NVIDIA Corp

NVIDIA has established a formal review process for its climate-related lobbying, based on internal authorization and board oversight, but it does not provide transparency on indirect lobbying or publish a dedicated climate-lobbying review. "As stated in NVIDIA's Code of Conduct, NVIDIA only seeks to affect government action on issues that directly impact our business and only through specifically authorized and legally compliant lobbying activities," and "Potential support of any climate change-related policy initiative would be presented to NVIDIA's CSR Committee, including executive staff, as well as NVIDIA's legal counsel and Government Affairs group, for discussion." All such activities "require the prior approval of NVIDIA Government Relations and Legal," and starting in FY22, "management began periodically reporting to the Nominating and Corporate Governance Committee ... about the company's policies and practices regarding governmental relations, public policy, and related expenditures." While these measures indicate strong approval workflows and oversight bodies, we found no evidence of processes to align indirect or trade-association lobbying, no "publicly available report" on climate-lobbying alignment, and the company "does not plan" to commit its engagement activities to the goals of the Paris Agreement.