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QUALCOMM integrates climate and ESG oversight into its corporate responsibility framework, stating that "Everyone is responsible for Corporate Responsibility at Qualcomm" and that "Our governance structure exists to facilitate accountability, transparency and the ongoing improvement of our programs." It notes that "The Governance Committee of the Board provides oversight on corporate responsibility matters, including ESG topics," and that "our sustainability team … sits within government affairs to ensure collaboration with our engagement activities." Qualcomm also confirms "Yes" when asked if it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." While these disclosures show that climate-related engagement is embedded in its overall governance and overseen by its Board and senior leadership, the company does not disclose any dedicated policy or process for reviewing or monitoring its lobbying activities, does not describe mechanisms for aligning direct or indirect lobbying with its climate strategy, and does not name any individual or formal body specifically charged with lobbying governance.
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Qualcomm offers only limited insight into its climate-related lobbying. It does name two pieces of U.S. legislation it has tried to influence—the “Build Back Better” package and the “Infrastructure Bill”—and therefore provides some specificity about the policy areas it engages on. Beyond these titles, however, the company generally refers to broad themes such as energy-efficiency standards for data centres, smart-city infrastructure and work through the EU Trade & Technology Council without identifying the underlying bills or regulations. The description of how it engages is similarly high-level: Qualcomm notes that it “advocated in support of legislation” and participates in trade bodies such as the Business Council for Sustainable Energy, the Information Technology Industry Council, the Responsible Business Alliance and the Semiconductor Climate Consortium, but it does not spell out concrete mechanisms (e.g., meetings, letters, testimony) or name the government agencies, legislators or jurisdictions that were approached. On objectives, the company states that it seeks to “promote the deployment of intelligent edge and energy-efficient technologies, like CV-2X and 5G across the United States,” yet it offers no measurable targets, timelines or detailed policy changes it wants enacted, and other references to grid decarbonisation or energy-efficient data centres remain general aspirations. Taken together, the disclosures acknowledge some climate-policy lobbying but lack the depth and precision needed to demonstrate robust transparency on the policies, channels and outcomes of that advocacy.
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