Flex Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Flex Ltd provides a very detailed picture of its climate-policy lobbying. It identifies several concrete measures it has worked on, including California’s “Senate Bill-100 California Renewables Portfolio Standard Program,” the “US Solar Tariff,” and the Bureau of Land Management’s “Competitive Processes, Terms, and Conditions for Leasing Public Land for Solar and Wind Energy Development,” making it easy to see precisely which laws and regulations the company tries to influence. The company also spells out how and where it lobbies: “NEXTracker lobbied in Sacramento, California in support of solar photovoltaic and energy storage legislation,” its founder and CEO gave testimony before the “House Committee on Natural Resources Subcommittee on Energy and Mineral Resources,” and it engages indirectly through bodies such as the Silicon Valley Leadership Group and the Business Roundtable, with targets ranging from the California State Assembly to the Bureau of Land Management and U.S. trade authorities. Finally, Flex is explicit about what it wants from each engagement—securing “directional support … for 100% renewable” power, achieving “the lowest levelized cost of producing energy through solar” by opposing import tariffs, and revising the BLM leasing rule so that rental rates “align with the unique economics of solar projects,” alongside calls for Direct Pay of the Investment Tax Credit and increased federal renewable-power procurement. By naming the specific policies, the channels of influence and the concrete outcomes it pursues, the company demonstrates a high degree of transparency in its climate-related lobbying. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Flex has established a structured internal oversight mechanism to ensure its policy-influencing activities align with its climate change strategy. The company reports that it has "implemented processes to ensure direct and indirect activities that influence policy are consistent with our overall climate change strategy," under which "Sustainability Regional Leads (RLs) and Corporate Real Estate and Facilities (CREF) Regional Leads (RLs) report any pertinent activity in their regions to CREF Vice President (VP) and the Head of Global Sustainability on a regular basis," and these senior executives "provide leadership and resources to drive global climate-related activities." it underscores its alignment with international climate objectives by committing to conduct its engagement "in line with the goals of the Paris Agreement." Flex has disclosed several trade associations of which it is a member that engage with climate policy. The company states that its positions on climate change are aligned; however, a formal process to address any misalignments does not appear to be disclosed. Flex also states that trade association membership is used "to understand various regulations and to drive compliance across Flex, not to influence policies." 2