Responsible Lobbying Policy

Introduction

bottle up is committed to using its voice responsibly, transparently and in a way that supports positive social and environmental impact. We aim to create measurable environmental and social value by reducing reliance on single-use plastic bottles, helping prevent waste and litter, and encouraging more sustainable everyday habits. By making reuse easy and attractive, bottle up seeks to inspire lasting behaviour change and contribute to a more circular economy.

This policy sets out our position on lobbying, political engagement and public policy influence. It applies to bottle up, its directors, workers, freelance contractors and any external parties acting on our behalf.

What we mean by lobbying

For the purpose of this policy, lobbying means any activity intended to influence public policy, legislation, regulation, government decision-making or the position of public officials. This may include direct engagement with elected representatives, civil servants, regulators, trade bodies, industry groups or public policy consultations.

Lobbying may be carried out directly by bottle up or indirectly through third parties, including trade associations, consultants, coalitions or other representative bodies.

Our responsible lobbying commitments

bottle up will ensure that all lobbying, public policy engagement and advocacy activity is conducted responsibly, lawfully, transparently and in alignment with our purpose, values and environmental commitments.

We will only support lobbying or public policy positions that are consistent with our commitment to reducing single-use plastic, supporting more circular packaging systems, protecting natural resources and contributing to positive social and environmental impact. Our lobbying will always be based on reliable data.

We will not knowingly support lobbying that undermines climate action, weakens environmental protection, delays progress towards a circular economy, promotes misleading sustainability claims, or conflicts with our public commitments as a purpose-led business.

Where we engage in policy discussions, we will aim to support fair, evidence-based and transparent decision-making. We will seek to contribute constructively to policies that reduce single-use plastic, improve packaging systems, support circularity, protect natural resources and encourage responsible business practice.

Transparency and public disclosure

bottle up will be open about any material lobbying activity it undertakes. We will maintain appropriate records of relevant lobbying positions, public policy priorities, trade association memberships and any political or lobbying-related expenditure.

Where appropriate, we will make this information publicly available through our website, annual reporting or other suitable public channels.

Political contributions

bottle up will not use company funds to make political contributions unless such contributions are lawful, transparent, approved by the highest governing body and clearly aligned with this policy.

Any proposed financial or in-kind contribution to a political party, political candidate, election campaign, political action committee or equivalent political organisation must be reviewed and approved in advance. bottle up’s default position is that company funds should not be used for political contributions.

Anti-corruption and bribery

bottle up is committed to conducting all lobbying, advocacy and public policy engagement with integrity and in accordance with applicable anti-corruption and anti-bribery laws.

bottle up will not offer, promise, give, request, accept or authorise any bribe, improper payment, facilitation payment, gift, hospitality, donation, favour or benefit intended to improperly influence a public official, political representative, regulator, trade body, intermediary organisation or any other third party.

Any person acting for or on behalf of bottle up must raise concerns if they become aware of conduct that may breach this policy. Concerns will be reviewed by the Board of Directors or the company director responsible for sustainability and impact, and appropriate action will be taken where required.

Trade associations and third-party representation

bottle up may join trade associations, industry groups or collaborative initiatives where these support our mission and help advance positive environmental or social outcomes.

Before joining or renewing any such membership, we will consider whether the organisation’s public policy positions are aligned with bottle up’s purpose, values and impact commitments. Where there is a material misalignment, bottle up will seek to address the concern through engagement, public clarification or, where necessary, withdrawal from the organisation.

No third party may lobby on behalf of bottle up unless they have been authorised to do so and agree to act in accordance with this policy.

Responsible lobbying through intermediary organisations

bottle up recognises that lobbying may take place indirectly through trade associations, industry bodies, consultants, coalitions or other intermediary organisations. Any such activity must remain consistent with this policy and aligned with bottle up’s purpose, values and environmental commitments.

Before authorising an intermediary organisation to represent bottle up’s interests, or before joining or renewing membership of a relevant organisation, bottle up will consider whether its public policy positions and lobbying activities are aligned with this policy. Where a material inconsistency is identified, bottle up will take proportionate action, which may include raising the concern, clarifying bottle up’s own position, declining to participate in specific activity, or ending the relationship.

Governance and accountability

Accountability for enforcing this policy sits with bottle up’s Board of Directors. The Board of Directors is responsible for approving this policy, ensuring it is implemented within the company, reviewing any proposed lobbying activity, public policy position, political contribution, trade association membership, or third-party lobbying arrangement, and taking action where any risk of non-compliance is identified.

This policy is embedded within bottle up through its governance, decision-making and impact management processes. In practice, this means that any activity that may involve lobbying, public policy engagement, political influence, political contributions, intermediary organisations, or third-party representation must be reviewed by the Board of Directors before approval. Decisions must consider legal compliance, alignment with bottle up’s purpose and values, stakeholder interests, environmental commitments, anti-corruption requirements and potential reputational risk.

bottle up identifies, manages and monitors risks of non-compliance by reviewing any activity that may involve public policy influence, political engagement or third-party representation before it takes place. Where a risk is identified, the Board of Directors will assess the nature and severity of the risk, agree proportionate actions, assign responsibility for follow-up and keep appropriate records of the decision. This may include declining an activity, amending a public policy position, seeking further clarification from an intermediary organisation, publicly clarifying bottle up’s position, or ending a relationship where the risk cannot be resolved.

bottle up evaluates compliance with this policy and its governance controls through periodic review by the Board of Directors. This review will consider any lobbying activity undertaken, relevant records, trade association memberships, stakeholder concerns, political or lobbying-related expenditure, conflicts of interest and any instances of actual or potential non-compliance. Any findings will be used to strengthen the policy, improve internal controls and guide future decision-making.

