Responsible Lobbying and Public Advocacy
We are Sync Savings Limited (14782182)
Our registered address is Unit 29 Highcroft Industrial Estate, Enterprise Road, Waterlooville, England, PO8 0BT
If you have any questions about this Responsible Lobbying and Public Advocacy notice, please contact us at support@sync-savings.com.
1. Purpose and Scope
Sync Savings Limited recognises that responsible engagement with government, regulators, policymakers, industry bodies and other stakeholders can contribute to positive social and environmental outcomes.
As a business whose mission is to improve financial wellbeing at scale, Sync engages with policymakers and industry stakeholders on issues including workplace savings, financial resilience, financial inclusion, payroll technology and the development of an effective regulatory framework for workplace savings.
Sync's public policy engagement is intended to contribute to better outcomes for consumers, employees, employers and society and seeks to avoid conflicts of interest, information asymmetry or unfair outcomes in all of its work.
This Policy applies to all employees, directors, contractors and representatives acting on behalf of Sync.
2. Principles of Responsible Lobbying
a) Positive Social and Environmental Impact
Sync will only engage in lobbying or public policy advocacy where the Company reasonably believes that doing so can contribute to a positive impact on society or the environment.
In particular, Sync's public policy engagement is focused on:
improving financial resilience and financial wellbeing;
increasing access to workplace savings;
reducing unnecessary barriers to financial inclusion;
supporting responsible financial innovation;
improving outcomes for consumers and employees; and
supporting a more inclusive and sustainable financial services ecosystem.
Sync will not advocate for policies solely because they benefit the Company's commercial interests, especially where those policies would reasonably be expected to create a negative impact on consumers, society or the environment.
b) Evidence-Based Advocacy
Sync's lobbying and public policy positions will be based on reliable evidence, research, data and, where relevant, scientific or independently produced evidence.
The Company will seek to:
distinguish clearly between evidence and opinion;
use reliable and appropriately sourced data;
avoid making unsupported or misleading claims;
acknowledge relevant evidence that may challenge the Company's preferred position; and
update its position where credible evidence changes.
Sync's policy work draws, where appropriate, on research from government, regulators, academic institutions, recognised research organisations and industry bodies.
The Company also contributes its own practical experience, data and user research from the workplace savings ecosystem to public policy discussions.
3. Financial and In-Kind Political Contributions
Sync does not make political donations or contributions to political parties, candidates or political campaigns.
The Company will not provide financial or in-kind support intended to influence an election, political party or political candidate.
Where Sync participates in legitimate industry associations, working groups, conferences or policy forums, any associated expenditure must be for a legitimate business, industry or public-policy purpose and must comply with this Policy and the Company's financial controls.
No employee may make a political contribution on behalf of Sync without prior written approval from the Board. Sync may pay a market rate for access to events, conferences, lobby groups and organisations including those convened by political parties.
4. Anti-Corruption and Bribery
Sync has a zero-tolerance approach to bribery and corruption.
Employees and representatives must not offer, promise, give, request or accept any improper payment, benefit, gift or advantage intended to influence a public official, policymaker, customer, supplier or other stakeholder.
All public-policy engagement must be conducted honestly and transparently.
Sync will comply with applicable UK anti-bribery and corruption legislation, the Sync Anti Bribery and Corruption Policy, the Bribery Act 2010, and will maintain proportionate controls over:
gifts and hospitality;
expenses;
charitable and other contributions;
third-party relationships; and
interactions with public officials.
Any suspected bribery or corruption must be reported promptly through the Company's internal reporting or grievance procedures.
5. Intermediaries and Industry Organisations
Sync may engage with intermediary organisations, including:
trade associations;
Political parties;
charities;
industry coalitions;
professional advisers;
public-policy organisations;
research organisations;
consultants; and
other representative bodies.
Where Sync participates in an organisation that undertakes lobbying or public-policy advocacy on its behalf, the Company will take reasonable steps to ensure that the organisation's activities are consistent with Sync's values and this Policy.
Before entering into a material relationship with a public-policy intermediary, Sync will consider:
the organisation's purpose and reputation;
its approach to lobbying and political engagement;
whether its public positions are consistent with Sync's mission;
potential conflicts of interest; and
the transparency of its activities.
