Walmart Inc

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 whether - based on the value they provide and positions they take - adjustments 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.