ServiceNow Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	ServiceNow describes an extensive ESG governance process, noting that “our engagement and climate change strategy are consistent with each other” through regular reporting of “progress, metrics, and targets” by multiple oversight bodies including the “ESG Steering Committee, Nominating and Governance Committee, [and] Audit Committee,” and that these are tracked in an “ESG Management tool with audit trails and documentation.” It explains that “the Nominating and Governance Committee oversees and reviews with management our major ESG activities and programs” and that the “ESG Steering Committee, chaired by the CFO, is responsible for overseeing the management of climate-related risks and opportunities.” However, we found no evidence of any specific policy, process, or named individual responsible for overseeing or aligning direct or indirect lobbying activities with ServiceNow’s climate goals, nor any description of how lobbying engagement is monitored or managed. View Sources	0

Overall Assessment

Analysis

Score

None

ServiceNow describes an extensive ESG governance process, noting that “our engagement and climate change strategy are consistent with each other” through regular reporting of “progress, metrics, and targets” by multiple oversight bodies including the “ESG Steering Committee, Nominating and Governance Committee, [and] Audit Committee,” and that these are tracked in an “ESG Management tool with audit trails and documentation.” It explains that “the Nominating and Governance Committee oversees and reviews with management our major ESG activities and programs” and that the “ESG Steering Committee, chaired by the CFO, is responsible for overseeing the management of climate-related risks and opportunities.” However, we found no evidence of any specific policy, process, or named individual responsible for overseeing or aligning direct or indirect lobbying activities with ServiceNow’s climate goals, nor any description of how lobbying engagement is monitored or managed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	0