Walmart Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Walmart provides an extensive and concrete picture of its climate-policy lobbying. It identifies numerous specific policies it has worked on, ranging from federal vehicle standards (“submitted comments to the EPA and NHTSA on the proposed Phase 2 Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles”) and major legislation (“engaged directly with policy makers to support the climate provisions of the Inflation Reduction Act,” the “Build Back Better legislation,” and the “Infrastructure Investment and Jobs Act”) to state-level renewable-energy programs such as the “Georgia Power C&I REDI,” “Florida Power & Light SolarTogether,” and “PNM Solar Direct” tariffs, as well as advocacy at FERC for broader wholesale-market access. The company also discloses how it lobbies, detailing direct meetings (“Walmart policy teams and subject matter experts met directly with lawmakers and their staff”), formal submissions (comment letters to the SEC, EPA and NHTSA), testimony before Congress, participation in “state utility commission-ordered working groups,” and indirect action through trade bodies such as the Business Roundtable, Clean Energy Buyers Association, Renewable Energy Buyers Alliance and Advanced Energy Management Alliance. Targets are named explicitly, including the U.S. Congress, Federal Energy Regulatory Commission, several state commissions, and foreign governments such as Thailand. Finally, Walmart is clear about the outcomes it seeks: it pressed for “a strong Phase 2 rule that drives innovation in truck technologies,” advocates “policies that allow market-based solutions like PPAs” and the expansion of wholesale energy markets, supports “tripling renewable electricity capacity by 2030,” backs carbon-pricing and technology-neutral decarbonisation measures, and wants regenerative agriculture included in the Farm Bill. This level of specificity across policies, mechanisms and desired results demonstrates comprehensive transparency in the company’s climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Walmart discloses a structured process to govern and align both its direct and indirect policy advocacy with its climate commitments. The company states that in 2021 it memorialized our commitment in a Board-approved Statement on Climate Policy that frames all advocacy around achieving 1.5 Celsius-aligned, science-based national and international climate policies, and confirms that the Nominating and Governance Committee (NGC) of the Board oversees our public policy strategies and activities, including those related to climate change, with management providing regular updates at least annually. Operationally, a Government Relations Policy delineates roles and responsibilities for engagement with public officials, sets parameters on the use of corporate and political giving, governs fundraising and solicitation by our associates, and defines how we evaluate trade association memberships, demonstrating a defined mechanism for managing direct lobbying. For indirect lobbying, Walmart explains that it periodically review[s] our memberships to determine whetherbased on the value they provide and positions they takeadjustments are needed, and where misalignments cannot be resolved, we may choose to modify our engagement or end ties with the organization altogether, indicating an active alignment process with trade associations. Transparency measures include commitments to reporting at least annually on our public policy priorities, strategies, and activities and publishing a list of trade associations to which Walmart contributes funds of $25,000 or more per year, which supports accountability. While this indicates strong governance through clear board oversight, articulated review procedures, and coverage of both direct and indirect lobbying, the company does not disclose a standalone climate-lobbying alignment audit or third-party review, nor does it provide detailed public findings of such reviews, which would further enhance transparency.	3