Varex Imaging Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Varex Imaging has a constrained governance framework for lobbying that does not extend to climate-related issues. The company states that “Varex does not have a government relations or lobbying function,” and that “as part of our conflict-of-interest policy, the Company does not give political donations globally,” while it “indirectly make[s] our voices heard” through trade associations. It describes internal controls by noting that “only a limited number of individuals are authorized to engage in efforts to discuss legislation or government policy with political officials,” and that employees “are encouraged to consult the legal department for support,” complemented by annual training for interacting with government officials. However, we found no evidence of a named individual or formal body overseeing these activities, no policy to align lobbying with climate goals, and no mechanism to monitor or manage association positions, indicating limited oversight and no climate-specific governance. View Sources	D

Overall Assessment

Analysis

Score

Limited

Varex Imaging has a constrained governance framework for lobbying that does not extend to climate-related issues. The company states that “Varex does not have a government relations or lobbying function,” and that “as part of our conflict-of-interest policy, the Company does not give political donations globally,” while it “indirectly make[s] our voices heard” through trade associations. It describes internal controls by noting that “only a limited number of individuals are authorized to engage in efforts to discuss legislation or government policy with political officials,” and that employees “are encouraged to consult the legal department for support,” complemented by annual training for interacting with government officials. However, we found no evidence of a named individual or formal body overseeing these activities, no policy to align lobbying with climate goals, and no mechanism to monitor or manage association positions, indicating limited oversight and no climate-specific governance.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Varex Imaging is upfront that it undertakes no direct climate-policy lobbying, stating that "Varex does not have a government relations or lobbying function and, as part of our conflict-of-interest policy, the Company does not give political donations globally." By clearly declaring this stance and explaining that any influence occurs only through membership in trade associations that help it "indirectly make our voices heard and gain valuable intelligence on the evolving regulatory landscape," the company provides full transparency on both the policies it does not lobby and the mechanisms it therefore does not employ. While it does not articulate concrete climate-policy outcomes it seeks, it does give a rationale for its non-engagement, allowing readers to understand the limited objectives of its indirect involvement. Overall, the disclosure offers a strong, candid picture of the company’s minimal and primarily indirect approach to climate-related lobbying.	B