Lenovo Group Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Lenovo discloses a defined chain of responsibility and a concrete internal process aimed at keeping its climate-related public engagement consistent with corporate policy, indicating a moderate level of lobbying-governance discipline. Oversight starts at the top: “Lenovo’s Board of Directors has the highest level of oversight for Environmental, Social and Governance (ESG) performance … At least annually, the Board of Directors is briefed on climate strategy and progress towards our climate change mitigation goals,” while the ESG Executive Oversight Committee, “comprised of senior management from across the business and functional areas,” is “chartered to promote a culture that encourages strong ESG performance, including compliance and leadership activities.” For day-to-day external engagement the company requires pre-clearance of climate-related positions: “Lenovo's corporate communications procedures require engagement of the Global Director of Environmental Affairs and the Corporate Communications team with regard to external communications/activities involving environmental issues, including climate change,” and these teams “now meet bi-weekly” and maintain “an ESG messaging house that is available across the Company to assist individuals in using accurate communication that avoids greenwashing and is in sync with Lenovo’s established policies and strategies.” Lenovo also states it has “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement,” showing an intention to align advocacy with climate objectives. However, the disclosure does not describe how lobbying positions directed at policymakers are formally reviewed, gives no information on monitoring or correcting trade-association advocacy, and provides no published audit or report assessing alignment; therefore evidence of governance for indirect lobbying and of systematic monitoring remains absent. This indicates solid but still incomplete governance of climate-related lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Lenovo discloses a defined chain of responsibility and a concrete internal process aimed at keeping its climate-related public engagement consistent with corporate policy, indicating a moderate level of lobbying-governance discipline. Oversight starts at the top: “Lenovo’s Board of Directors has the highest level of oversight for Environmental, Social and Governance (ESG) performance … At least annually, the Board of Directors is briefed on climate strategy and progress towards our climate change mitigation goals,” while the ESG Executive Oversight Committee, “comprised of senior management from across the business and functional areas,” is “chartered to promote a culture that encourages strong ESG performance, including compliance and leadership activities.” For day-to-day external engagement the company requires pre-clearance of climate-related positions: “Lenovo's corporate communications procedures require engagement of the Global Director of Environmental Affairs and the Corporate Communications team with regard to external communications/activities involving environmental issues, including climate change,” and these teams “now meet bi-weekly” and maintain “an ESG messaging house that is available across the Company to assist individuals in using accurate communication that avoids greenwashing and is in sync with Lenovo’s established policies and strategies.” Lenovo also states it has “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement,” showing an intention to align advocacy with climate objectives. However, the disclosure does not describe how lobbying positions directed at policymakers are formally reviewed, gives no information on monitoring or correcting trade-association advocacy, and provides no published audit or report assessing alignment; therefore evidence of governance for indirect lobbying and of systematic monitoring remains absent. This indicates solid but still incomplete governance of climate-related lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Lenovo provides an unusually detailed picture of its climate-related public-policy engagement. It names numerous concrete instruments it has worked on, including the Product Carbon Footprint (PCF) China Standard, the national standard GB/T 37552-2019 on life-cycle assessment, the “Minimum Allowable Values of Energy Efficiency and Energy Efficiency Grades for Servers,” revisions to the China Energy Label and China WEEE rules, ENERGY STAR® specifications that drive US DOE/CEC and EU ErP regulations, and clean-energy transportation initiatives developed with the Ministry of Communications. The company is equally explicit about how it intervenes and whom it targets. It describes acting as “main drafters” of mandatory standards, submitting “test values and suggestions to the CNIS,” holding “several industry meetings with CNIS,” collaborating through the Information Technology Industry Council with the US EPA and DOE, and working directly with bodies such as the Ministry of Industry and Information Technology, the China Electronics Standardization Institute, and the China Communications and Transportation Association. These disclosures make clear the direct, indirect, and multistakeholder channels Lenovo uses to influence policy. Lenovo also spells out the concrete outcomes it pursues. It seeks the formal adoption of the PCF China Standard and related product-category rules, supports “minimum energy efficiency requirements” for servers, data centres and other IT equipment “with no exceptions,” and aims to “enable new energy transportation generalization” by encouraging logistics partners to shift to rail and new-energy vehicles. Across these engagements the company links its goals to improving resource-use efficiency, reducing GHG emissions, and aligning with China’s 2060 carbon-neutrality target and the Paris Agreement, demonstrating a high level of transparency about its policy objectives.	A