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Responsible Lobbying Policy

Policy No. POL-LOB-001 · Version 1.0 · Effective September 22, 2026

1.0 Purpose and Scope

Riverside Natural Foods engages in public policy because the rules governing agriculture, food safety, labelling, and trade determine whether good food is available to everyone. This policy sets out how we do that responsibly. It defines what we will and will not advocate for, the evidence our positions rest on, how we treat political contributions and the risk of bribery or corruption, how we work through the associations that speak on our behalf, and who inside Riverside is accountable for all of it.

The policy applies to every Riverside employee, contractor, agency worker, officer, and director, and to any consultant, agency, trade association, or other intermediary that engages with government or regulators on Riverside's behalf. It covers direct contact with elected officials and public servants, formal submissions to consultations, participation in industry association advocacy, and public campaigning intended to influence legislation, regulation, or public policy. It sits alongside our Employee Handbook and Code of Conduct, which remain the governing documents for individual conduct.

2.0 We Lobby Only to Create Positive Impact

Riverside's purpose is to inspire a healthier and more compassionate world, where access to good food becomes a reality for all. Our Vision 2050 holds that access to good food is a human right: good for the people, good for the planet. We will lobby only where doing so contributes to a positive social or environmental outcome consistent with that purpose, and we will not lobby, directly or through an intermediary, in a way that works against it.

To decide whether a position qualifies, we test it against our purpose, values, and the environmental and social issues that are most relevant to us as determined by our double materiality assessment results. A proposed position that cannot be tied to one of those outcomes is not advanced. While our purpose sets the why and what, our values set the tone for how we show up. Humility means we do not assume we have the answer, so we listen to farmers, scientists, customers, and communities before taking a position. Ownership means doing the right thing even when no one is watching, including in rooms that are closed to the public. Respect for our partners means we aim for win-win outcomes and long-term relationships rather than advantage at someone else's expense.

3.0 The Evidence Behind Our Positions

Every position we take is grounded in reliable or scientific data. Reliable data means evidence that is replicable and drawn from independent research and market analysis, leveraging third-party validation where applicable. Scientific data means findings published in reputable peer-reviewed literature. Where the evidence is contested or incomplete, we say so rather than overstating it, and we do not advance a claim we cannot substantiate.

Recent examples of the evidence base we build and rely on include the life cycle assessment of organic chocolate production in Peru, completed with Machu Picchu Foods and the University of Lima's PELCAN Institute and published as a scientific article in 2025, the environmental risk assessment of our top strategic organic ingredients completed by the CU Boulder master's program, and our double materiality assessment delivered in partnership with Junxion Strategy, which identifies the environmental and social topics most material to our business and our stakeholders. We also draw on sector research published by the organizations we belong to, including regenerative agriculture position statements from IFOAM Organics International and the Canada and US Organic Trade Associations.

4.0 Political Contributions

Riverside makes no financial contributions to political parties, candidates for public office, political action committees, referendum campaigns, or organizations whose primary purpose is to elect candidates. This applies in every country where we operate, and whether a contribution would be made directly or through a third party.

We make no in-kind political contributions either. Riverside facilities, staff time, products, data, media, or brand assets are not provided to a party, candidate, or electoral campaign. Loaned personnel, free services, and discounted goods count as contributions and are treated the same way.

Membership dues, sponsorships, and event fees paid to trade associations and non-profit organizations are not political contributions, but they can indirectly fund advocacy. We therefore track them, review them against this policy each year, and report them alongside our lobbying positions in our annual Impact Report.

Employees are free to take part in the political process in their own time, with their own money, and in their own name. Personal political activity must never be presented as a Riverside position, and no one will be favoured or disadvantaged at Riverside because of it.

5.0 Anti-Corruption and Bribery

Riverside prohibits bribery and corruption in every form. No one acting for Riverside may offer, promise, give, demand, or accept any payment, gift, favour, commission, reward, or other advantage intended to improperly influence a public official, regulator, customer, supplier, or association. Facilitation payments are prohibited, as are donations or sponsorships offered as a substitute for an improper payment.

