Lam Research Corp

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.