Illumina Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Illumina discloses a governance structure that links climate strategy and policy engagement but provides only limited detail on how the company actively manages the substance of its lobbying. The company states that “The Board provides oversight to the CSR program covering environmental, social, and governance (ESG) topics, including climate-related issues,” and that lobbying-related engagement is handled by “Illumina’s Executive CSR Steering Committee, chaired by the Chief Financial Officer (CFO)… [which] provide[s] guidance on strategic plans, and review[s] progress on a quarterly basis.” This named body and the Board therefore give a clear point of oversight for policy engagement. Illumina also notes that “These organizations help ensure our engagement activities are consistent with our overall climate change strategy” and confirms a commitment to conduct engagement “in line with the goals of the Paris Agreement,” indicating the presence of an alignment policy. For indirect lobbying, the company commits to transparency, stating that “Illumina will publicly disclose in its annual…Report (i) each trade association to which it has paid dues…[and] (ii)…the portion of such payments that is non-deductible,” but it does not describe any process for assessing or addressing misalignment between those associations’ climate positions and its own. No evidence was found of a formal climate-lobbying audit, criteria for evaluating trade-association stances, or actions to correct or exit misaligned bodies. Overall, Illumina shows board-level and senior-management oversight and a stated intent to align engagement with climate strategy, yet it does not disclose detailed monitoring mechanisms or active alignment measures for either direct or indirect lobbying, which limits the strength of its governance. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Illumina discloses a governance structure that links climate strategy and policy engagement but provides only limited detail on how the company actively manages the substance of its lobbying. The company states that “The Board provides oversight to the CSR program covering environmental, social, and governance (ESG) topics, including climate-related issues,” and that lobbying-related engagement is handled by “Illumina’s Executive CSR Steering Committee, chaired by the Chief Financial Officer (CFO)… [which] provide[s] guidance on strategic plans, and review[s] progress on a quarterly basis.” This named body and the Board therefore give a clear point of oversight for policy engagement. Illumina also notes that “These organizations help ensure our engagement activities are consistent with our overall climate change strategy” and confirms a commitment to conduct engagement “in line with the goals of the Paris Agreement,” indicating the presence of an alignment policy. For indirect lobbying, the company commits to transparency, stating that “Illumina will publicly disclose in its annual…Report (i) each trade association to which it has paid dues…[and] (ii)…the portion of such payments that is non-deductible,” but it does not describe any process for assessing or addressing misalignment between those associations’ climate positions and its own. No evidence was found of a formal climate-lobbying audit, criteria for evaluating trade-association stances, or actions to correct or exit misaligned bodies. Overall, Illumina shows board-level and senior-management oversight and a stated intent to align engagement with climate strategy, yet it does not disclose detailed monitoring mechanisms or active alignment measures for either direct or indirect lobbying, which limits the strength of its governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Illumina Inc offers only limited insight into its climate-related lobbying. It acknowledges that it seeks to influence policy indirectly through industry bodies, stating that “Illumina participates in various trade associations for collaboration and exchange of ideas,” and lists the US Chamber of Commerce and the California Chamber of Commerce as the channels it funds. Beyond noting this indirect mechanism, however, the company does not describe concrete activities such as meetings, submissions, or correspondence, nor does it identify any specific government officials or agencies it targets. On substance, Illumina does not name any particular bills, regulations or rule-makings it has tried to shape; it merely refers in broad terms to supporting the advancement of “energy policies in California” and aligning with international frameworks like the Paris Agreement. Likewise, the outcomes it seeks remain aspirational—“We endorse the use of scientific consensus and science-based targets to address carbon emissions reduction efforts to keep global warming to 1.5 °C above pre-industrial levels”—without spelling out what legislative changes or regulatory thresholds it is advocating. As a result, the disclosure provides only a general picture of intent and partnership but little concrete detail on the policies, methods or policy results Illumina is pursuing.	D