DXC Technology Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	DXC Technology Co. describes structured processes to align its external engagement with its climate strategy, including membership in climate-focused trade bodies such as “the UK Climate Change Agreement,” techUK and the DEFRA Government Digital Sustainability Alliance, and involvement in techUK working groups on “Net Zero Tech” and “Green Finance,” but it does not disclose a formal lobbying governance framework detailing how it manages either direct or indirect lobbying beyond these memberships and reviews. The company states that its “process for aligning engagement activities with strategy involves regular communications between the ESG Executive Steering Committee and other executive leaders,” and that “Any public submissions released by DXC are reviewed by our COO, who is responsible for DXC’s ESG strategy and response to climate related issues; our Corporate Communications and Marketing specialists; as well as Investor Relations specialists, for alignment with DXC’s overall ESG strategy.” Meetings to review progress are “held quarterly with the Board of Directors and ESG Executive Steering Committee, as well as monthly with responsible executives,” indicating oversight and named responsibility, but DXC does not disclose a policy for monitoring or managing lobbying activities through trade associations or a process for enforcing consistency with its climate commitments in its lobbying relationships, and we found no evidence of an independent audit or exit strategy for associations whose positions conflict with DXC’s climate objectives. View Sources	2

Overall Assessment

Analysis

Score

Moderate

DXC Technology Co. describes structured processes to align its external engagement with its climate strategy, including membership in climate-focused trade bodies such as “the UK Climate Change Agreement,” techUK and the DEFRA Government Digital Sustainability Alliance, and involvement in techUK working groups on “Net Zero Tech” and “Green Finance,” but it does not disclose a formal lobbying governance framework detailing how it manages either direct or indirect lobbying beyond these memberships and reviews. The company states that its “process for aligning engagement activities with strategy involves regular communications between the ESG Executive Steering Committee and other executive leaders,” and that “Any public submissions released by DXC are reviewed by our COO, who is responsible for DXC’s ESG strategy and response to climate related issues; our Corporate Communications and Marketing specialists; as well as Investor Relations specialists, for alignment with DXC’s overall ESG strategy.” Meetings to review progress are “held quarterly with the Board of Directors and ESG Executive Steering Committee, as well as monthly with responsible executives,” indicating oversight and named responsibility, but DXC does not disclose a policy for monitoring or managing lobbying activities through trade associations or a process for enforcing consistency with its climate commitments in its lobbying relationships, and we found no evidence of an independent audit or exit strategy for associations whose positions conflict with DXC’s climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	DXC Technology discloses extensive information on every aspect of its climate-policy engagement, demonstrating a high level of transparency. It identifies multiple specific policies it has worked on, including the UK Climate Change Agreement, the “Net Zero Strategy: Build Back Greener,” the UK Green Finance Strategy, the review of “Better Energy Efficiency Tax Reform,” and related sustainable-finance regulations, clearly situating each within its UK or EU jurisdiction. The company also explains how it lobbies and who it targets: it meets directly with government officials, participates in the techUK Net Zero Tech working group, presents proposals to the European Central Bank and the Central Bank of Ireland, and contributes funding and expertise through bodies such as SustainableIT.org and the Green Software Foundation. Finally, DXC sets out the concrete outcomes it seeks, such as “maintaining existing energy-efficiency targets,” “establishment of longer-term targets to ensure time for businesses to actively prepare,” creation of a regulatory reporting “sandbox mechanism” to smooth the introduction of sustainable-finance rules, and lowering administrative burdens while preserving enforcement incentives—measures it links to achieving the UK’s net-zero goal and alignment with the Paris Agreement. Together, these disclosures provide clear visibility into the policies addressed, the methods and forums used, and the specific regulatory changes the company is pursuing.	4