publishes policy submissions or formal positions, these are reviewed against our own values and commitments.

What if there is a conflict?

If a member organisation were to adopt lobbying positions that directly conflict with our commitment to environmental sustainability, ethical business practice, or the principles of B Corp certification, KEES would:

• Formally communicate its own position to the relevant organisation.
• Seek to influence the organisation's position through available member channels.
• Withdraw membership if the conflict remains unresolved and the organisation's position continues to undermine our stated commitments.

05Responsibility, governance, and compliance

Accountability

Kiro Tamer, Director, is accountable for this policy and for ensuring all KEES activities remain consistent with its commitments.

Approval and review

This policy is approved by Kiro Tamer as the highest governing authority of KEES. It will be reviewed annually, or sooner if there is a material change in our memberships, engagement activities, or the relevant B Lab Standards. This version was approved in August 2026 and is due for review by August 2027.

Staff and associate awareness

All staff and associates are made aware of this policy during onboarding. An annual communication is issued to all relevant individuals to confirm continued compliance and to highlight any updates to the policy.

Monitoring compliance

Kiro Tamer reviews our memberships and engagement activities on an annual basis to confirm continued alignment with this policy. Any breach would be addressed promptly, with corrective action taken and the policy updated as necessary.

06Raising a concern

Any employee, client, or member of the public who has a concern about our lobbying activities or the conduct of any member organisation on our behalf is encouraged to raise it. Concerns can be submitted via the KEES grievance form (available on request) or by contacting Kiro Tamer directly at kiro@kees.co.uk.

All concerns will be acknowledged promptly and investigated in good faith. KEES is committed to ensuring that no one who raises a concern in good faith is disadvantaged as a result. Concerns are handled under the Grievance Policy.

07Annual public disclosure

From Year 3 of B Corp certification, KEES will publish a brief annual summary of its lobbying activities. This will be updated each year and may be published as part of this document or separately on the KEES website.