KLA Corp

KLA Corp demonstrates a moderate level of governance in its lobbying activities, particularly in relation to climate-related efforts. The company states that its ESG and climate-related industry engagements, including participation in SEMI climate initiatives, are overseen by its ESG Global Leader and ESG Steering Committee, which drive its climate strategy and initiatives. "Our ESG steering committee receives oversight from the Nominating and Governance Committee and meets monthly to discuss ESG-related initiatives, which may include trade association engagement." This indicates a structured oversight mechanism for indirect lobbying through trade associations. Additionally, KLA monitors and reports corporate lobbying efforts, with quarterly and annual reporting by its Global Government Affairs group, and has policies requiring preapproval for any political contributions by the CFO and Legal and Compliance organization. However, while the company provides details on oversight and reporting mechanisms, it does not disclose a specific process for ensuring alignment of lobbying activities with climate goals, nor does it have a public commitment to align engagement activities with the Paris Agreement. "KLA does not engage in undisclosed political spending" and participates in trade associations such as SEMI and the Semiconductor Industry Association (SIA), but there is no evidence of actions taken to align or correct lobbying positions of these associations with its climate strategy. Furthermore, while the ESG Steering Committee and Nominating and Governance Committee provide oversight, the company does not describe a detailed monitoring or alignment process for its lobbying activities beyond general reporting and oversight structures. This indicates some governance measures but lacks comprehensive alignment mechanisms for climate lobbying.