Digital Realty Trust Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Digital Realty Trust provides a high level of visibility into its climate-policy engagement. It explicitly names multiple regulations it has worked on, including the proposed SEC Climate Change disclosure rule in the United States, the EU Corporate Sustainability Reporting Directive, the EU Energy Efficiency Directive, and the EU Emissions Trading Scheme, as well as its participation in the EU Climate Neutral Data Centre Pact, allowing readers to see exactly which climate measures it seeks to influence. The company also explains how it lobbies and whom it approaches: it undertakes "regular dialogue, filings, permitting, and hearings" with government regulators and channels further advocacy through the National Association of Real Estate Investment Trusts, the Clean Energy Buyers Association, and the EU Data Centre Association, where it joins working groups that prepare formal responses to draft regulations aimed at EU policymakers. On outcomes, the company discloses clear positions for several policies—supporting the SEC rule "with minor exceptions" focused on Scope 3 reporting, endorsing the CSRD "without exceptions," and stating support for the Energy Efficiency Directive and the EU-ETS while confirming all positions are "aligned with the Paris Agreement." Although it does not always spell out the precise amendments it seeks for every file, its declared stances and rationale on at least two major proposals give a solid picture of the results it is pursuing. Collectively, these disclosures demonstrate strong transparency across the key dimensions of policy focus, engagement methods, and desired outcomes.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Digital Realty Trust outlines a process to assess alignment of its indirect lobbying activities, stating that "we review the policy positions of groups we participate in to assess alignment with our own goals and priorities, including those related to energy, sustainability, and climate change," and that "value and alignment are assessed annually at the time of membership renewal." It also notes that it "seeks to actively review and support the creation of work products from these groups that support our positions" and engages through co-chairing and participating in committees, such as being "active participants on their Real Estate Sustainability Committee (RESC), including co-chairing past forums, and participating on their RESC executive committee." However, the company does not disclose any governance mechanism for its direct lobbying, names no individual or formal body responsible for overseeing lobbying alignment, and provides no details of ongoing monitoring beyond annual membership reviews. This indicates moderate governance around indirect climate lobbying through associations but limited transparency on direct lobbying oversight and accountability structures.	2