Dell Technologies Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Dell Technologies offers a high degree of transparency around its climate-related lobbying. It names a range of specific measures it has tried to influence, including the “EU Directive on Public Procurement from 2014,” the U.S. “Inflation Reduction Act,” the SEC’s proposed mandatory climate-disclosure rule, the “Infrastructure Investment and Jobs Act,” and the hydrofluorocarbon phasedown amendment to the “Montreal Protocol,” demonstrating that its engagement spans both U.S. and international legislation. The company also describes how it lobbies and whom it targets: it hosts conferences in Brussels, launches public “Call to Action” campaigns, signs joint statements, conducts “meetings with congressional staff teams charged with developing and evaluating policy positions,” and works through trade bodies such as the Business Roundtable, Digital Climate Alliance and World Economic Forum, explicitly directing these efforts at the European Commission, several European national governments, U.S. federal legislators, the SEC and “world leaders” responsible for the Montreal Protocol. Finally, Dell states the concrete outcomes it seeks, such as to “develop guidelines for the implementation of social and environmental sustainability in public IT procurement contracts,” to “promote the use of sustainability criteria as a default in public procurement,” to decarbonize public energy grids, and to secure “an ambitious amendment to the Montreal Protocol” that includes “an early first reduction step for Article 2 countries and a freeze date for Article 5 countries that is as early as practicable.” It further records its “support with no exceptions” for the Infrastructure Investment and Jobs Act and affirms that its advocacy is “aligned with the Paris Agreement.” By clearly identifying the policies, mechanisms, targets and desired legislative changes, the company provides comprehensive insight into its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	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 Dells 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 lobbyingwhere advocacy and engagement on issues of climate policy with policymakers and regulators helps shape supportive policyand 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 Dells 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.	3