Stakeholders, including workers, freelance contractors, suppliers, customers, partners and other affected parties, may raise concerns about bottle up’s business conduct, lobbying practices, political engagement, intermediary organisations, or suspected breaches of this policy through the company’s grievance procedure. Concerns will be reviewed fairly, confidentially where appropriate, and without retaliation against any person raising a concern in good faith. Where a concern is upheld, bottle up will take appropriate corrective action and, where relevant, update its governance controls to reduce the risk of recurrence.

Review

This policy will be reviewed at least every three years, or sooner if bottle up begins material lobbying activity, joins a relevant trade association, changes its governance structure, or identifies a material issue requiring review.

 

Human Rights Policy

Purpose

bottle up is committed to respecting human rights across our business, supply chain, partnerships and wider stakeholder relationships. We recognise that businesses have a responsibility to respect the dignity, freedom, safety and wellbeing of all people who may be affected by their activities, products, services and commercial relationships.

This policy sets out our public commitment to human rights and explains how we seek to identify, prevent, manage and address human rights risks connected to our business. It applies to bottle up, our Board of Directors, workers, freelance contractors, suppliers, manufacturing partners, logistics partners, distributors and other business relationships.

Our human rights commitment

bottle up publicly commits to respect internationally recognised human rights. In particular, we commit to respecting the principles and rights set out in:

1. a) the United Nations Guiding Principles on Business and Human Rights;
2. b) the International Bill of Human Rights, including the rights set out under the Universal Declaration of Human Rights; and
3. c) the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

We recognise our responsibility to avoid causing or contributing to adverse human rights impacts through our own activities, and to seek to prevent or mitigate adverse human rights impacts that may be directly linked to our operations, products or services through our business relationships.

Rights covered by this policy

bottle up’s commitment includes, but is not limited to, respect for the following rights and principles:

Freedom from forced labour, bonded labour, human trafficking, slavery and modern slavery.

Freedom from child labour and the protection of young workers.

Freedom from discrimination, harassment, bullying, victimisation, hate speech and degrading treatment.

Respect for equality, diversity, inclusion, dignity and fair treatment.

Freedom of association and the right to collective bargaining, where applicable.

The right to safe, healthy and fair working conditions.

The right to fair pay, lawful working hours and appropriate rest.

The right to privacy and protection of personal information.

The right to raise concerns without fear of retaliation.

Respect for communities affected by our supply chain, including workers involved in raw material production, manufacturing, logistics, distribution and waste management.

Limits on human rights where they harm others

bottle up recognises that human rights must be respected in a way that protects the rights, dignity and safety of others.

We will not accept the use of free speech, religious expression, personal belief or cultural practice as a justification for treating people unfairly, excluding people, harassing people, spreading hate, inciting violence, or undermining the rights and dignity of others. In practice, this means that all people connected to bottle up are expected to behave respectfully, inclusively and lawfully, even where views, beliefs or backgrounds differ.

Modern slavery statement

bottle up has zero tolerance for modern slavery, forced labour, bonded labour, human trafficking, child labour and all forms of exploitation. We are committed to acting ethically and responsibly in our business relationships and to taking proportionate steps to reduce the risk of modern slavery in our operations and supply chain.

bottle up does not knowingly work with any supplier, contractor, manufacturer, distributor or partner that uses forced labour, trafficked labour, child labour, debt bondage, coercion, unlawful recruitment fees, withheld identity documents, abusive working conditions, or any other form of modern slavery.

We expect all suppliers and business partners to comply with applicable labour laws and to respect internationally recognised labour rights. Where we identify an actual or potential modern slavery risk, we will investigate the matter, seek corrective action where appropriate, and consider suspending or ending the relationship if the issue cannot be resolved.

Supply chain and special consideration: sugar cane from Brazil

bottle up recognises that some human rights risks may be more likely to occur in supply chains than in our direct operations. This is particularly important where raw materials are grown, harvested, processed or manufactured in countries or sectors that may carry higher risks relating to labour standards, land use, seasonal work, migrant labour, occupational health and safety, low wages, or community impacts.

A specific consideration for bottle up is the use of sugar cane from Brazil in our plant-based bottle material. While sugar cane can offer environmental benefits as a renewable input, we recognise that agricultural supply chains can present human rights and labour risks if they are not properly managed. These risks may include poor working conditions, unsafe labour practices, excessive working hours, inadequate pay, forced or bonded labour, child labour, land-related impacts, and impacts on local communities.

bottle up therefore treats sugar cane sourcing from Brazil as a priority human rights due diligence consideration. We will seek to work with credible suppliers and manufacturing partners that can provide appropriate assurances on responsible sourcing, labour standards, traceability, environmental management and compliance with applicable laws. Where available, we will request relevant evidence, certifications, supplier policies, audit information or other documentation that helps demonstrate that human rights risks are being identified and managed.

bottle up expects all suppliers, manufacturing partners, logistics partners, distributors and other business partners to respect human rights and to operate in line with the principles of this policy. This includes expectations relating to lawful employment, fair treatment, safe working conditions, non-discrimination, no forced labour, no child labour, responsible recruitment, reasonable working hours, fair pay, and respect for workers’ ability to raise concerns.

We seek to embed these expectations through supplier selection, supplier communication, contracts, due diligence, ongoing review and corrective action where needed. The level of due diligence will be proportionate to the nature of the relationship, the country or sector risk, the importance of the supplier, and the potential severity of any human rights impact.

Braskem – Supplier Spotlight

bottle up uses Braskem “I’m Green” bio-based materials for all sugar cane-based products. This is an important part of our human rights approach because Braskem’s I’m Green programme includes a Responsible Ethanol Sourcing Programme for the ethanol supply chain, which is the key agricultural input used to produce bio-based polyethylene from sugar cane.

Braskem’s Responsible Ethanol Sourcing Programme uses the Bonsucro© Production Standard as a reference for assessing responsible ethanol sourcing. Its stated objectives are to help ensure that livelihoods are improved, human rights are respected, land rights are protected, local agricultural and industrial workers benefit, forests and natural ecosystems are protected and restored, biodiversity and ecosystem services are conserved, and climate change impacts are reduced.

