Lam Research Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Lam Research Corp demonstrates a moderate level of governance in its lobbying activities, particularly in the oversight of political activities. The company states that its nominating and governance committee has expanded its role to include oversight of political activities, with responsibilities such as ensuring alignment with company policy, reviewing the policy regarding political activities and spending annually, and reviewing payments to trade associations and other third parties that may be used for political purposes. Additionally, the Vice President of Global Government Affairs leads political activities and reports to the nominating and governance committee at least annually, which indicates a defined oversight structure. However, while Lam Research participates in industry associations like SEMI and has been a founding member of SEMI’s Semiconductor Climate Consortium to address climate-related issues, there is no explicit evidence of a process to align lobbying activities directly with climate commitments or the goals of the Paris Agreement. The company does not disclose a public commitment to conduct engagement activities in line with the Paris Agreement and does not plan to have one in the next two years. Furthermore, while the governance framework mentions oversight of political activities, it does not provide detailed mechanisms for monitoring or managing alignment of lobbying activities with climate-related goals, nor does it describe actions taken to address misalignment in indirect lobbying through trade associations. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Lam Research Corp demonstrates a moderate level of governance in its lobbying activities, particularly in the oversight of political activities. The company states that its nominating and governance committee has expanded its role to include oversight of political activities, with responsibilities such as ensuring alignment with company policy, reviewing the policy regarding political activities and spending annually, and reviewing payments to trade associations and other third parties that may be used for political purposes. Additionally, the Vice President of Global Government Affairs leads political activities and reports to the nominating and governance committee at least annually, which indicates a defined oversight structure. However, while Lam Research participates in industry associations like SEMI and has been a founding member of SEMI’s Semiconductor Climate Consortium to address climate-related issues, there is no explicit evidence of a process to align lobbying activities directly with climate commitments or the goals of the Paris Agreement. The company does not disclose a public commitment to conduct engagement activities in line with the Paris Agreement and does not plan to have one in the next two years. Furthermore, while the governance framework mentions oversight of political activities, it does not provide detailed mechanisms for monitoring or managing alignment of lobbying activities with climate-related goals, nor does it describe actions taken to address misalignment in indirect lobbying through trade associations.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Lam Research provides a reasonable level of transparency about its climate-related lobbying. It identifies the forums where it engages – its Global Trade and Government Affairs team works directly with the U.S. Congress, the executive branch and other regulators, the chief executive has testified before the Senate Committee on Commerce, Science and Transportation, the company participates in the Semiconductor Climate Consortium, and it operates its own political action committee, LAMPAC – giving a clear picture of the mechanisms it uses and the specific public-sector bodies it targets. The company also sets out the broad outcomes it is pursuing, such as measures that would “leverage existing infrastructure”, “enable shared innovation” and promote an “all-of-ecosystem” approach to strengthen U.S. semiconductor competitiveness, as well as developing industry-wide sustainability standards through the consortium. However, its disclosures stop short of naming the particular climate-related bills or regulations it seeks to influence, instead referring only to general themes like climate action within the semiconductor industry. This limits the precision with which external readers can connect its lobbying to specific pieces of legislation even though the company is open about how and why it engages.	2