Dell Technologies Inc

Dell Technologies presents a clear framework for ensuring engagement consistency with its climate commitments, grounded in its "public Global Climate Principles document," which "lays out the principles by which Dell conducts business as it relates to climate change" and emphasizes "engagements with internal and external stakeholders" in climate action. Governance of these engagement activities occurs through a dedicated "Climate Engagement Workgroup that meets at least monthly" to "review various engagements to determine if they are appropriate to be included in Dell's overall climate action strategy," supplemented by a "lean-in process" featuring a "cross-functional group" that decides on high-profile alliances or letters. This structure encompasses both direct lobbying - where "advocacy and engagement on issues of climate policy" with "policymakers and regulators" helps shape supportive policy - and indirect lobbying via affiliations such as the "Alliance of CEO Climate Leaders," "We Mean Business Coalition," and RE100. Oversight of climate-related policy activities is embedded within Dell's broader ESG governance model, with an ESG Steering Committee and Interlock Team including government affairs functions and ultimate accountability resting with its Board of Directors and Executive Leadership Team. However, we found no evidence of a dedicated climate lobbying audit or third-party review explicitly evaluating lobbying alignment, nor is there disclosure of a named individual solely responsible for overseeing lobbying alignment or specific board-level criteria for assessing engagement through industry associations.