The programme assesses suppliers through principles covering management and ethics, quality, environment, and social and human rights. The social and human rights requirements include expectations relating to hiring and labour, working hours, wage payments, freedom of association, prohibition of discrimination, whistleblowing channels, training, prohibition of child labour and labour conditions. The wider programme also includes requirements relating to legal compliance, supplier management, environmental management, pesticides, biodiversity, air quality, emissions and community impacts.

bottle up recognises Braskem I’m Green as a key due diligence control for our sugar cane-based products. We will continue to request and retain appropriate evidence relating to Braskem’s responsible sourcing programme, supplier controls and relevant certifications, and we will treat the Brazilian sugar cane supply chain as a priority area for ongoing human rights and environmental due diligence.

Human rights due diligence

bottle up takes a proportionate, risk-based approach to human rights due diligence. This means we will seek to identify and understand the most relevant human rights risks connected to our business, with particular attention to our product supply chain, raw materials, manufacturing, logistics, distribution and partnerships.

Our approach may include reviewing supplier information, requesting policies or certifications, assessing country and sector risks, considering stakeholder concerns, reviewing contractual arrangements, asking suppliers about labour practices, and investigating concerns where they arise.

Where we identify actual or potential human rights impacts, we will seek to prevent, reduce or address them in a practical and proportionate way. This may include engaging with suppliers, requesting corrective action, increasing monitoring, changing purchasing practices, seeking external advice, or ending relationships where serious issues cannot be resolved.

Grievance and raising concerns

bottle up encourages workers, freelance contractors, suppliers, customers, partners, communities and other stakeholders to raise concerns about human rights, labour standards, modern slavery, discrimination, harassment, unsafe work, supply chain practices, or any suspected breach of this policy.

Concerns may be raised through bottle up’s grievance procedure. All concerns will be reviewed fairly, confidentially where appropriate, and without retaliation against any person who raises a concern in good faith. Where a concern is upheld, bottle up will take appropriate corrective action and, where relevant, update its procedures, supplier controls or due diligence approach to reduce the risk of recurrence.

Governance and accountability

Accountability for this policy sits with bottle up’s Board of Directors. The Board of Directors is responsible for approving this policy, ensuring it is embedded within the company, reviewing material human rights risks, overseeing serious concerns, and ensuring appropriate action is taken where actual or potential human rights impacts are identified.

This policy is embedded through bottle up’s governance, supplier management, impact management and decision-making processes. In practice, this means that human rights considerations are taken into account when selecting suppliers, reviewing material supply chain risks, entering into key commercial relationships, assessing stakeholder concerns, and managing any actual or potential non-compliance.

bottle up will monitor human rights risks on a proportionate basis, with particular focus on higher-risk areas of the supply chain, including raw material sourcing, manufacturing and logistics. The Board of Directors will periodically review the effectiveness of this policy and any related controls, including supplier due diligence, grievances, corrective actions and relevant changes in supply chain risk.

Review

This policy will be reviewed at least every three years, or sooner if bottle up identifies a material human rights risk, changes its supply chain, introduces new materials, enters a higher-risk market, receives a significant grievance, or identifies a need to strengthen its approach.

 

Grievance Procedure

As part of our B Corp commitment, whilst we proudly haven’t had any grievances raised to-date, this Grievance Policy is in place to reassure stakeholders that any future issues would be handled professionally and swiftly. At bottle up, we aim to work openly, honestly and responsibly with everyone we interact with. We recognise that concerns may sometimes arise, and we want all stakeholders to feel comfortable raising them. This policy explains how to share a grievance with us, how we handle it and how we make sure concerns are treated fairly and confidentially.

Stakeholders include customers, suppliers, subcontractors, contractors, investors, community members and anyone else who may be affected by our work.

If you would like to raise a grievance, please email:

Name: bottle up

Email: hello@bottleup.com 

1. What We Consider a Grievance

We accept grievances about any issue where you believe bottle up may have:

• Caused or contributed to a negative impact
• Created a risk of harm
• Not met an agreement or expectation
• Not followed a stated commitment or policy
• Acted in a way that felt unfair, unsafe or inappropriate
• Affected people, communities or the environment

If something does not fall under these areas, we will still take the time to explain why and offer guidance on what may be more suitable.

2. How to Raise a Grievance

To raise a grievance, simply email at the address above.

If you prefer to stay anonymous throughout the review process, please let us know and we will keep your identity confidential.

When you first contact us, we will let you know:

• Who will be looking into the issue
• What information we may need
• Whether anyone else may need to be involved
• How we will protect your confidentiality

We will only involve other people if it is essential to understand or resolve the issue, and we will ask for your consent first wherever possible.

We will confirm receipt of your grievance within five working days.

3. How We Handle a Grievance

Our approach is designed to be fair, thoughtful and timely. Although every situation is different, we generally follow these steps.

Step 1: Acknowledgement

We confirm we have received your grievance and outline the next steps.

Step 2: Initial Review

We review the information shared and decide whether the issue meets the criteria for a formal grievance. This normally takes up to ten working days.

If it is not accepted, we will explain why and suggest any alternative routes if relevant.

Step 3: Looking into the Issue

If it is accepted, we gather the information needed to understand what has happened. This may include speaking with relevant people (with your consent) or reviewing any supporting details you provide.

If the issue involves specialist topics or vulnerable stakeholders, we may seek advice from an independent expert.

This stage usually takes up to twenty working days.

Step 4: Finding a Resolution

Once we have a clear picture, we will share our findings with you and talk through any proposed actions or next steps.

This should happen within thirty working days of accepting the grievance.

Step 5: Final Response

We provide a final response confirming what was done, what we concluded and what actions will be taken.

We aim to resolve any grievance within forty working days. If more time is needed, we will let you know.

