Medtronic PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Medtronic has established formal review structures for its political contributions, where "the Medtronic PAC … governed by a Board of Directors comprised of employees and executives of Medtronic" and "all corporate contribution recommendations" are subject to approval by a "three-member Corporate Political Fund Committee to include the Chief Financial Officer, the General Counsel and the Vice President of Government Affairs," and the Board’s Nominating and Corporate Governance Committee "reviews corporate political contributions" on an annual basis, with semiannual disclosure of "all political contributions made by Medtronic and the Medtronic PAC." On the climate front, the company asserts that "before engagement with other organizations, we examine alignment with our own Decarbonization Roadmap" and affirms a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." However, we found no evidence of a dedicated governance process for its direct lobbying activities or ongoing monitoring protocols specifically for climate lobbying, nor does Medtronic publish a standalone climate-lobbying alignment report or name clear oversight responsibilities for climate lobbying beyond its existing contribution committees. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Medtronic has established formal review structures for its political contributions, where "the Medtronic PAC … governed by a Board of Directors comprised of employees and executives of Medtronic" and "all corporate contribution recommendations" are subject to approval by a "three-member Corporate Political Fund Committee to include the Chief Financial Officer, the General Counsel and the Vice President of Government Affairs," and the Board’s Nominating and Corporate Governance Committee "reviews corporate political contributions" on an annual basis, with semiannual disclosure of "all political contributions made by Medtronic and the Medtronic PAC." On the climate front, the company asserts that "before engagement with other organizations, we examine alignment with our own Decarbonization Roadmap" and affirms a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." However, we found no evidence of a dedicated governance process for its direct lobbying activities or ongoing monitoring protocols specifically for climate lobbying, nor does Medtronic publish a standalone climate-lobbying alignment report or name clear oversight responsibilities for climate lobbying beyond its existing contribution committees.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E