Climate Lobbying Index

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Seagate Technology Holdings PLC provides limited disclosure regarding its lobbying governance processes, particularly in relation to climate lobbying. The company states that "Seagate may actively engage in legislative and regulatory processes, including advocacy for certain policies that the company believes will facilitate productive economic growth," and acknowledges participation in trade associations that may engage in public policy advocacy. However, it also clarifies that "Seagate’s payments to, participation in, or membership with these trade associations and organizations does not mean that Seagate endorses or agrees with all of a group’s policy objectives." While this indicates some awareness of potential misalignment, there is no evidence of a structured process to monitor or manage such alignment. The company mentions that its CEO has direct responsibility for its broader Global Citizenship program, which includes climate change strategy, but there is no explicit mention of oversight or governance mechanisms specifically for lobbying activities. Additionally, while Seagate participates in forums and collaborations such as the Responsible Business Alliance and the United Nations Global Compact, these engagements are described in the context of broader sustainability goals rather than specific lobbying governance. The company does not disclose any policy or process to ensure alignment of its lobbying activities with its climate strategy, nor does it identify any individual or committee responsible for reviewing or overseeing lobbying alignment. Furthermore, Seagate explicitly states that it does not have a public commitment to align its engagement activities with the goals of the Paris Agreement and does not plan to adopt one in the next two years. Overall, the disclosures lack detail on governance structures, monitoring mechanisms, or accountability measures for lobbying activities, particularly in the context of climate-related advocacy. View Sources	1

Overall Assessment

Analysis

Score

Limited

Seagate Technology Holdings PLC provides limited disclosure regarding its lobbying governance processes, particularly in relation to climate lobbying. The company states that "Seagate may actively engage in legislative and regulatory processes, including advocacy for certain policies that the company believes will facilitate productive economic growth," and acknowledges participation in trade associations that may engage in public policy advocacy. However, it also clarifies that "Seagate’s payments to, participation in, or membership with these trade associations and organizations does not mean that Seagate endorses or agrees with all of a group’s policy objectives." While this indicates some awareness of potential misalignment, there is no evidence of a structured process to monitor or manage such alignment. The company mentions that its CEO has direct responsibility for its broader Global Citizenship program, which includes climate change strategy, but there is no explicit mention of oversight or governance mechanisms specifically for lobbying activities. Additionally, while Seagate participates in forums and collaborations such as the Responsible Business Alliance and the United Nations Global Compact, these engagements are described in the context of broader sustainability goals rather than specific lobbying governance. The company does not disclose any policy or process to ensure alignment of its lobbying activities with its climate strategy, nor does it identify any individual or committee responsible for reviewing or overseeing lobbying alignment. Furthermore, Seagate explicitly states that it does not have a public commitment to align its engagement activities with the goals of the Paris Agreement and does not plan to adopt one in the next two years. Overall, the disclosures lack detail on governance structures, monitoring mechanisms, or accountability measures for lobbying activities, particularly in the context of climate-related advocacy.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Seagate Technology Holdings PLC offers only limited insight into its climate-related lobbying. The company indicates that it works “through trade associations, particularly the Responsible Business Alliance (RBA)” and that “Seagate may actively engage in legislative and regulatory processes,” but it does not identify which government bodies, legislators, or jurisdictions are approached, nor does it describe concrete actions such as meetings, letters, or submissions. Likewise, while it acknowledges that the revised RBA Code includes greenhouse-gas requirements, it does not cite any specific climate law, regulation, or bill that it has sought to influence, leaving readers unable to link the company’s advocacy to identifiable public-policy proposals. Finally, beyond the broad aspiration to support “policies that … facilitate productive economic growth” and internal targets to cut its own emissions, Seagate offers no description of the policy changes or legislative outcomes it is seeking. Overall, the disclosure signals that some engagement may be occurring but provides little substantive detail on the policies, mechanisms, or outcomes involved.	1

Seagate Technology Holdings PLC

Lobbying Transparency and Governance