Responsible Lobbying Policy
ISIFARMER’s Public Commitment to Transparent and Responsible Engagement with Public Institutions
Why Responsible Lobbying Matters
ISIFARMER engages with public institutions as part of operating and developing our business. We believe that any engagement with public decision-making must be transparent, consistent, responsible, and aligned with our purpose of democratizing urban entrepreneurship and accelerating social inclusion. Our Responsible Lobbying Policy sets out how we approach lobbying and engagement with public institutions, including the principles that would apply if we were to engage in lobbying in the future.
Who This Commitment Applies To
This commitment applies to ISIFARMER, S.L. across all areas of our business. It covers our own operations, our value chain and everyone acting on our behalf, including:
- Our employees and workers
- Our contractors
- People acting on behalf of ISIFARMER
- Intermediary organisations representing ISIFARMER
It applies to interactions intended to influence public decision-making at municipal, regional, national or European Union level, whether conducted directly or through intermediary organisations.
What We Mean by Lobbying
For ISIFARMER, lobbying means any activity carried out by, or on behalf of, the company that is intended to influence a public decision — such as legislation, regulation or public policy — or to influence public opinion on these matters.
This includes:
Direct Lobbying
Engaging directly with public officials or elected representatives, submitting policy positions or proposed amendments, giving testimony, or conducting public campaigns intended to influence policy.
Indirect Lobbying
Pursuing the same objectives through an intermediary such as a trade association, industry group, chamber of commerce, lobbyist or consultant acting on ISIFARMER’s behalf.
Activities that do not seek to influence public decisions or public opinion are not lobbying. These may include ordinary commercial, and operational dealings with public bodies; participation in public programmes or grants, routine regulatory compliance, providing factual information in public consultations and general business networking.
Our Position and Principles
ISIFARMER publicly declares that it does not currently engage in lobbying. We do not seek to influence legislation, regulation, or public-policy decisions – directly or indirectly through intermediaries – at any level of government, and we make no financial or in-kind political contributions. If ISIFARMER engages in lobbying in the future, our approach will be guided by the following principles:
Positive Impact Only
We will engage in lobbying only where it contributes to a positive impact on society or the environment and is consistent with our purpose of democratizing urban entrepreneurship and advancing social inclusion. Any lobbying will serve the public interest rather than narrow commercial advantage.
Evidence-Based Positions
Any position we advocate will be based on reliable, evidence-based and replicable data or scientific data, or a combination of these. If the evidence supporting a position is shown to be wrong, we will correct or withdraw that position.
No Political Contributions
ISIFARMER makes no financial or in-kind contributions to political parties, politicians, or candidates for public office in any jurisdiction. Any change to this approach would require prior approval from our Highest Governing Body and public disclosure.
Anti-Corruption and Integrity
We apply a zero-tolerance approach to corruption and bribery in all its forms. We do not offer, promise, give or accept undue advantages in dealings with public officials or private parties and we manage conflicts of interest in public engagement.
Transparency and Honesty
When engaging with public institutions, we identify ourselves openly and accurately. We do not lobby through undisclosed third parties or front groups, and we do not misrepresent our identity, interests or the facts we present.
Responsible Engagement with Intermediaries
Before joining a trade association, platform or other intermediary organisation that engages in lobbying, we review its public positions for consistency with this commitment. We repeat this review at least annually and, where necessary, publicly disclose differences between our position and that of the intermediary, how we are seeking to influence its position and the circumstances in which we would end the relationship.
No Circumvention
We will not use an intermediary to pursue indirectly a position that we would not adopt directly under this commitment.
Consistency of Positions
Our positions will be consistent with our public statements and applied consistently across jurisdictions. We will not hold one position publicly while pursuing a contradictory position privately.
Governance and Accountability
Our Responsible Lobbying Policy is approved by ISIFARMER’s Highest Governing Body. The Sole Administrator is accountable for enforcing the policy and is the only person who may authorise lobbying activity or political contributions on ISIFARMER’s behalf. The Chief Impact Officer monitors the application of the policy day to day. No worker, contractor or person acting on behalf of ISIFARMER may lobby or make a political contribution without the prior written approval of the Sole Administrator.
How We Monitor Our Approach
We maintain a Public Affairs Register as an audit trail for this commitment. Where applicable, the register records:
- The date and public institution or counterpart
- The subject and objective of the engagement
- The position advocated
- The evidence supporting the position
- Any intermediary organisation involved
- Prior written approval
- The outcome
Raising Concerns
Anyone, including workers, urban farmers, partners, suppliers and members of the public, can raise concerns about ISIFARMER’s business conduct or lobbying practices without fear of retaliation. Concerns can be raised anonymously via the bilingual online forms on our website, by email, by post or in person.
Review and Transparency
We review our Responsible Lobbying Policy at least annually, or sooner if our activities, memberships or the regulatory environment change. The policy is approved by our Highest Governing Body and published publicly so that it is accessible to all stakeholders.