These commitments restate obligations our people already carry. Our Code of Conduct treats kickbacks, undisclosed gifts, and vendor commissions as serious misconduct, requires everyone to deal honestly, ethically, fairly, and in good faith with all persons and entities having dealings with the company, and prohibits taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, or misrepresentation of material facts. Our conflict of interest rules prohibit accepting gifts or favours offered in gratitude for services rendered or anticipated, and require business entertainment to be reasonable, approved, and free of any suspicion about an employee's objectivity.

Any hospitality offered to or accepted from a public official in the course of policy work must be modest, transparent, lawful, and recorded. Where a lobbying registry, disclosure regime, or gift rule applies to an interaction, we register and report as required, and we brief our people on those rules before they enter the room as needed.

6.0 Trade Associations and Other Intermediaries

Most of our policy work happens in collaboration. Since 2022 we have been an active member of the Canada Organic Trade Association, where one of our founders, Nima Fotovat, serves on the board as Treasurer and where our Impact Team has travelled to Ottawa to advocate for federal adoption of the Organic Action Plan at the association's annual summit. We are a member of the Organic Trade Association in the United States and have taken part in advocacy on Capitol Hill during its annual Organic Week, similarly, lobbying for organic sector support. We are also members of IFOAM Organics International which supports organic organizations across the globe to support the sector in their respective countries and regions.

We join these organizations because collective action achieves more than we can alone, and we accept responsibility for the advocacy they carry out in our name. The following controls apply to every intermediary that lobbies on our behalf.

  • We maintain a register of the associations, coalitions, and consultants we fund or participate in, recording their stated policy objectives and positions on social and environmental topics.
  • We share this policy with each intermediary on joining and renewal and ask them to confirm they will not lobby in our name in a way that conflicts with it.
  • Riverside representatives who sit on an association board or committee are briefed on our positions before they take part, and report back on the positions taken.
  • The Impact team reviews each intermediary's advocacy against this policy upon engagement, and again ahead of any renewal or sponsorship decision.
  • Riverside retains independent ownership of its own policy positions and never delegates a position to an association without review.

Where an association takes a position that undermines this policy, we first seek to change it through dialogue and through the seats we hold. If a material divergence persists, we will publicly report our position alongside the association's, explain how we are working to influence it, and set out the red lines that would end our involvement.

Those red lines are specific. We will withdraw from an intermediary that lobbies to weaken organic certification standards or their enforcement, campaigns against science-based climate, biodiversity, or animal welfare regulation, promotes misleading environmental or health claims, obstructs transparency, traceability, or consumer right-to-know measures, engages in corruption or undisclosed lobbying, or supports any position we consider to be antithetical to our purpose and values. Where dialogue over a reasonable period fails to resolve the conflict, we will end the relationship and say publicly why.

7.0 Our Policy Priorities

Currently, Riverside advocates for a defined set of issues, which trace back to our purpose and are aligned with our partners' positions.

7.1 Organic Agriculture and Food Systems

  • Strengthening the growth and resilience of organic agriculture, including federal adoption and funding of organic sector development strategies such as the Canadian Organic Action Plan.
  • Expanding support for farmers who are just starting or those transitioning to organic production.
  • Increasing investment in organic agricultural research and innovation.
  • Protecting and strengthening organic certification systems, standards, and equivalency arrangements.

7.2 Climate, Biodiversity, Regenerative Agriculture, and Waste Reduction

  • Advancing agricultural practices that build soil health, biodiversity, climate resilience, and ecosystem restoration, without reliance on fossil-fuel-derived agrichemicals.
  • Encouraging nature-based solutions, circular packaging, and lower-impact supply chains.

7.3 Trade and Market Access

  • Supporting science-based and transparent trade policy for organic goods.
  • Reducing barriers that limit the growth of sustainable and organic businesses, particularly for small and mid-sized producers.

7.4 Consumer Trust and Transparency

  • Supporting policies that improve transparency, traceability, and credible environmental claims, including anti-greenwashing rules.
  • Advancing public education about the benefits and standards of certified organic production.