Step 6: Tracking

We record each grievance in a confidential log, including key dates, actions, outcomes and any follow-up required. The log is reviewed periodically to monitor progress, identify recurring issues and support continuous improvement.

4. How We Work Towards a Resolution

Depending on the situation, a resolution may involve:

• Correcting a mistake or improving a process
• Providing additional guidance or training
• Updating internal practices
• Taking action with suppliers or subcontractors
• Repairing or remaking work where appropriate
• Putting additional safeguards in place
• Addressing misconduct or confidentiality breaches

All resolutions are handled carefully and respectfully.

5. Communication Throughout the Process

We aim to keep you informed at key stages, including:

• When we receive your grievance
• When we begin reviewing it
• If we need more information or more time
• When we share findings
• When the issue is resolved

If your grievance is not accepted, we will explain this clearly and respectfully.

 

JEDI Commitment Statement

We are committed to creating an inclusive, respectful and fair business, where people are treated with dignity and opportunities are accessible to all. We recognise that equity and inclusion require active and ongoing attention, shaped by the experiences of the people we work with, the communities we serve, and the partners in our wider value chain. This commitment applies to all policies and practices across our operations, our relationships with customers, and our engagement with communities.

We build a culture where different perspectives are welcomed, discrimination, harassment and unfair treatment are not tolerated, and people feel able to contribute, raise concerns and share feedback. Our policies, working practices, communications and decision-making processes are reviewed to identify barriers and ensure that our approach remains fair, transparent and proportionate to the size and nature of our business.

Where relevant, we support equity and inclusion across our business and value chain through practical action. This includes improving accessibility, strengthening recruitment and supplier practices, supporting inclusive communication, engaging with workers and stakeholders, and ensuring that our expectations around respect, fairness and non-discrimination are reflected in the way we work with others.

We listen to feedback, respond to issues where they arise, and continue to improve our practices over time. Equity and inclusion are part of everyday business conduct, embedded in how we operate, how decisions are made, and how we work with others.

Accountability for our JEDI commitment sits with the Directors, who are responsible for ensuring that equity, inclusion, respect and fairness are reflected in our policies, practices and decision-making.

 

 

Climate, Environment and Circularity Action Plan (2026-2030)

1. Purpose

bottle up recognises that climate change, environmental degradation, resource use and waste are defining challenges for businesses, communities and natural systems. As a small company, our approach is designed to be practical, proportionate and focused on the areas where we can have the greatest influence.

Our core product already supports a simple environmental principle: reduce reliance on single-use bottled water by offering water in a reusable, plant-based bottle that is designed to be refilled and kept in use. This action plan sets out how we will continue to measure, manage and improve our climate, environmental and circularity performance over the coming B Corp certification cycle.

2. Our Climate Commitment

bottle up supports the global ambition to limit warming to 1.5°C above pre-industrial levels, in line with the goals of the Paris Agreement and the wider need to reduce greenhouse gas emissions across the global economy.

As a small business, our immediate priority is to build a reliable emissions baseline, improve the quality of our environmental data, and make better decisions across product design, sourcing, operations and supplier engagement. We will use this plan as a living roadmap, helping us move from measurement in Year 0 towards deeper supply chain engagement and Scope 3 emissions understanding over Years 3 to 5.

3. Current Environmental Position – June 2026

bottle up’s environmental position is built around a simple principle: the most effective way to reduce the environmental impact of drinking water on the go is to move everyday consumption away from single-use water bottles and other disposable water formats, and towards repeated reuse.

Interestingly, we sometimes get asked why we believe another bottle can help reduce single-use bottled water. For us, the answer is that single-use water is so deeply embedded in everyday life that real change has to come from within the category itself. Instead of asking people to completely change their habits overnight, we believe we need to offer a better alternative in the places where single-use is still the default.

Our product has been designed to support that shift in a practical, accessible and scalable way. bottle up bottles are made from 100% plant-based HDPE derived from sugar cane, using Braskem’s I’m green™ bio-based material. This means the bottle material is bio-based HDPE rather than a blend of plant-based and fossil fuel-based HDPE. The bottles are designed to be strong, BPA-free, refillable and recyclable through relevant HDPE recycling streams where suitable collection and recycling infrastructure exists.

In addition to using plant-based materials, another core environmental value of the model comes from reuse. A reusable bottle only delivers its full potential when it is used repeatedly, and our customer engagement, product design and wider business model are therefore focused on encouraging people to refill and reuse their bottle as many times as possible. Durability, portability and convenience are central to this approach because reuse has to fit naturally into everyday life if it is to displace single-use water bottle consumption at scale.

Our product-level Life Cycle Assessment reviews support this position. The 2025 ACV Brasil LCA assesses reusable Green PE BottleUp bottles against disposable PET bottles, disposable aluminium cans, disposable carton packaging and reusable aluminium bottles, across the UK, France and Benelux, following ISO 14040 and 14044. The study was independently critically reviewed by AmSpec in accordance with ISO 14040:2006 and ISO 14044:2006. AmSpec concluded that the LCA complies with the methodological requirements of ISO 14044:2006, is supported by data that faithfully represent the unit processes analysed, and is suitable for use in B2B, B2C and environmental-labelling communications, subject to the scope and limitations of the study. The independent review further confirmed that the methodologies applied are consistent with international standards, the calculation models have scientific validity and technical integrity, and the report is transparent and consistent, allowing the results to be reproduced.

Under the UK 10-use scenario for the 500 mL bottle up bottle, the LCA reports a climate change impact of 0.00162 kg CO2 eq per litre, compared with 0.182 kg CO2 eq per litre for a 500 mL disposable PET bottle, 0.2416 kg CO2 eq per litre for a 330 mL aluminium can, 0.1136 kg CO2 eq per litre for 500 mL carton packaging, and 0.0540 kg CO2 eq per litre for a 500 mL reusable aluminium bottle. Put simply, this means bottle up’s climate impact is approximately 99.1% lower than 500 mL disposable PET, 99.3% lower than a 330 mL aluminium can, 98.6% lower than 500 mL carton packaging, and 97.0% lower than the 500 mL reusable aluminium bottle in the UK 10-use scenario assessed.

