International Business Machines Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	IBM provides a high level of transparency around its climate-policy lobbying. It identifies several concrete policies it seeks to influence, including its founding-member support for “the plan outlined by the Climate Leadership Council that would put a tax on carbon dioxide emissions, with the proceeds of that tax — a ‘carbon dividend’ — to be returned to citizens,” its long-standing advocacy for ENERGY STAR energy-efficiency requirements for ICT products, and work with the EU Commission and the China National Institute of Standardization on comparable efficiency standards, as well as initiatives to expand corporate access to renewables and upgrade grid technology for wind and solar integration. The company is similarly explicit about how it lobbies: it has “directly participated in discussions with members of the U.S. Senate and House of Representatives” through the Climate Leadership Council, provides technical data and recommendations to the US EPA, the European Commission and Chinese standard-setting bodies, and undertakes additional advocacy through industry coalitions such as the Gridwise Alliance and the Clean Energy Buyers Alliance. Finally, IBM clearly states the outcomes it is pursuing—an economy-wide carbon fee starting at US$40/t and rising by 5 % above inflation, stringent ICT energy-efficiency rules that deliver “real improvements in energy efficiency,” and policies that give large buyers easier access to renewable electricity and modernise the grid to accommodate distributed generation. By naming the specific policies, detailing the methods and targets of engagement, and spelling out the legislative and regulatory changes it seeks, IBM demonstrates comprehensive disclosure of its climate-lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	International Business Machines Corporation demonstrates strong governance of its climate-related lobbying activities by embedding clear oversight within its global Environmental Management System, which “adheres to clearly and explicitly defined organizational roles and responsibilities.” According to IBM, “All direct and indirect activities that could be considered to influence environmental policy externally must be approved by Corporate Environmental Affairs staff and Government and Regulatory Affairs staff,” ensuring consistency with “the company’s own position on climate change and commitment to environmental leadership.” IBM further clarifies that its “Corporate Environmental Affairs staff organization is responsible for developing IBM environmental public policy positions including those addressing climate protection and advocating the company’s positions on public policies related to climate change,” while business units execute the applicable requirements. However, we found contradictory evidence regarding any public alignment with the Paris Agreement—one response states “No, and we do not plan to have one in the next two years,” while another simply states “Yes” without detail—and no publicly available audit or review assessing its climate-lobbying alignment nor a single executive or board-level committee explicitly named as the ultimate overseer of these lobbying alignment procedures.	3