Xerox Holdings Corp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong Xerox has provided detailed disclosures on its climate-related lobbying, outlining multiple direct engagement methods and identifying the specific policymakers targeted. It reports having "engaged NY state and congressional legislators that represent areas of major Xerox operations" and collaborating with the US Environmental Protection Agency through consultation responses and service as a technical advisor on versions 3.1 and 3.2 of the ENERGY STAR eco-label specification for imaging equipment. On policy disclosure, Xerox names two principal measures: the ENERGY STAR Imaging Equipment Standard—contributing definitions for remanufactured products and the new Professional Equipment category—and the US SEC’s 2022 proposed climate rule for financial reporting. It also articulates clear outcomes it seeks, including advocating specific product-category requirements under ENERGY STAR and supporting the SEC rule on the basis that "an adopted rule must be technically achievable." This level of detail demonstrates strong transparency around both its lobbying mechanisms and the outcomes it aims to achieve. 3
Lobbying Governance
Overall Assessment Comment Score
Strong Xerox’s climate lobbying governance is anchored in its Office of Global Government Affairs, which “coordinates and oversees all policy-based interactions with governments” and “is responsible for undertaking comprehensive annual reviews of our environmental partnerships to ensure alignment of Xerox's environmental priorities.” This formal body also has “the exclusive authority to express the Xerox position on matters of public policy, including climate change,” ensuring the company “speaks with one voice” in these engagements. In addition, the Office of Global Government Affairs is charged with “tracking external developments including climate change policy and determining if they are likely to affect Xerox products and operations” and, through trade associations and partnerships, “tracks applicable climate change legislation and policy that may affect the company.” While this framework indicates strong governance of both direct engagements and indirect representation, the company does not disclose a specific process for addressing or exiting associations whose positions diverge from its climate priorities, nor a dedicated board-level sign-off mechanism on climate lobbying plans. 3