Lodestone Communications
Code of Conduct
Introduction
1. This Code covers all activities undertaken by Lodestone and all employees are expected to adhere to its principles and requirements at all times when undertaking these activities on behalf of the company.
2. It applies to all full time employees of the company, those working on a temporary basis on behalf of, or under a temporary contract for Lodestone, and Associates and Strategic Advisory Council members when they are acting in a capacity related to the company.
3. Where there is a clear and direct overlap with, or impact on the work and reputation of the company and its clients, employees are also expected to comply with the Code in their non-professional lives.
4. In compliance with the Transparency of Lobbying, Non-Party Campaigning, and Trade Union Administration Act 2014 (the Act) and the Guidance issued by the Office of the Registrar of Consultant Lobbyists (ORCL), Lodestone is registered with ORCL and adheres to all the relevant requirements. This Code, therefore, covers and includes compliance with ORCL, and the obligations Lodestone places on all employees to ensure this compliance.
5. However, the work of Lodestone goes much wider than those activities that would fall under the scope or definitions set out in the Act or ORCL’s guidance. Therefore, this Code is drafted so as to cover all activities undertaken by the company, and not just those that would fall under ORCL’s remit.
Behaviours & expectations
6. Lodestone expects all employees, and those professionally associated with the company, to act at all times with honesty, integrity, and transparency, and in such a way so as to protect the reputation of the company and its clients.
7. No employee, or anyone professionally associated with the company, shall seek to exert improper influence nor offer or give any inducement to any holders of public office for any reason or purpose connected with the activities of the company or in seeking to advance the interests of its clients.
8. Lodestone will not engage elected representatives or members of the House of Lords specifically to undertake lobbying work on behalf of the company and its clients.
9. Where the company may employ such a representative in a wider capacity, it will do so in full accordance with any Code of Conduct or guidance from their relevant institution or employer (e.g. the Code of Conduct for Members of the House of Lords).
10. The Code of Conduct will form part of all Employment Contracts for Lodestone employees and, as well as adhering to the requirements of the Code, all employees are required to act in line with the full range of supporting internal policies, procedures, and guidance as set out in the Lodestone Employee Handbook.
Clients
11. All employees, and those professionally associated with the company, must act at all times in such a way so as to protect the reputation of those we work on behalf of.
12. In support of this, we will always be fully open and transparent in relation to our role as representatives of our clients, when engaging with political, media, or wider audiences, whilst also respecting the legitimate confidentiality of the information our clients share with us.
13. We will always be truthful and accurate in the information we share, communicate, or publicise on our clients’ behalf and ensure we do not misrepresent their interests in the course of our activities and work.
14. With regards to those we represent, we will always assess – at the Executive level – any concerns or questions about a client or potential client against our own internal ethical framework and in line with the Lodestone Mission and Values. Part of this process – alongside legal and moral considerations – will be consideration of the potential impact on our corporate reputation or that of our wider clients.
15. We will proactively manage any potential conflicts of interest – real or perceived – through assessment and consideration at the Executive level and through, where appropriate, consultation with existing clients. We will not accept new clients where these would negatively impact our relationship with current clients or the efficacy of the work we can undertake on their behalf.
Transparency of Lobbying, Non-Party Campaigning, and Trade Union Administration Act 2014, & ORCL
16. The Act and the guidance published by ORCL sets out clear definitions and requirements on those companies that fall under its remit. Lodestone has been registered with ORCL since 2017 and we have in place rigorous internal processes and procedures to ensure we comply with all our obligations under the Act, including submission of quarterly returns to the Registrar.
17. As part of these processes, we promote awareness amongst all staff of our obligations under the Act, ensure delegated responsibility for compliance and capture of relevant information on each individual client account, and oversight and sign-off from the Executive prior to each submission.
18. In the interests of transparency and ensuring full understanding of our obligations, we will also notify clients of the requirement to register relevant client names with ORCL if there is any request from the client for support or proposed activity that meets the threshold in the ORCL guidance prior to undertaking that activity.
Compliance
19. The Act and ORCL have set out the process and sanctions for breaches of its specific requirements and obligations, so these are not covered or duplicated in our Code of Conduct.
20. With regards to compliance with the wider Code, where there is a suspected or possible breach, these will be dealt with in line with our own internal processes, as set out in our Employee Handbook, with investigations led by the Chair and a Non-Executive Board Member.
21. If any external audience wishes to submit a complaint under, or suspected breach of the Code of Conduct they can do so by emailing info@lodestonecommunications.com and this will be dealt with under the same process.
Reviews & updates
21. This Code of Conduct was approved by the Lodestone Executive in April 2025 and will be reviewed annually and/or in line with changes to relevant legislation and guidance.