The same pattern is shown for fossil resource use. Under the UK 10-use scenario, the LCA reports bottle up at 0.242 MJ per litre, compared with 3.49 MJ per litre for a 500 mL disposable PET bottle, 2.80 MJ per litre for a 330 mL aluminium can, 2.10 MJ per litre for 500 mL carton packaging, and 0.639 MJ per litre for a 500 mL reusable aluminium bottle. Expressed as percentage reductions, bottle up’s fossil resource use is approximately 93.1% lower than 500 mL disposable PET, 91.4% lower than a 330 mL aluminium can, 88.5% lower than 500 mL carton packaging, and 62.1% lower than the 500 mL reusable aluminium bottle in the UK 10-use scenario assessed.

These findings reinforce the importance of reuse as the central impact lever. The LCA includes minimum, average and maximum reuse scenarios of 10, 30 and 100 uses, with the same use-phase assumptions applied to bottle up and reusable aluminium bottles. Even under the limited 10-use scenario, bottle up performs strongly against the single-use alternatives assessed. Greater reuse is expected to strengthen the environmental case further, provided the bottle remains in active use and is managed responsibly at end of life. This is why our communications and customer engagement place a clear emphasis on refill behaviour, long-term use and responsible disposal.

Material choice is also an important part of our environmental model. By using plant-based HDPE derived from sugar cane, we reduce reliance on fossil-based plastic feedstocks while retaining the practical benefits of HDPE, including durability, low weight and compatibility with established recycling streams in relevant markets. The lightweight nature of the bottle also supports efficient distribution and everyday portability, helping to make reuse convenient for customers in real-world settings.

We recognise that bio-based materials must be sourced responsibly. Our use of Braskem’s I’m green™ material is supported by Braskem’s Responsible Ethanol Sourcing Programme, which is designed to monitor and improve sustainability practices within the sugar cane ethanol supply chain. The programme uses Bonsucro as a key reference point and includes expectations covering management and ethics, quality, environment, and social and human rights. These areas include supplier management, legal compliance, waste and water management, biodiversity, air emissions, working hours, payment, freedom of association, non-discrimination, child labour, labour conditions, and health and safety.

This sourcing context matters because the benefits of a bio-based material depend on the quality and integrity of the upstream supply chain. Sugar cane production can create environmental and social risks if it is poorly managed, including risks linked to land use, biodiversity, water, agricultural inputs, labour rights and community impacts. Braskem’s programme provides a due diligence framework for monitoring these issues and encouraging improvement among ethanol suppliers, including through audits, supplier requirements and alignment with Bonsucro certification or Bonsucro-referenced criteria.

Our position is therefore broader than material substitution alone. bottle up’s model combines responsible material selection, product durability, customer reuse, and end-of-life recyclability. The bottle is designed to help avoid the repeated resource use, manufacturing impact and waste associated with single-use bottled water and other disposable water formats, while remaining practical enough for daily use. The environmental case is strongest when customers reuse the bottle repeatedly, refill from available water sources, and recycle it responsibly at the end of its useful life where appropriate infrastructure is available.

We also recognise the need for careful, evidence-based environmental communication. We will continue to avoid overstating the benefits of any material or product, and we will ensure that environmental claims are specific, proportionate and supported by evidence. Our claims will distinguish between the material composition of the bottle, the LCA results under the scenarios assessed, the importance of repeated reuse, and the practical dependence of recycling outcomes on local infrastructure.

We are always looking to work hand-in-hand with our key suppliers to reduce environmental impacts, where practical opportunities exist. In June 2026, through collaboration with our main supplier, Juiceworks, we moved from 6-pack cases to 12-pack cases, reducing the amount of secondary packaging plastic used per bottle by approximately 12.4%, and reducing secondary cardboard packaging by 32.7% per bottle. This change reflects our broader approach to continual improvement: focusing first on the core impact of replacing single-use bottled water with reuse, while also addressing the supporting materials and operational choices that influence the overall environmental footprint of the product.

bottle up also considers the source of the water itself. Our bottles are pre-filled with pure still water from Lichfield, UK, close to the point of bottling. This supports our wider environmental model by reducing unnecessary transport and avoiding the international shipping of water where a suitable local source is available. We do not have ambitions to transport our water around the globe. Instead, our focus is on making reuse work at scale in the UK and Western Europe, where we can source responsibly, reduce avoidable transport impacts, and support customers to move away from single-use bottled water in a practical and regionally appropriate way.

Although bottle up’s office energy use is not a material driver of our overall environmental impact, it remains important because our Netherlands office is the only site under our operational control. We therefore include office energy within our environmental review and continue to monitor how this part of our footprint is managed.

Please refer to the documents “Secondary Packaging Letter”, “Braskem – Responsible Ethanol Sourcing 2024”, “2025 Energy Bill (with English translation)”, “ACV Brasil – LCA for bottles” and “ACV Brasil – LCA Critical Review (AmSpec)” for more information.

Summary of current initiatives:

• Using bottles made from 100% plant-based HDPE derived from sugar cane.
• Designing products for reuse, rather than single-use disposal.
• Offering a bottle that is BPA-free and intended for repeated refilling.
• Using Life Cycle Assessment reviews to understand product-level environmental impacts and guide environmental decision-making, with two-tier third-party independent audits.
• Promoting a lower-impact alternative to conventional single-use bottled water.
• Reducing transport impacts by sourcing water as locally and practically as possible.
• Supporting clean drinking water projects through bottle up’s wider impact model.
• Using 100% Dutch wind electricity, SMK certified, at our Netherlands office, while recognising that the site also uses natural gas for heating.
• Reducing secondary packaging plastic per bottle by 12.4% by moving from 6-pack cases to 12-pack cases in June 2026.
• Reducing secondary packaging cardboard per bottle by 32.7% by moving from 6-pack cases to 12-pack cases in June 2026.

