KLA Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	KLA Corp demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate-related efforts. The company states that its ESG and climate-related industry engagements, including participation in SEMI climate initiatives, are overseen by its ESG Global Leader and ESG Steering Committee, which drive its climate strategy and initiatives. "Our ESG steering committee receives oversight from the Nominating and Governance Committee and meets monthly to discuss ESG-related initiatives, which may include trade association engagement." This indicates a structured oversight mechanism for indirect lobbying through trade associations. Additionally, KLA monitors and reports corporate lobbying efforts, with quarterly and annual reporting by its Global Government Affairs group, and has policies requiring preapproval for any political contributions by the CFO and Legal and Compliance organization. However, while the company provides details on oversight and reporting mechanisms, it does not disclose a specific process for ensuring alignment of lobbying activities with climate goals, nor does it have a public commitment to align engagement activities with the Paris Agreement. "KLA does not engage in undisclosed political spending" and participates in trade associations such as SEMI and the Semiconductor Industry Association (SIA), but there is no evidence of actions taken to align or correct lobbying positions of these associations with its climate strategy. Furthermore, while the ESG Steering Committee and Nominating and Governance Committee provide oversight, the company does not describe a detailed monitoring or alignment process for its lobbying activities beyond general reporting and oversight structures. This indicates some governance measures but lacks comprehensive alignment mechanisms for climate lobbying. View Sources	C

Overall Assessment

Analysis

Score

Moderate

KLA Corp demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate-related efforts. The company states that its ESG and climate-related industry engagements, including participation in SEMI climate initiatives, are overseen by its ESG Global Leader and ESG Steering Committee, which drive its climate strategy and initiatives. "Our ESG steering committee receives oversight from the Nominating and Governance Committee and meets monthly to discuss ESG-related initiatives, which may include trade association engagement." This indicates a structured oversight mechanism for indirect lobbying through trade associations. Additionally, KLA monitors and reports corporate lobbying efforts, with quarterly and annual reporting by its Global Government Affairs group, and has policies requiring preapproval for any political contributions by the CFO and Legal and Compliance organization. However, while the company provides details on oversight and reporting mechanisms, it does not disclose a specific process for ensuring alignment of lobbying activities with climate goals, nor does it have a public commitment to align engagement activities with the Paris Agreement. "KLA does not engage in undisclosed political spending" and participates in trade associations such as SEMI and the Semiconductor Industry Association (SIA), but there is no evidence of actions taken to align or correct lobbying positions of these associations with its climate strategy. Furthermore, while the ESG Steering Committee and Nominating and Governance Committee provide oversight, the company does not describe a detailed monitoring or alignment process for its lobbying activities beyond general reporting and oversight structures. This indicates some governance measures but lacks comprehensive alignment mechanisms for climate lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	KLA Corp provides only limited insight into its climate-related lobbying. It notes that it "participates in trade and business associations that represent the interests of our company and industry" and cites memberships in bodies such as SEMI, the Semiconductor Industry Association and the Silicon Valley Leadership Group, implying that any climate policy engagement is channelled through these groups. Beyond describing this indirect avenue, the company does not detail how it actually engages—there is no discussion of specific meetings, letters, consultations, or the government institutions targeted. Similarly, it offers no concrete examples of the climate legislation or regulations on which these associations lobby, referring only in broad terms to addressing “regulatory challenges” and supporting industry-wide efforts to mitigate climate change. The outcomes KLA seeks remain equally vague; it expresses general support for environmental sustainability but discloses no measurable policy changes, amendments, or targets it is advocating. This high-level narrative signals that some lobbying activity exists but leaves stakeholders without substantive information on the policies, mechanisms or objectives involved, demonstrating a low level of transparency overall.	D