Hewlett Packard Enterprise Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Hewlett Packard Enterprise Co (HPE) demonstrates a moderate level of governance in its lobbying activities, with some mechanisms in place to ensure alignment with its broader values and policies. The company discloses that its Senior Vice President of Corporate Affairs is responsible for political and public policy engagement, operating under the oversight of the Nominating, Governance and Social Responsibility Committee (NGSRC) of the Board of Directors, which "reviews, assesses, reports and provides guidance to HPE’s management and the full Board of Directors with respect to political activities and contributions." Additionally, HPE outlines that "employees engaged in lobbying activities receive regular training on lobbying and ethics regulations," and that external lobbyists are subject to "a thorough due diligence process" and must adhere to HPE’s Standards of Business Conduct. While these measures indicate some oversight and monitoring, the evidence does not explicitly detail how lobbying activities—both direct and indirect—are aligned with climate-related goals. Although HPE supports climate policies aligned with the Paris Agreement and principles such as carbon pricing and renewable energy, the company does not disclose a specific process or audit mechanism to ensure its lobbying activities are consistent with these climate goals. Furthermore, while the NGSRC oversees political engagement broadly, there is no indication of a dedicated review process for climate lobbying alignment or actions taken to address misalignment with trade associations or industry bodies. This suggests that while HPE has governance structures for lobbying, the transparency and specificity regarding climate lobbying governance remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Hewlett Packard Enterprise Co (HPE) demonstrates a moderate level of governance in its lobbying activities, with some mechanisms in place to ensure alignment with its broader values and policies. The company discloses that its Senior Vice President of Corporate Affairs is responsible for political and public policy engagement, operating under the oversight of the Nominating, Governance and Social Responsibility Committee (NGSRC) of the Board of Directors, which "reviews, assesses, reports and provides guidance to HPE’s management and the full Board of Directors with respect to political activities and contributions." Additionally, HPE outlines that "employees engaged in lobbying activities receive regular training on lobbying and ethics regulations," and that external lobbyists are subject to "a thorough due diligence process" and must adhere to HPE’s Standards of Business Conduct. While these measures indicate some oversight and monitoring, the evidence does not explicitly detail how lobbying activities—both direct and indirect—are aligned with climate-related goals. Although HPE supports climate policies aligned with the Paris Agreement and principles such as carbon pricing and renewable energy, the company does not disclose a specific process or audit mechanism to ensure its lobbying activities are consistent with these climate goals. Furthermore, while the NGSRC oversees political engagement broadly, there is no indication of a dedicated review process for climate lobbying alignment or actions taken to address misalignment with trade associations or industry bodies. This suggests that while HPE has governance structures for lobbying, the transparency and specificity regarding climate lobbying governance remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	HPE provides detailed disclosures across the policies it lobbies, the mechanisms it uses, and the outcomes it seeks. It names multiple specific climate policies, including its collaboration on “a new data center efficiency standard together with Switzerland’s Federal Energy Office,” its support for “US participation in the Paris Agreement” to “realize the Paris Agreement’s commitment of a global economy that limits global temperature rise to well below 2 degrees Celsius,” and its advocacy for the renewable energy buyers’ principles, highlighting areas such as “greater choice in options to procure renewable energy,” “cost competitiveness between traditional and renewable energy rates,” and “access to longer-term, fixed-price renewable energy.” The company outlines its lobbying mechanisms comprehensively—both direct and indirect—explaining that it “meets with national and European policymakers on our own behalf to share knowledge and experiences related to implementation of legal obligations and technology developments,” while also working through associations like the Green Grid Association, Digital Europe, We Mean Business Coalition, and board roles such as a founding member of REBA, targeting entities like Switzerland’s Federal Energy Office, local policymakers in Amsterdam, utilities, and regulators. Finally, HPE clearly identifies the specific outcomes it seeks, from supporting a global low-carbon economy aligned with a “1.5°C science-based target” to advocating for market reforms that expand procurement options, financing vehicles, and cost competitiveness for renewable energy. These disclosures reflect a comprehensive level of transparency around its climate lobbying activities.	A