Walmart Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Walmart Inc has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly disclosed specific climate-related policies it has engaged with, such as the Inflation Reduction Act (IRA), the Build Back Better legislation, the Infrastructure Investment and Jobs Act, and the Growing Climate Solutions Act. Walmart also provided details on its advocacy for "1.5° Celsius-aligned, science-based national and international climate policies" and its endorsement of the Business Roundtable's call for a U.S. national climate policy solution to reduce emissions by at least 80% by 2050 through a market-based mechanism. In terms of lobbying mechanisms, Walmart has outlined direct engagement with lawmakers, public advocacy, and participation in trade associations like the Business Roundtable and Consumer Goods Forum. Specific mechanisms include submitting comments to the EPA and NHTSA, participating in advisory groups, and engaging in state utility commission-ordered working groups. The company has also disclosed its targets, such as the U.S. Congress, Federal Energy Regulatory Commission, and state-level entities in Kansas, North Carolina, South Carolina, and Missouri. Regarding outcomes sought, Walmart has been explicit about its goals, such as advocating for "market-based emissions-reduction policies," supporting "carbon pricing and sector-based, technology-neutral approaches to decarbonize sectors like agriculture," and aiming to achieve "1.5° Celsius-aligned, science-based national and international climate policies." Additionally, Walmart seeks to expand wholesale energy markets, increase renewable energy consumption through green tariffs, and triple renewable electricity capacity by 2030. This level of detail illustrates Walmart's comprehensive approach to disclosing its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Walmart demonstrates a strong governance process for climate lobbying alignment, with clear oversight structures and monitoring mechanisms in place. The company explicitly states that its "Nominating and Governance Committee (NGC) of the Walmart Inc. Board of Directors, a Board committee comprised entirely of independent directors, oversees our public policy strategies and activities." This oversight includes "management providing annual updates to the NGC concerning the company's public policy strategy," ensuring alignment with Walmart's business priorities and values. Furthermore, Walmart has a defined process for managing trade association memberships, noting that it "periodically reviews our memberships to determine whether—based on the value they provide and positions they take—adjustments are needed in our engagement, membership status, or the level of financial support we provide." The company also commits to transparency by publishing "a list of trade associations to which Walmart contributes funds of $25,000 or more per year" and updating it annually. Additionally, Walmart addresses misalignments with trade associations, stating that "where substantial concerns arise, we work to influence the direction of the organization and convey any concerns to the organization's leadership." These disclosures indicate a robust governance framework for both direct and indirect lobbying activities, supported by monitoring processes and accountability measures.	3