4. Scope of the Plan

This Climate, Environment and Circularity Action Plan covers bottle up’s key climate, environmental and circularity impacts, including:

GHG inventory – Direct operational emissions, Scope 1

GHG inventory – Purchased energy emissions, Scope 2

GHG inventory – Value chain emissions, Scope 3

Product-level environmental impacts, LCA

Material sourcing

Water sourcing

Packaging considerations

End-of-life considerations

Energy, waste and water at controlled sites

Supplier engagement

Climate-related risks and opportunities

Customer behaviour, especially reuse and refill

The plan is comprehensive but intentionally simple, so that it can be managed by a small company without creating unnecessary administrative burden. It will be reviewed at least annually and updated as better data becomes available.

5. Our 5-year Action Plan

GHG inventory – Direct operational emissions, Scope 1

We will baseline our direct operational emissions in 2026 and monitor these on an ongoing basis. This includes emissions from sources under our operational control, including natural gas use at our Netherlands office, which is treated separately from our renewable electricity supply.

Five-year objective: Establish and maintain annual Scope 1 monitoring from the 2026 baseline and identify practical opportunities to reduce direct fossil fuel use where feasible.

Actions: Review Scope 1 emissions annually, including natural gas use, and record any material changes in site use, heating arrangements or operational control. Where practical options are available, assess opportunities to reduce reliance on natural gas over the five-year cycle.

GHG inventory – Purchased energy emissions, Scope 2

We will baseline our purchased energy emissions in 2026 and monitor these on an ongoing basis. Our Netherlands office is supplied with 100% Dutch wind electricity, SMK certified, and our ongoing commitment is to continue using 100% renewable electricity for all sites under our operational control.

Five-year objective: Maintain 100% renewable electricity for all sites under our operational control throughout the five-year cycle.

Actions: Review electricity supply annually and retain evidence of renewable electricity procurement, including supplier documentation, certification or equivalent verification. Apply the same renewable electricity commitment to any future site under our operational control.

GHG inventory – Value chain emissions, Scope 3

We have not yet completed a full Scope 3 emissions baseline. However, we recognise that many of our most material climate impacts are likely to sit within our wider value chain, including materials, manufacturing, packaging, logistics, product use and end-of-life.

Five-year objective: Develop a proportionate Scope 3 approach, beginning with the most material and practical categories, with timing and methodology to be confirmed from 2026 or 2027 onwards.

Actions: Identify priority Scope 3 categories by the next review cycle, focusing on materials, manufacturing, packaging, logistics and end-of-life. Begin collecting supplier and activity data for the most relevant categories, then use the findings to inform future reduction priorities.

Product-level environmental impacts, LCA

We use product-level Life Cycle Assessment reviews to understand the environmental impacts of our bottle across key life cycle stages. Our final LCA assesses bottle up against disposable PET bottles, disposable aluminium cans, disposable carton packaging and reusable aluminium bottles, with reuse identified as the central driver of reduced impact.

Five-year objective: Keep our product-level environmental evidence current and use it to guide product decisions, supplier engagement and customer communications.

Actions: Review the LCA whenever there are material changes to product design, materials, suppliers, production, packaging or distribution. Reassess whether an updated LCA is needed at least once during the five-year cycle.

Material sourcing

Our bottles are made from 100% plant-based HDPE derived from sugar cane, using Braskem’s I’m green™ bio-based material. This supports a reduction in reliance on fossil-based plastic feedstocks while retaining the durability, low weight and recyclability benefits of HDPE.

Five-year objective: Maintain traceability and responsible sourcing oversight for our plant-based HDPE material.

Actions: Retain current supplier documentation confirming material composition and sourcing approach. Review relevant supplier information, including Braskem’s responsible sourcing programme, at least annually or when supplier arrangements change.

Water sourcing

We source water locally and practically wherever possible, including pure still water from Lichfield in the UK for UK production. This helps reduce unnecessary transport impacts and avoids shipping water internationally where a suitable local source is available close to bottling.

Five-year objective: Continue to prioritise local or regionally appropriate water sourcing close to bottling locations.

Actions: Review water sourcing arrangements annually and when entering new markets or changing bottling partners. Where new supply arrangements are considered, include transport distance and local sourcing practicality as part of the decision-making process.

Packaging considerations

We review secondary packaging and work with suppliers to reduce packaging impacts where practical. In June 2026, through collaboration with our main supplier, Juiceworks, we moved from 6-pack cases to 12-pack cases, reducing secondary packaging plastic per bottle by approximately 12%.

Five-year objective: Continue reducing avoidable secondary packaging impacts while maintaining product protection and operational practicality.

Actions: Review secondary packaging annually with key suppliers, including Juiceworks, to identify realistic opportunities for material reduction, improved recyclability or better packaging efficiency. Record any changes made and quantify reductions where data is available.

End-of-life considerations

Our bottles are designed to be recyclable through relevant HDPE recycling streams where suitable collection and recycling infrastructure exists. We recognise that end-of-life outcomes depend on local systems and customer behaviour, so our communications focus on responsible use, repeated reuse and appropriate disposal.

Five-year objective: Keep end-of-life guidance accurate, practical and aligned with recycling infrastructure in key markets.

Actions: Review customer-facing reuse and recycling guidance annually to ensure claims remain accurate and proportionate. Update on-pack, website or customer guidance where changes in market infrastructure, product design or evidence require it.

Energy, waste and water

bottle up operates from one leased office. In accordance with B Lab’s Environmental Stewardship & Circularity requirements, we apply an operational control approach when determining the environmental data included within our monitoring boundary.