Sync will not knowingly permit an intermediary to advocate a position on its behalf that is materially inconsistent with this Policy.
Where a material inconsistency is identified, management will consider appropriate action, including requesting clarification, withdrawing support or terminating the relationship.
6. Governance and Accountability
The Board of Directors has ultimate responsibility for approving and overseeing this Policy.
The Chief Executive Officer is accountable for its implementation and enforcement and is responsible for ensuring that public-policy engagement undertaken by Sync is consistent with the Company's mission, values and governance framework.
Material or potentially sensitive lobbying activity may be escalated to the Board for consideration.
The Board will formally review and approve this Policy at least once every 12 months and following any material change in the Company's public-policy activities or applicable legal and regulatory requirements.
7. Embedding the Policy
The Policy is embedded within Sync's wider governance and compliance framework through:
leadership oversight of public-policy engagement;
appropriate approval of external policy positions;
internal financial controls;
conflict-of-interest controls;
anti-bribery and corruption requirements;
supplier and intermediary due diligence;
employee access to the Policy;
appropriate record keeping; and
regular Board review.
Employees involved in government relations, public policy, marketing, partnerships or external communications are expected to understand and comply with this Policy.
Where appropriate, public-policy positions will be reviewed alongside relevant compliance, legal and regulatory considerations before being communicated externally.
8. Identification and Management of Compliance Risks
Sync recognises that public-policy engagement can create risks including:
inaccurate or misleading public statements;
conflicts of interest;
inappropriate political contributions;
bribery or improper influence;
inconsistent positions communicated through third parties;
reputational damage; and
failure to comply with applicable laws or regulatory requirements.
The Company manages these risks through proportionate controls, including:
management oversight;
Board oversight of material matters;
appropriate due diligence on intermediaries;
financial controls;
conflict-of-interest procedures;
anti-bribery requirements;
documentation of material policy positions; and
escalation of concerns.
Where a potential breach is identified, management will assess the issue, determine appropriate remedial action and escalate material matters to the Board.
9. Compliance Monitoring and Review
Compliance with this Policy will be monitored through Sync's existing governance and risk management processes.
The Company will periodically assess:
whether public-policy activity remains consistent with Sync's mission;
whether claims and representations are appropriately evidenced;
whether political contributions or expenditure remain prohibited;
whether intermediary relationships remain appropriate;
whether conflicts of interest have been appropriately identified and managed; and
whether employees understand their responsibilities.
Material breaches will be reported to the CEO and, where appropriate, the Board.
The Board will review the effectiveness of the Policy at least annually and make amendments where necessary.
10. Stakeholder Concerns and Grievances
Sync encourages stakeholders to raise concerns about its business conduct, public-policy activities or lobbying practices.
Concerns may be raised through the Company's grievance procedure, which is available to stakeholders through the Company's public governance framework:
Stakeholders may raise concerns relating to:
misleading or inaccurate public-policy representations;
conflicts of interest;
inappropriate lobbying activity;
bribery or corruption;
political contributions;
conduct of intermediaries acting on Sync's behalf; or
other conduct inconsistent with this Policy.
All concerns will be treated seriously and investigated proportionately. Retaliation against a person who raises a concern in good faith is not permitted.
11. Transparency
Sync will maintain transparency regarding its approach to public-policy engagement.
The Company will not represent itself as speaking on behalf of government, regulators, industry bodies or other organisations without appropriate authority.
Where Sync participates in research, industry initiatives or policy discussions, it will seek to accurately represent the nature of its involvement.
Sync's public-policy activity is primarily focused on advancing workplace savings and financial inclusion. The Company believes that constructive engagement between industry, government, regulators and community organisations is important in developing policies that improve financial wellbeing.
12. Board Approval and Publication
This Policy has been approved by the Board of Directors of Sync Savings Limited, which is the Company's highest governing body.
The Policy will be reviewed and formally approved by the Board at least annually.
The current approved version will be published on the Sync Savings website and made accessible to employees, customers, investors, suppliers, policymakers and other stakeholders.
Approved by: Board of Directors, Sync Savings Limited
Date approved: 7 July 2026
Next review: 6 July 2027
Policy owner: Chief Executive Officer