7.5 Healthy and Food-Secure Communities

  • Increasing access to nutritious food for all people, especially those in need.
  • Supporting initiatives that strengthen food security and resilient local food infrastructure.

8.0 Governance and Approval

This policy is approved by the Board of Directors of Riverside Natural Foods. The Board formally reviews this policy if our advocacy activities, corporate structure, materiality assessment findings, or regulatory environment changes materially.

The policy is embedded in how we work rather than filed away. It is published on our website, referenced in our Employee Handbook, draws from our Code of Conduct, and is covered in onboarding for employees whose roles touch government, regulatory associations, or significant communications work. Those employees are briefed before they represent Riverside externally, and the Impact team keeps a written record of positions taken, meetings held, submissions made, and memberships funded.

9.0 Accountability

  • Board of Directors: Approves this policy; formally reviews it if advocacy activity, corporate structure, or the regulatory environment changes materially; receives material issues escalated by the Impact team.
  • VP, Impact & Responsible Sourcing: Co-approves any public policy position adopted in Riverside's name, alongside the Director of Impact.
  • Director of Impact: Holds day-to-day accountability for enforcing this policy; approves lobbying positions, maintains the intermediary register, oversees registrations and disclosures, and escalates conflicts to the Board.
  • Impact Team: Reviews each intermediary's advocacy against this policy at least annually; manages risk on a continuing basis; evaluates the governance and control framework; keeps the written record of positions taken, meetings held, submissions made, and memberships funded.
  • Employees, Contractors, and Intermediaries: May not adopt a public policy position in Riverside's name without approval; are briefed before representing Riverside externally; raise concerns promptly and without fear of retaliation.

10.0 Risk, Monitoring, and Evaluation

We identify the risk of non-compliance through the annual review of intermediary positions, screening of every proposed position against the purpose and evidence tests in sections 2 and 3, tracking of association dues and sponsorships, and our double materiality assessment, which surfaces the topics where a misaligned position would do the most damage.

Risks are managed by the Impact team on a continuing basis and reported to the executive leadership team as needed, with material issues escalated to the Board. Monitoring covers whether positions were approved before being advanced, whether disclosures were filed where required, whether intermediaries acted consistently with this policy, and whether any concerns were raised.

The Impact team is responsible for the evaluation of the governance and control framework set out in sections 6, 8, and 9 annually. The evaluation asks whether the controls were applied, whether they worked, and what changed as a result. Any material findings and corrective actions are recorded and summarized publicly in our annual Impact Report.

11.0 Raising a Concern

Anyone can raise a concern about Riverside's business conduct or lobbying practices, whether they are an employee, contractor, supplier, farmer, community member, customer, or member of the public. These concerns may be raised to people leaders, the People and Values team, through the anonymous channel available to all team members, our public grievance mechanism, or directly with the Director of Impact. Our Code of Conduct places a duty on every employee to promptly report any violation that becomes known or is reasonably suspected and treats delay in reporting as a violation in itself.

External stakeholders can raise concerns by writing to us at info@riversidenaturals.com. We acknowledge concerns received and investigate them through the same grievance process that applies internally.

Riverside does not tolerate retaliation. Our Code of Conduct commits the company not to carry out or permit retribution or retaliation of any kind against anyone who reports a suspected violation in good faith. Where a breach of this policy is substantiated, it is addressed through our disciplinary process, up to and including termination of employment, or through termination of a contract, sponsorship, or membership.

12.0 Publication and Reporting

This policy is published on the Riverside Natural Foods website and is freely accessible to all stakeholders, without registration or request. Each fiscal year we publish, in our Impact Report, the policy positions we advocated, the associations and coalitions we funded or participated in, any material divergence between our positions and theirs, and confirmation of our position on political contributions.

Document Control

  • Document owner: Director of Impact, Riverside Impact Team
  • Approved by: Board of Directors, Riverside Natural Foods Ltd.
  • Applies to: All employees, contractors, agency workers, officers, directors, and intermediaries acting on Riverside's behalf
  • Effective date: September 22, 2026
  • Review cycle: Reviewed by the Board of Directors following any noted material changes