Alphabet Inc

Alphabet Inc has a defined governance framework for its policy engagement, anchored by a "well-established compliance program and multi-layered oversight structure" led by its "Global Vice President of Government Affairs and Public Policy" with "additional input from our Chief Legal Officer," and regular updates to both the Audit Committee and full Board. On climate policy matters, "all activities related to engagement on climate policy are coordinated and managed by designated members of our operations team," who "coordinate the drafting and review of all public-facing content related to our overall energy, sustainability and climate change strategy," with materials "tracked centrally for reference and use by other employees" to maintain consistency. These designated employees "ultimately report to our Chief Legal Officer," and "sustainability teams throughout the organization use this team for review to ensure consistency with our overall climate change strategy." Alphabet also confirms a "public commitment ... to conduct your engagement activities in line with the goals of the Paris Agreement." We found no evidence of a process to assess or align its indirect lobbying through industry associations or a dedicated audit of its climate-related lobbying activities.