Walgreens Boots Alliance Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Walgreens Boots Alliance Inc’s disclosures outline a broad ESG oversight structure in which “the Nominating and Governance Committee oversees the ESG agenda on behalf of the board of directors” and the “WBA ESG Committee plays a key role in providing further oversight and governance of our ESG program. This committee meets four times a year to review our ESG program, policy statements, evolving ESG-related regulations, social and environmental risks and progress toward achieving our ESG goals.” The company also states that “Responsible corporate citizenship includes exercising our responsibility to actively participate in the political process” and that it “engage[s] in the political and policymaking processes in the United States,” yet it does not disclose any mechanisms to ensure that these engagement or lobbying activities are aligned with its climate change strategy or managed via a defined review process. We found no evidence of a policy to guide or monitor climate-related lobbying, no mention of oversight of direct or indirect lobbying by a named individual or committee, and, notably, the company confirms that it does not have and does not plan to have “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” View Sources	0

Overall Assessment

Analysis

Score

None

Walgreens Boots Alliance Inc’s disclosures outline a broad ESG oversight structure in which “the Nominating and Governance Committee oversees the ESG agenda on behalf of the board of directors” and the “WBA ESG Committee plays a key role in providing further oversight and governance of our ESG program. This committee meets four times a year to review our ESG program, policy statements, evolving ESG-related regulations, social and environmental risks and progress toward achieving our ESG goals.” The company also states that “Responsible corporate citizenship includes exercising our responsibility to actively participate in the political process” and that it “engage[s] in the political and policymaking processes in the United States,” yet it does not disclose any mechanisms to ensure that these engagement or lobbying activities are aligned with its climate change strategy or managed via a defined review process. We found no evidence of a policy to guide or monitor climate-related lobbying, no mention of oversight of direct or indirect lobbying by a named individual or committee, and, notably, the company confirms that it does not have and does not plan to have “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.”

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Walgreens Boots Alliance offers only limited insight into its climate-related lobbying. The company notes that it joined the Retail Industry Leaders Association’s response to the U.S. Securities and Exchange Commission’s consultation on climate-risk disclosure rules and that it is “supportive of the BRC Climate Roadmap,” but it does not name any other specific climate laws or regulations it attempts to influence. The only mechanisms it describes are indirect—membership of trade bodies such as the Business Roundtable, the British Retail Consortium and RILA, and participation in a public comment process with the SEC—without detailing any direct engagements such as meetings, letters, or testimony, nor identifying additional policymaking targets beyond the SEC. On outcomes, WBA voices broad aspirations, endorsing the BRC’s net-zero 2040 vision and the Business Roundtable’s call for “a well-designed market-based mechanism,” yet it does not spell out the concrete legislative changes or regulatory thresholds it is advocating. This high-level, largely generic information means stakeholders receive only a narrow picture of the company’s actual climate-policy lobbying activities and objectives.	1