Applied Materials Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Applied Materials Inc. demonstrates a moderate level of governance in its lobbying activities, with some processes in place to align its efforts with broader corporate objectives, including climate-related priorities. The company states that "the ESG team works closely with Applied’s Government Affairs team to ensure awareness of Applied’s ESG-related priorities and objectives (including climate-related issues) and alignment in any engagement efforts." This indicates a mechanism for integrating climate considerations into its lobbying activities. Additionally, the company discloses that "all trade association memberships are regularly reviewed and approved initially and annually by the Vice President of Communications and Public Affairs and Managing Director, Government Affairs," which suggests some oversight of indirect lobbying. However, while the Corporate Governance and Nominating Committee oversees public policy activities and receives annual reports, there is no explicit evidence of a detailed process for monitoring or managing the alignment of lobbying activities specifically with climate goals. Furthermore, while the company mentions its participation in trade associations and advocacy efforts, it does not disclose any specific actions taken to address misalignments between its climate policy and the positions of these associations. The evidence also lacks a comprehensive description of how direct lobbying activities are aligned with climate goals. Overall, while there are some governance mechanisms in place, the disclosures do not provide sufficient detail to indicate a robust or comprehensive climate lobbying governance framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Applied Materials Inc. demonstrates a moderate level of governance in its lobbying activities, with some processes in place to align its efforts with broader corporate objectives, including climate-related priorities. The company states that "the ESG team works closely with Applied’s Government Affairs team to ensure awareness of Applied’s ESG-related priorities and objectives (including climate-related issues) and alignment in any engagement efforts." This indicates a mechanism for integrating climate considerations into its lobbying activities. Additionally, the company discloses that "all trade association memberships are regularly reviewed and approved initially and annually by the Vice President of Communications and Public Affairs and Managing Director, Government Affairs," which suggests some oversight of indirect lobbying. However, while the Corporate Governance and Nominating Committee oversees public policy activities and receives annual reports, there is no explicit evidence of a detailed process for monitoring or managing the alignment of lobbying activities specifically with climate goals. Furthermore, while the company mentions its participation in trade associations and advocacy efforts, it does not disclose any specific actions taken to address misalignments between its climate policy and the positions of these associations. The evidence also lacks a comprehensive description of how direct lobbying activities are aligned with climate goals. Overall, while there are some governance mechanisms in place, the disclosures do not provide sufficient detail to indicate a robust or comprehensive climate lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Applied Materials provides only limited detail on which climate-related public policies it tries to influence, naming the U.S. CHIPS and Science Act but not pointing to any other climate or energy measures. In contrast, the company is much more forthcoming about how it seeks to exert influence, describing direct “meetings and hearings” with both Congress and the Biden administration, participation in Semiconductor Industry Association advocacy, and its Chief Technology Officer’s seat on the federal Industrial Advisory Committee that guides implementation of the CHIPS Act. The objectives of these interventions are spelled out clearly: securing federal grants for semiconductor research, development and manufacturing, funding for workforce development, and the expansion of a federal investment tax credit for new fabrication facilities. By articulating multiple concrete outcomes and disclosing several distinct engagement channels and targets, the company shows a high level of transparency on mechanisms and goals, but its narrow focus on a single named statute limits the breadth of its policy disclosure.	B