Microsoft Corp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Microsoft provides an extensive and specific picture of its climate-policy advocacy. It names a wide range of concrete measures it has engaged on, including the European Commission’s Carbon Removals Certification Framework, the U.S. Inflation Reduction Act and FERC transmission rules, Virginia bills SB1027/HB981 to join the Regional Greenhouse Gas Initiative, the Clean Futures Act, Singapore’s Long-Term Low Emissions Strategy consultation, the EU Game Console Voluntary Agreement, revisions to the Non-Financial Reporting Directive, and many other identifiable initiatives across the EU, United States and Asia. The company is equally explicit about how it lobbies: it files formal submissions and comment letters (e.g., to the U.S. SEC, the EU public consultation on sustainable corporate governance, the U.S. House Energy & Commerce Committee), participates in advocacy days such as “Lawmaker Education & Advocacy Day on Carbon Pricing,” signs joint letters to policymakers (for example to MEP Pascal Canfin on a Green Recovery and to the Trump Administration on the Paris Agreement), and holds regular meetings with officials such as the European Commission Directorate-General for Energy and the Singapore National Climate Change Secretariat. Desired outcomes are clearly spelled out—for instance, Microsoft seeks “clear definitions and high-quality standards” in the EU CRCF, supports “a price on carbon and a green recovery package,” pushes for grid-decarbonization rules and expanded transmission capacity in the United States, advocates for renewable energy crediting and easier grid access in Singapore, and calls for Virginia to adopt cap-and-trade through RGGI. By disclosing specific policies, the methods and targets of its engagement, and the concrete legislative or regulatory changes it wants to see, Microsoft demonstrates a comprehensive level of transparency around its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Comprehensive Microsoft Corp demonstrates a comprehensive climate lobbying governance process that integrates transparency, accountability, and alignment with its climate-related goals. The company has disclosed a detailed report evaluating the alignment of its climate-related lobbying activities, both direct and through trade associations, with its sustainability commitments. Specifically, Microsoft provides an overview of positions on eleven key climate policies held by eight trade associations, stating, "The purpose of this report is to help us evaluate how well these trade associations align with our own sustainability goals and values, and to identify potential areas of collaboration or misalignment." Furthermore, Microsoft commits to addressing misalignment by "redoubling efforts to engage with the trade association to drive closer alignment in their advocacy for a more sustainable future." The governance framework includes oversight by the Environmental, Social, and Public Policy Committee of the Board of Directors, which "reviews and provides guidance to the Board and management about key environmental and social matters such as climate change and environmental sustainability." Additionally, the Senior Director of Global Sustainability Policy coordinates advocacy efforts to ensure consistency with Microsoft's climate change and sustainability strategy. The company also conducts annual reviews of trade association memberships to assess alignment with its public policy agenda, stating, "We will not support groups that spend an abundance of their time working against our direct business interests and public policy agenda." Details are contained within Microsoft's 2024 Lobbying Alignment Report. This indicates a robust governance process encompassing direct and indirect lobbying activities, with clear monitoring mechanisms and accountability structures in place. 4