Micron Technology Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Micron Technology has instituted a governance framework for its lobbying activities that integrates board oversight and executive accountability, though it stops short of providing a dedicated climate-lobbying alignment report or formal Paris Agreement commitment. The Board’s Governance and Sustainability Committee, “compris[ed] entirely of outside directors,” is charged with “the oversight and monitoring of the manner in which the Company conducts its public policy and government affairs activities,” and “shall review, on a semi-annual basis, reports on the Company’s political spending and lobbying activities,” while “the Executive Vice President of Global Operations ... and the Global Head of Government and Public Affairs” manage day-to-day political engagement. To align its indirect lobbying, Micron states that “on an annual basis, Government and Public Affairs analyzes the alignment and effectiveness of the external partners that Micron engages,” and it “review[s] policy and industry association stances internally with relevant sustainability and executive leadership as needed, taking into account consistency with our climate commitments.” This process indicates active governance of both direct and indirect lobbying and clear assignment of oversight, but the company does not disclose a standalone climate-lobbying audit or policy requiring that it “exit associations” whose positions conflict with its climate goals, nor does it offer a public commitment to align its engagement with the Paris Agreement. View Sources	B

Overall Assessment

Analysis

Score

Strong

Micron Technology has instituted a governance framework for its lobbying activities that integrates board oversight and executive accountability, though it stops short of providing a dedicated climate-lobbying alignment report or formal Paris Agreement commitment. The Board’s Governance and Sustainability Committee, “compris[ed] entirely of outside directors,” is charged with “the oversight and monitoring of the manner in which the Company conducts its public policy and government affairs activities,” and “shall review, on a semi-annual basis, reports on the Company’s political spending and lobbying activities,” while “the Executive Vice President of Global Operations ... and the Global Head of Government and Public Affairs” manage day-to-day political engagement. To align its indirect lobbying, Micron states that “on an annual basis, Government and Public Affairs analyzes the alignment and effectiveness of the external partners that Micron engages,” and it “review[s] policy and industry association stances internally with relevant sustainability and executive leadership as needed, taking into account consistency with our climate commitments.” This process indicates active governance of both direct and indirect lobbying and clear assignment of oversight, but the company does not disclose a standalone climate-lobbying audit or policy requiring that it “exit associations” whose positions conflict with its climate goals, nor does it offer a public commitment to align its engagement with the Paris Agreement.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Micron Technology provides a fairly detailed picture of its climate-policy lobbying. It names identifiable measures it has engaged on, including Malaysia’s “Green Electricity Tariff” programme and Singapore’s “Carbon Pricing Act,” and describes collaboration with Taiwan’s Bureau of Water Resources on water-use strategies, demonstrating that the company is willing to disclose the specific initiatives it seeks to influence. The company is also open about the ways it lobbies, citing multiple approaches such as “direct and indirect lobbying,” “political contributions,” participation in trade bodies like the Semiconductor Industry Association and SEMI’s Semiconductor Climate Coalition, and direct partnerships with public authorities – for example its work with “the city of Boise to operate an advanced water treatment plant,” with “Higashi-Hiroshima City Hall” on habitat restoration, and with the Singapore government on a central abatement system. Finally, Micron sets out the outcomes it is pursuing: it backs measures that will enable “100 % renewable electricity in the U.S. by the end of 2025,” supports Malaysian incentives that created the country’s first renewable-energy manufacturing zone, and seeks policies in Taiwan that ensure sustainable local water supplies. Together these disclosures show clear policy targets, multiple, well-defined lobbying channels and concrete environmental objectives, illustrating a strong level of transparency in how the company tries to shape climate-related public policy.	B