International Business Machines Corp

International Business Machines Corporation demonstrates strong governance of its climate-related lobbying activities by embedding clear oversight within its global Environmental Management System, which "adheres to clearly and explicitly defined organizational roles and responsibilities." According to IBM, "All direct and indirect activities that could be considered to influence environmental policy externally must be approved by Corporate Environmental Affairs staff and Government and Regulatory Affairs staff," ensuring consistency with "the company's own position on climate change and commitment to environmental leadership." IBM further clarifies that its "Corporate Environmental Affairs staff organization is responsible for developing IBM environmental public policy positions including those addressing climate protection and advocating the company's positions on public policies related to climate change," while business units execute the applicable requirements. However, we found contradictory evidence regarding any public alignment with the Paris Agreement - one response states "No, and we do not plan to have one in the next two years," while another simply states "Yes" without detail - and no publicly available audit or review assessing its climate-lobbying alignment nor a single executive or board-level committee explicitly named as the ultimate overseer of these lobbying alignment procedures.