NVIDIA Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	NVIDIA has established a formal review process for its climate-related lobbying, based on internal authorization and board oversight, but it does not provide transparency on indirect lobbying or publish a dedicated climate-lobbying review. “As stated in NVIDIA’s Code of Conduct, NVIDIA only seeks to affect government action on issues that directly impact our business and only through specifically authorized and legally compliant lobbying activities,” and “Potential support of any climate change-related policy initiative would be presented to NVIDIA’s CSR Committee, including executive staff, as well as NVIDIA’s legal counsel and Government Affairs group, for discussion.” All such activities “require the prior approval of NVIDIA Government Relations and Legal,” and starting in FY22, “management began periodically reporting to the Nominating and Corporate Governance Committee … about the company’s policies and practices regarding governmental relations, public policy, and related expenditures.” While these measures indicate strong approval workflows and oversight bodies, we found no evidence of processes to align indirect or trade-association lobbying, no “publicly available report” on climate-lobbying alignment, and the company “does not plan” to commit its engagement activities to the goals of the Paris Agreement. View Sources	C

Overall Assessment

Analysis

Score

Moderate

NVIDIA has established a formal review process for its climate-related lobbying, based on internal authorization and board oversight, but it does not provide transparency on indirect lobbying or publish a dedicated climate-lobbying review. “As stated in NVIDIA’s Code of Conduct, NVIDIA only seeks to affect government action on issues that directly impact our business and only through specifically authorized and legally compliant lobbying activities,” and “Potential support of any climate change-related policy initiative would be presented to NVIDIA’s CSR Committee, including executive staff, as well as NVIDIA’s legal counsel and Government Affairs group, for discussion.” All such activities “require the prior approval of NVIDIA Government Relations and Legal,” and starting in FY22, “management began periodically reporting to the Nominating and Corporate Governance Committee … about the company’s policies and practices regarding governmental relations, public policy, and related expenditures.” While these measures indicate strong approval workflows and oversight bodies, we found no evidence of processes to align indirect or trade-association lobbying, no “publicly available report” on climate-lobbying alignment, and the company “does not plan” to commit its engagement activities to the goals of the Paris Agreement.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	NVIDIA provides clear disclosures of the specific climate-related regulations it has engaged with, naming measures such as the European Display and Server Energy Regulations and updates to the Computer Energy Regulation in both Europe and China. It also outlines how it influences these policies through multiple channels, including direct submissions to the White House, membership in bodies like the Semiconductor Industry Association, the Information Technology Industry Council, DigitalEurope, energy standard working groups in China, and participation in collaborative initiatives such as SPEC and Green Grid. Finally, the company specifies the outcomes it seeks, notably integrating active workload energy efficiency into computer energy regulations and shaping Energy Star and comparable standards in China and Japan. This combination of detailed policy identification, clearly described mechanisms, and defined outcomes demonstrates a strong level of transparency around NVIDIA’s climate lobbying activities.	B