Xerox Holdings Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Xerox discloses a defined internal structure for managing how the company engages on public-policy issues that include climate change: the company states that its "Office of Global Government Affairs coordinates and oversees all policy-based interactions with governments and governmental organizations" and "has the exclusive authority to express the Xerox position on matters of public policy, including climate change," thereby creating a clear gate-keeper for direct lobbying activities. The same office is said to conduct "comprehensive annual reviews of our environmental partnerships to ensure alignment of Xerox's environmental priorities" and, by "restricting such communications to the Office of Global Government Affairs, Xerox ensures that the company speaks with one voice on matters of climate related public policy," indicating a concrete process intended to align lobbying messages with overall climate strategy. Governance responsibility is further escalated through the CSR Council, which "reports to and advises the CEO," is chaired by an Executive Committee member, and is led by the Chief Sustainability Officer who "is responsible for overseeing our environmental (including climate related) governance" and communicates outcomes to the Board; this demonstrates that senior management and board-level structures review and approve climate-related advocacy priorities. It describes oversight of direct lobbying and the tracking of policy developments"the Office of Global Government Affairs is also responsible for tracking external developments including climate change policy". And though it has disclosed about one trade association, its lobbying and alignment (Information Technology Industry Council (ITI), it has not dislcosed a systematic process for assessing whether the lobbying positions of trade associations or other indirect channels align with Xeroxs climate goals, nor published an external lobbying-alignment review. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Xerox discloses a defined internal structure for managing how the company engages on public-policy issues that include climate change: the company states that its "Office of Global Government Affairs coordinates and oversees all policy-based interactions with governments and governmental organizations" and "has the exclusive authority to express the Xerox position on matters of public policy, including climate change," thereby creating a clear gate-keeper for direct lobbying activities. The same office is said to conduct "comprehensive annual reviews of our environmental partnerships to ensure alignment of Xerox's environmental priorities" and, by "restricting such communications to the Office of Global Government Affairs, Xerox ensures that the company speaks with one voice on matters of climate related public policy," indicating a concrete process intended to align lobbying messages with overall climate strategy. Governance responsibility is further escalated through the CSR Council, which "reports to and advises the CEO," is chaired by an Executive Committee member, and is led by the Chief Sustainability Officer who "is responsible for overseeing our environmental (including climate related) governance" and communicates outcomes to the Board; this demonstrates that senior management and board-level structures review and approve climate-related advocacy priorities. It describes oversight of direct lobbying and the tracking of policy developments"the Office of Global Government Affairs is also responsible for tracking external developments including climate change policy". And though it has disclosed about one trade association, its lobbying and alignment (Information Technology Industry Council (ITI), it has not dislcosed a systematic process for assessing whether the lobbying positions of trade associations or other indirect channels align with Xeroxs climate goals, nor published an external lobbying-alignment review.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Xerox has provided detailed disclosures on its climate-related lobbying, outlining multiple direct engagement methods and identifying the specific policymakers targeted. It reports having "engaged NY state and congressional legislators that represent areas of major Xerox operations" and collaborating with the US Environmental Protection Agency through consultation responses and service as a technical advisor on versions 3.1 and 3.2 of the ENERGY STAR eco-label specification for imaging equipment. On policy disclosure, Xerox names two principal measures: the ENERGY STAR Imaging Equipment Standard—contributing definitions for remanufactured products and the new Professional Equipment category—and the US SEC’s 2022 proposed climate rule for financial reporting. It also articulates clear outcomes it seeks, including advocating specific product-category requirements under ENERGY STAR and supporting the SEC rule on the basis that "an adopted rule must be technically achievable." This level of detail demonstrates strong transparency around both its lobbying mechanisms and the outcomes it aims to achieve.	3