Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Moderate |
Western Digital discloses a basic governance mechanism linking policy advocacy to its climate strategy, stating that "Potential support of any policy initiative would need to be presented to the appropriate senior executives, legal and government affairs staff for discussion" and that "Decisions on matters such as these will take into consideration degree of alignment between the proposed initiative and Western Digital’s overall sustainability and climate change strategies." This demonstrates that lobbying proposals undergo an internal review process led by senior executives and the Legal/Government Affairs team, indicating oversight and an explicit step to align direct engagement with the company’s climate-related objectives, which suggests moderate governance. However, the disclosure remains high-level: it does not specify the frequency or criteria of these reviews, names no individual or board-level committee formally accountable, and provides no information on how indirect lobbying via trade associations is monitored or corrected. The company also notes that it has “No” public commitment to conduct engagement in line with the Paris Agreement “and we do not plan to have one in the next two years,” signalling a gap in its climate-specific lobbying framework. Overall, while the described sign-off procedure indicates some alignment controls, the absence of detailed monitoring, public reporting, or coverage of indirect lobbying shows that Western Digital’s lobbying governance is only partially developed.
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