Vertiv Holdings Co

Vertiv discloses governance over its lobbying through its Code of Conduct, which "prohibits the use of corporate funds for political contributions and describes the nature of our lobbying activities," and assigns oversight to Vertiv's "Chief Legal Officer and Global Compliance Officer," who "report to the Audit Committee of the Board regarding the company's performance on business ethics risks and performance on a quarterly basis," with the "Board of Directors review[ing] the company's ethics program and policies annually." However, the company does not disclose any process for ensuring that its direct or indirect lobbying aligns with its climate commitments, nor does it outline any procedures for monitoring or managing climate-related advocacy through trade associations, and we found no evidence of a climate lobbying alignment policy or third-party review of its lobbying activities.