We have operational control over the office energy used directly by bottle up and therefore monitor this using available meter data, supplier invoices and other relevant records.

Waste collection and water provision for the building are managed centrally by the landlord. bottle up does not select or manage the waste contractor, determine waste treatment arrangements, manage the building’s water supply, or have access to company-specific waste or water consumption data. We therefore do not have the authority to implement or change the relevant environmental management practices for these activities.

Under B Lab’s definition, ESC1.1 and ESC1.3 apply to facilities and environmental activities over which the company has operational control, meaning that it has the authority to implement environmental policies and manage the related practices. Accordingly, landlord-controlled waste and water associated with our leased office are outside bottle up’s operational control and are therefore excluded from quantitative monitoring under ESC1.1 and ESC1.3.

We will retain a documented record of this boundary and review it if our lease arrangements, landlord responsibilities or level of operational control change.

Five year objective: Maintain consistent and reliable monitoring of energy use within bottle up’s operational control, supported by appropriate performance objectives and year on year tracking. Continue to review the operational boundary for waste and water and bring these impacts into quantitative monitoring if bottle up gains sufficient operational control over them.

Actions: Record and review energy data at least annually using consistent units and a clearly defined reporting boundary. Investigate significant changes in energy performance and address gaps in source data where practical. Review landlord and lease arrangements periodically to confirm the operational control assessment for waste and water, documenting any changes that would bring these activities within the scope of ESC1.1 or ESC1.3.

Supplier engagement

We engage suppliers on practical opportunities to improve environmental performance, including packaging reduction, material sourcing and product impact considerations. This includes working with Juiceworks on secondary packaging improvements and relying on Braskem’s Responsible Ethanol Sourcing Programme as part of our due diligence for sugar cane-based material sourcing.

Five-year objective: Build a simple supplier engagement process focused on the suppliers and topics most relevant to our environmental impact.

Actions: Identify priority suppliers for environmental engagement, including suppliers linked to materials, production, packaging and logistics. Request relevant environmental information from priority suppliers at least once during the five-year cycle, with annual follow-up where the supplier or topic is material.

Climate-related risks and opportunities

We recognise climate-related risks linked to materials, agriculture, transport, energy, regulation and changing customer expectations. We also see a clear opportunity to support lower-impact drinking habits by replacing conventional single-use bottled water with a durable, refillable and reusable alternative.

Five-year objective: Review climate-related risks and opportunities regularly and use the findings to inform business planning.

Actions: Complete a light-touch annual review of climate-related risks and opportunities, covering materials, energy, transport, regulation, customer expectations and supply chain resilience. Record any priority issues and assign follow-up actions where a risk or opportunity is significant.

Customer behaviour, especially reuse and refill

Customer behaviour is central to our environmental model. Our bottle delivers its strongest environmental benefit when it is reused repeatedly, so our product design, customer messaging and wider business model focus on making refill and reuse easy, accessible and normal in everyday life.

‘Reuse’ is a system, rather than a product. While bottle up bottles are specifically designed for reuse, they only fulfil their purpose when people have the opportunity and motivation to refill them. That is why we look beyond the bottle itself, helping customers create the conditions that make reuse work in practice. Through refill stations, in-room and in-store communications, staff guidance and other practical support, we help make refilling easier and repeatable, encouraging people to reuse their bottles again and again.

Five-year objective: Strengthen customer understanding of reuse and refill as the central driver of our environmental model, while improving our understanding of how customers actually use the bottle after purchase.

Actions: Review customer messaging annually to ensure reuse and refill remain clear, prominent and evidence-based. Explore at least one practical consumer engagement initiative during the five-year cycle, such as customer surveys, feedback forms, refill guidance, retail messaging or campaign activity, to better understand reuse behaviour and identify ways to encourage repeated refilling.

6. Circularity Priorities

Our circularity approach is based on keeping products and materials in use for longer, while reducing the need for single-use alternatives.

Our priorities are to design bottles for reuse, ensuring they are durable enough to be refilled repeatedly; encourage customers to keep and refill their bottles, because reuse is central to the product’s environmental benefit; and design for recyclability, so that our materials are compatible with relevant recycling systems wherever possible.

We also aim to reduce unnecessary packaging, avoid materials that create avoidable waste, and work with suppliers to improve recycled, renewable or lower-impact content where this is technically and commercially viable. Alongside this, we will continue to review our end-of-life messaging so that customers understand how to dispose of bottles responsibly when they can no longer be reused.

We recognise that circularity depends on both product design and real-world behaviour. For that reason, our focus is not only on what the bottle is made from, but also on how long it is used, how often it is refilled, and how responsibly it is managed at the end of its useful life.

7. Climate and Environmental Risks

We recognise that climate change and wider environmental pressures may create risks for our business, our suppliers, our customers and the markets in which we operate. Globally, businesses are already facing more frequent disruption from extreme weather, rising temperatures, water stress, shifting regulation and growing scrutiny of environmental claims. For bottle up, these risks are particularly relevant because our model depends on agricultural raw materials, water availability, manufacturing partners, transport networks, credible environmental communication and customer participation in reuse.

A key area of vulnerability is our reliance on bio-based material. Our bottles are made from plant-based HDPE derived from sugar cane, which means that parts of our upstream supply chain may be exposed to climate-related agricultural risks. These include changing rainfall patterns, drought, heat stress, land-use pressures, biodiversity impacts and potential disruption to crop yields or production costs. We consider the likelihood of some level of climate-related pressure on agricultural supply chains over the next five years to be medium to high, although the direct impact on bottle up will depend on supplier resilience, sourcing arrangements and the availability of suitable material inputs.

Water availability and quality are also important considerations. While we source water locally and practically wherever possible, including UK water close to bottling for UK production, changing rainfall patterns, drought, water stress or local infrastructure pressures could affect water availability, production planning or stakeholder expectations in some regions. We currently consider the likelihood of direct material disruption to bottle up’s water sourcing over the next five years to be low to medium, but the wider likelihood of increasing scrutiny around responsible water use is medium to high.

