Vertex Pharmaceuticals Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Vertex Pharmaceuticals provides only limited insight into how it governs climate-related lobbying and policy engagement. In response to a CDP question about ensuring that "engagement activities are consistent with your overall climate change strategy," the company says it "will collaborate with industry leaders to determine best practices for meeting local and global needs" and notes that "an internal Sustainability Committee oversees and implements Vertex’s global environmental programs." While this identifies a formal body with some responsibility for overseeing climate-related engagement, the disclosure offers no detail on how the committee reviews, approves or monitors direct lobbying positions, trade-association memberships or advocacy outcomes. The company simply lists its participation in groups such as "the Massachusetts Competitive Partnership" and "Climate Ready Boston" without describing any process for assessing whether these organizations’ policy positions align with Vertex’s own climate strategy. Moreover, Vertex states that it has "No" public commitment "to conduct your engagement activities in line with the goals of the Paris Agreement," underscoring the absence of a defined alignment framework. We found no evidence of regular audits, escalation procedures, corrective actions, or board-level oversight of lobbying, indicating that the company discloses only a basic oversight structure and lacks a transparent, systematic governance process for climate lobbying. View Sources	D

Overall Assessment

Analysis

Score

Limited

Vertex Pharmaceuticals provides only limited insight into how it governs climate-related lobbying and policy engagement. In response to a CDP question about ensuring that "engagement activities are consistent with your overall climate change strategy," the company says it "will collaborate with industry leaders to determine best practices for meeting local and global needs" and notes that "an internal Sustainability Committee oversees and implements Vertex’s global environmental programs." While this identifies a formal body with some responsibility for overseeing climate-related engagement, the disclosure offers no detail on how the committee reviews, approves or monitors direct lobbying positions, trade-association memberships or advocacy outcomes. The company simply lists its participation in groups such as "the Massachusetts Competitive Partnership" and "Climate Ready Boston" without describing any process for assessing whether these organizations’ policy positions align with Vertex’s own climate strategy. Moreover, Vertex states that it has "No" public commitment "to conduct your engagement activities in line with the goals of the Paris Agreement," underscoring the absence of a defined alignment framework. We found no evidence of regular audits, escalation procedures, corrective actions, or board-level oversight of lobbying, indicating that the company discloses only a basic oversight structure and lacks a transparent, systematic governance process for climate lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Vertex Pharmaceuticals provides a moderate level of transparency around its climate-related lobbying. It identifies two concrete policy engagements: support for the “Massachusetts Governor’s proposal to raise the tax rate on real estate transfers in order to pay for infrastructure to address climate change” and involvement in Boston-level “adaptation measures against rising sea levels,” giving reasonable clarity on the policy areas and jurisdictions it tries to influence. The company also explains how it engages, noting that “Vertex's Executive Chairman is on The Trustees’ Boston Waterfront Initiative CEO Roundtable” and that “Vertex’s CEO is part of a coalition that supports Boston’s mayor,” thereby describing two distinct mechanisms—participation in a task-force style roundtable and a business coalition—and naming specific targets such as the Boston mayor and state leadership. Finally, the disclosures outline the intended outcomes: raising dedicated funding for climate infrastructure, “crafting innovative greenspace solutions as well as advocating for open space and financing,” and “protecting Boston Harbor and vulnerable infrastructure.” While the company does not list a broader range of policies or provide quantitative targets, it still offers clear insight into the policies it backs, the channels it uses, and the results it seeks.	C