International Business Machines Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	IBM has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named specific climate policies it has engaged with, such as its founding membership in the Climate Leadership Council and support for its bipartisan plan for an economy-wide carbon tax, which includes a $40/ton fee on carbon dioxide emissions, increasing annually by 5% above inflation. IBM has also actively supported energy efficiency requirements for ICT products under programs like the US EPA ENERGY STAR and by governments including the European Union and China. Additionally, IBM advocates for increased corporate access to renewables and improvements in grid technology to integrate distributed generation, specifically wind and solar systems. IBM has disclosed its lobbying mechanisms and targets, including direct participation in discussions with members of the U.S. Senate and House of Representatives as part of its involvement with the Climate Leadership Council. The company has also committed human resources and technical expertise to provide test data, analyses, and recommendations to entities such as the US EPA, the EU Commission, and the China National Institute of Standardization. Furthermore, IBM conducts advocacy both as an individual company and through industry associations globally, such as the Gridwise Alliance and the Clean Energy Buyers Alliance. IBM has been transparent about the specific outcomes it seeks, advocating for "a responsible plan to tax carbon emissions" and endorsing the Climate Leadership Council's proposal for an economy-wide carbon tax. The company outlines the desired impact of this policy, including "strong economic incentives for energy companies to reduce carbon emissions and for energy consumers to reduce their own energy consumption." IBM also seeks effective energy efficiency requirements for ICT products, increased corporate access to renewables, and improvements in grid technology to facilitate the integration of distributed generation. These disclosures clearly outline the policy changes and outcomes IBM aims to achieve, reflecting a high level of transparency.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	IBM demonstrates a strong governance process for climate lobbying alignment, as evidenced by its clear accountability and oversight mechanisms. The company states that "IBM's Corporate Environmental Affairs staff organization is responsible for developing IBM environmental public policy positions including those addressing climate protection and advocating the company's positions on public policies related to climate change," indicating defined roles and responsibilities. Furthermore, IBM ensures alignment by requiring that "all direct and indirect activities that could be considered to influence environmental policy externally must be approved by Corporate Environmental Affairs staff and Government and Regulatory Affairs staff, ensuring consistency with the company's own position on climate change and commitment to environmental leadership." This reflects a robust monitoring and management process for lobbying activities. Additionally, the evidence highlights that these roles and responsibilities are "clearly and explicitly defined" and documented in IBM's global Environmental Management System, further supporting the structured and comprehensive nature of its governance framework. This indicates strong governance with defined oversight and monitoring mechanisms for climate lobbying alignment.	3