Target Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Target Corporation provides a highly detailed picture of its climate-policy lobbying. It names a wide range of specific measures it has engaged on, including state regulatory cases such as “Minnesota Public Utilities Commission Docket 22-600,” “Minnesota House File 7,” and “Virginia HB 1770,” federal and regional initiatives like the “Inflation Reduction Act,” “Western Electricity Market Expansion,” “Texas Market Reform,” and the “Southeast Energy Exchange Market,” as well as international efforts to accelerate Vietnam’s Direct Power Purchase Agreement programme. The company also explains how it intervenes. It discloses direct actions—“filed comments and provided testimony at the Minnesota Public Utilities Commission,” “signed a business-coalition letter to South Carolina legislature,” “contributed to regulatory comments… with Commercial Customers with Clean Energy Goals,” and sent “a letter to the Prime Minister of Vietnam”—and indirect routes such as advocacy “through our state retail association and chamber of commerce channels” or “working through CEBA” to influence regional transmission policy. Each example identifies the policymaking body or official forum being targeted, demonstrating clarity on both mechanism and audience. Target is equally explicit about what it wants those interventions to achieve. It seeks to “break down barriers to a full Regional Transmission Operator across western states,” supports “clean energy provisions in the IRA,” advocates for “increased clean energy options for businesses and customers in regulated electric markets,” “fair rates for solar energy production,” and the launch of Vietnam’s DPPA scheme, while opposing proposals it believes would “restrict the opportunities to site and operate renewable resources.” These statements spell out concrete policy changes or design parameters and frequently note whether the company’s stance is fully supportive, supportive with caveats, or opposed. Taken together, the disclosure offers comprehensive visibility into the policies addressed, the methods and channels used, and the precise outcomes Target is pursuing in order to advance the energy transition.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Target discloses several elements of oversight for its advocacy activities, indicating a developing governance process for lobbying alignment. A “subset of the leadership team” serves as the “decision-making body for financial support of political activities” and “reports to the Board of Directors at least twice per year,” demonstrating named oversight and regular board reporting. The company further notes that “Target corporate political contributions and lobbying practices may be subject to periodic internal audits,” signalling an internal monitoring mechanism, and it publishes quarterly federal “Lobbying Reports” as well as an annual list of “trade associations and other policy-based organizations that we support.” With respect to climate, Target states that it will “engag[e] constructively … with policymakers to help accelerate the transition to a zero-carbon economy” and affirms “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement,” which constitutes an explicit policy commitment to climate-aligned advocacy. However, the disclosures do not explain how the leadership team or audits specifically assess whether direct or trade-association lobbying positions align with this climate policy, nor do they describe any process for “engaging with, correcting, or exiting” associations whose stances conflict with Target’s net-zero goals. The evidence therefore indicates some governance and climate-alignment intent, but the company does not disclose detailed procedures, criteria, or outcomes for ensuring its lobbying—direct or indirect—remains consistent with its stated climate objectives.	2