Costco Wholesale Corp

Costco's governance of policy advocacy is confined to its spending policy, which "expressly prohibits 'making contributions to any political party or candidate, federal, state or local, in all countries in which we do business'" and mandates that trade associations it joins "not use any portion of the dues paid by Costco Wholesale for political contributions or independent expenditures." This policy is overseen by a formal body - namely, "The Nominating and Governance Committee of the Board of Directors, which is comprised exclusively of independent directors" - that "reviews the Company's spending on politics and advocacy and compliance with the policies described above." However, we found no evidence of any process to align direct or indirect lobbying activities with Costco's climate-change strategy or any mention of climate-focused lobbying oversight.