Open Text Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Open Text Corp provides only limited insight into how it governs climate-related lobbying. The company states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement", indicating an intention that any external engagement, which could include lobbying, should be Paris-aligned. Governance responsibility for broader sustainability matters is assigned to several bodies – for example the "Corporate Governance and Nominating Committee" which has "oversight and authority to consider matters regarding sustainability and corporate citizenship" and the Chief Legal Officer who "provides general oversight responsibility with respect to matters of sustainability and corporate citizenship" – but these descriptions do not spell out how lobbying positions are reviewed, approved, or monitored. There is no disclosure of specific procedures to test the alignment of direct or trade-association lobbying, no mention of audits or corrective actions, and no identification of individuals or committees tasked explicitly with overseeing political advocacy. Consequently, while the Paris-alignment commitment and the existence of ESG oversight committees suggest some governance attention, the company does not disclose a concrete process for managing or assuring alignment of its lobbying activities with its climate goals. View Sources	D

Overall Assessment

Analysis

Score

Limited

Open Text Corp provides only limited insight into how it governs climate-related lobbying. The company states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement", indicating an intention that any external engagement, which could include lobbying, should be Paris-aligned. Governance responsibility for broader sustainability matters is assigned to several bodies – for example the "Corporate Governance and Nominating Committee" which has "oversight and authority to consider matters regarding sustainability and corporate citizenship" and the Chief Legal Officer who "provides general oversight responsibility with respect to matters of sustainability and corporate citizenship" – but these descriptions do not spell out how lobbying positions are reviewed, approved, or monitored. There is no disclosure of specific procedures to test the alignment of direct or trade-association lobbying, no mention of audits or corrective actions, and no identification of individuals or committees tasked explicitly with overseeing political advocacy. Consequently, while the Paris-alignment commitment and the existence of ESG oversight committees suggest some governance attention, the company does not disclose a concrete process for managing or assuring alignment of its lobbying activities with its climate goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E