Coherent Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Coherent Corp’s lobbying governance is centered on its Chief Sustainability Officer, who “is responsible for ESG and climate action, and also for Risk Management, Mergers and Acquisition, and Government Affairs” and therefore “would be aware of any action to influence policy, regulation, or law related to climate action, and ensure consistency with our climate commitments and transition plan.” This assignment of oversight to a named executive indicates a mechanism for reviewing lobbying alignment, but the company does not disclose any formal policy or detailed process for monitoring or managing its direct or indirect lobbying activities, and we found no evidence of criteria for assessing or aligning trade association engagement with climate goals. Furthermore, Coherent Corp explicitly states it “does not plan to have” a public commitment to align its engagement activities with the goals of the Paris Agreement, indicating that structured alignment measures are not in place. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Coherent Corp’s lobbying governance is centered on its Chief Sustainability Officer, who “is responsible for ESG and climate action, and also for Risk Management, Mergers and Acquisition, and Government Affairs” and therefore “would be aware of any action to influence policy, regulation, or law related to climate action, and ensure consistency with our climate commitments and transition plan.” This assignment of oversight to a named executive indicates a mechanism for reviewing lobbying alignment, but the company does not disclose any formal policy or detailed process for monitoring or managing its direct or indirect lobbying activities, and we found no evidence of criteria for assessing or aligning trade association engagement with climate goals. Furthermore, Coherent Corp explicitly states it “does not plan to have” a public commitment to align its engagement activities with the goals of the Paris Agreement, indicating that structured alignment measures are not in place.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Coherent Corp is highly transparent about its position on climate-related lobbying. The company states unambiguously that it undertakes no lobbying that could “directly or indirectly influence policy, law, or regulation that may impact the climate,” adding, “We do not believe Coherent has sufficient influence to have a meaningful impact on policy, regulation, or law on climate action.” By explaining its rationale for non-engagement and assigning responsibility for oversight to its Chief Sustainability Officer, it fully discloses its stance on policies lobbied, the mechanisms it would otherwise use, and the outcomes it might seek. Although the firm notes general interaction with officials on the CHIPS and Science Act, it makes clear that these conversations are not climate-related. This level of clarity demonstrates comprehensive transparency across all three dimensions of climate-policy lobbying disclosure.	4