Smart Global Holdings, Inc.

Rating Overview

Smart Global Holdings, Inc. is Medium Risk.

Penguin Solutions often yields to political activism in shaping corporate governance, potentially alienating consumers, dividing employees, and harming shareholders. The company implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. Penguin Solutions occasionally embraces corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues at times. This approach fails to safeguard free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria	Risk Level
Cancellations	Medium Risk
Discriminatory Philanthropy	Lower Risk
Employment Protection	High Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	High Risk
Funding	Medium Risk
Political Actions	No Data

Corporate Governance and Public Policy ⓘ

Rating Criteria Detail

Criteria Risk Level Rationale

Corporate Weaponization

Criteria:

Has canceled customers, suppliers, or vendors due to their political views or religious beliefs OR corporately boycotts, divests, or sanctions regions, people groups, or industries.

Risk Level:

Medium

Rationale:

Penguin Solutions integrates ESG into its business practices. From its 2025 Proxy Report: “Ten percent of each executive’s target bonus is subject to performance on predetermined, measurable ESG goals related to human capital and environmental stewardship” (1). The company integrates DEI into its supply chain. From its Human and Workforce Labor Rights policy: “Penguin requires suppliers to adhere to its Supplier Code of Conduct (the “Supplier Code”), along with relevant terms and conditions. The Supplier Code sets out requirements related to ethics and integrity, labor and employment practices, protecting human rights, sustainability, health and safety, and diversity and inclusion, among other key provisions” (2). Penguin Solutions promotes divisive sex and gender policies. Its Supplier Code of Conduct requires international vendors to include sexual orientation and gender identity in their nondiscrimination policy (3)(4). However, the company has not publicly canceled customers, suppliers, or vendors based on political views or religious beliefs (5).

Criteria:

Charitable giving (including employee matching programs) policies or practices discriminate against charitable organizations based on views or religious beliefs.

Risk Level:

Lower

Rationale:

Penguin Solutions does not appear to discriminate against charitable organizations based on views or beliefs (1).

Criteria:

Employment policies fail to protect against viewpoint or other discrimination and/or are ideological in nature.

Risk Level:

High

Rationale:

Penguin Solutions requires its employees to take DEI training
(1). In 2025, the company rebranded its DEI training as Inclusion; however, it remains unclear whether the underlying divisive corporate policies/practices materially changed following the rebrand (2). Penguin Solutions appears to prioritize diversity over merit in its recruitment, hiring, and leadership composition. From its 2025 Proxy Report: “Collaborate with external partners such as CIRCA, a diversity recruitment and HR compliance solutions company, which promotes our open positions to individuals in Black, Hispanic, and LGBTQIA+ communities, as well as partnerships with Historically Black Colleges and Universities” (3). “In fiscal 2024, our Board revised our Corporate Governance Guidelines to include consideration of diversity in gender, race, ethnicity, and age in evaluating director candidates and whether to nominate directors for election or re-election” (4). The company is an affirmative action employer. “We are an Affirmative Action/Equal Opportunity Employer…” (5). Penguin Solutions does not provide viewpoint protections for its employees (6).

Corporate Governance and Public Policy

Criteria:

Uses corporate reputation to support causes, organizations, or policies hostile to freedom of expression.

Risk Level:

High

Rationale:

Penguin Solutions is committed to net zero emissions by 2030 (1). The company supports DEI within its business practices, hosting a DEI Council (2). In 2025, Penguin Solutions rebranded its DEI Council as Global Belonging Council; despite the rebranding, the underlying divisive corporate policies/practices appear to remain in place (3). The company supports DEI and ESG within its business practices. From its 2023 ESG Report: “Our commitment to diversity, equity, and inclusion goes beyond
mere representation. We are dedicated to creating an inclusive
environment where every employee feels respected, valued, and
empowered to bring their authentic self to work” (4). From its 2025 ESS Report: “We also formulated Future Impact Goals that reaffirm our commitments to environmental sustainability, governance and ethics, and inclusion and belonging” (5).

Criteria:

Uses corporate funds to advance ideological causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Medium

Rationale:

Penguin Solutions funded the Asian American Legal Defense and Education Fund (AALDEF) and he Thurgood Marshall College Fund (1)(2)(3). Otherwise, there are no publicly known cases of the company using corporate funds to advance ideological causes, organizations, or policies (4).

Criteria:

Uses corporate political actions and/or financial contributions for ideological, non-business purposes.

Risk Level:

N/A

Rationale:

Penguin Solutions does not operate a PAC or engage in lobbying at this time (1)(2)(3).