Transport and logistics present another area of risk. Extreme weather events, fuel and energy price volatility, port disruption, road disruption and broader supply chain instability may affect the movement of raw materials, bottles, packaging and finished products. We consider the likelihood of occasional transport or logistics disruption over the next five years to be medium, with the potential impact depending on the location, duration and severity of any disruption.

We also recognise regulatory risks. Policy and market expectations are evolving quickly in areas such as plastics, packaging, environmental claims, carbon reporting, extended producer responsibility, recycling labelling and product-level environmental information. These changes may increase compliance requirements, reporting expectations or the need for clearer evidence behind claims. We consider the likelihood of relevant regulatory or market expectation changes over the next five years to be high.

Reputational and communication risks are also material. Customers, retailers and regulators are increasingly attentive to the accuracy and clarity of environmental claims. Claims relating to bio-based plastic, recyclability, reuse, carbon impact, local sourcing and end-of-life disposal must therefore be specific, balanced and evidence-based. We consider the likelihood of increased scrutiny of environmental claims over the next five years to be high, particularly for products positioned as alternatives to conventional single-use bottled water.

Customer understanding is another important risk area. Our environmental model depends on customers keeping and refilling the bottle, rather than treating it as another disposable format. Confusion around reuse, refill, bio-based plastic, recyclability or responsible disposal could reduce the environmental benefit of the product in real-world use. We consider the likelihood of this behavioural risk to be medium, which is why clear customer communication and engagement will remain central to our approach.

Supply chain costs may also rise as suppliers respond to higher energy costs, material constraints, logistics disruption, regulation or climate adaptation needs. These pressures may affect material prices, manufacturing costs, packaging choices or distribution. We consider the likelihood of some cost pressure over the next five years to be high, although the level of impact will depend on market conditions and supplier resilience.

We will manage these risks through proportionate and practical action. This includes maintaining supplier engagement, reviewing product and packaging decisions, keeping environmental claims evidence-based, improving data collection, monitoring emerging regulation, and reviewing climate-related risks and opportunities annually. Our approach is to focus on the areas most relevant to our business model, while ensuring that climate and environmental risks are considered as part of ongoing decision-making rather than treated as a one-off review.

8. Responsibilities

Overall responsibility for this action plan sits with bottle up’s leadership team. Day-to-day implementation will be proportionate to the size of the company and integrated into existing business decisions rather than managed as a separate administrative exercise. Our responsibilities include:

Maintaining GHG emissions records

Reviewing LCA evidence

Keeping supplier information up to date

Ensuring environmental claims are accurate

Reviewing progress annually

Identifying practical improvement actions

Embedding climate, environment and circularity considerations into product and supplier decisions

This approach is intended to keep the plan useful, manageable and connected to real business activity, while ensuring that environmental responsibility remains part of how we make decisions over the five-year cycle.

9. Targets and Milestones

Annual actions

• Review Scope 1 and Scope 2 emissions records, including natural gas and purchased electricity.
• Confirm that all electricity for sites under our operational control remains 100% renewable, with supporting supplier evidence retained.
• Review customer-facing environmental claims to ensure they remain accurate, balanced and evidence-based.
• Review reuse, refill and end-of-life messaging to ensure customers understand how to use and dispose of the bottle responsibly.
• Review supplier information for key environmental inputs, including plant-based HDPE, packaging and bottling partners.
• Review water sourcing arrangements to ensure local or regionally appropriate sourcing remains prioritised where practical.
• Review climate and environmental risks, including regulation, materials, water, transport, customer expectations and supply chain resilience.
• Review progress against this action plan and record any updates, decisions or improvement actions.

At least twice within the five-year cycle

• Review secondary packaging with key suppliers, including Juiceworks, to identify practical opportunities for material reduction, improved recyclability or better packaging efficiency.
• Review customer engagement around reuse and refill, including practical feedback methods such as surveys, feedback forms or campaign learning.
• Review priority supplier engagement and request updated environmental information from suppliers linked to materials, production, packaging and logistics.
• Review whether changes in markets, regulation or customer expectations require updates to environmental messaging or product guidance.

At least once within the five-year cycle

• Begin developing a proportionate Scope 3 approach, starting with the most material and practical categories such as materials, manufacturing, packaging, logistics and end-of-life.
• Reassess whether an updated LCA or equivalent product-level environmental assessment is needed, particularly if there have been material changes to product design, materials, suppliers, packaging or distribution.
• Carry out a structured review of climate-related risks and opportunities to inform future business planning and supplier engagement.
• Explore at least one practical initiative to better understand or encourage reuse behaviour, such as a customer survey, refill-focused campaign, retail messaging trial or improved reuse guidance.

As needed

• Update the LCA or product-level evidence if there is a material change to product design, materials, production, packaging, supplier arrangements or distribution.
• Review environmental claims before any major new campaign, product launch or public sustainability communication.
• Apply environmental impact considerations to any future product development, including material selection, durability, reuse potential, packaging, logistics, end-of-life and evidence for claims.
• Review energy arrangements if bottle up moves office, gains operational control of a new site, changes supplier, or materially changes energy use.
• Review water sourcing and transport considerations when entering new markets, changing bottling partners or altering production locations.

10. Monitoring and Review

bottle up will review this Climate, Environment and Circularity Action Plan annually. The review will consider emissions data, LCA findings, supplier information, regulatory changes, customer feedback and progress against the milestones in this plan.

Where progress is slower than expected, bottle up will document the reason and identify a practical next step. Where better information becomes available, bottle up will update its approach so that decisions remain grounded in evidence.

This plan reflects bottle up’s commitment to continuous improvement. We know that climate and circularity work is an ongoing process, and we will continue to improve our understanding, reduce our impacts where we can, and help customers move away from unnecessary single-use bottled water.