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Broadcom states that it “participates in the political process through engagement with government officials and policy-makers” and “engages with officials, key thought leaders and organizations to advocate for responsible policies that support the development of leading edge technology,” while noting that “trade associations of which Broadcom is a member ... may engage indirectly on policy ... that may impact the climate.” However, the company replies “No, and we do not plan to have one in the next two years” when asked if it has a public commitment to align its engagement with the goals of the Paris Agreement and does not disclose any specific governance processes—such as oversight bodies, named individuals, review or monitoring mechanisms—to ensure its direct or indirect lobbying aligns with its climate change strategy. We found no evidence of any policy or procedure for reviewing or managing climate-related lobbying activities, indicating an absence of transparency and accountability measures for its policy advocacy.
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