Walmart Inc

In coming months, we expect to revise our Scope 3 targets in collaboration with NGOs, suppliers and other stakeholders. In addition to pursuing our own mitigation initiatives, we also continue to engage policymakers, NGOs, customers, associates and other retailers through direct advocacy, industry engagement campaigns such as the Retail Race to Zero and trade associations. [...] Individually and collectively, we can all accelerate our own climate action and advocate for consistent and robust national and international policies that align with the Paris Agreement.

Walmart's Approach

Our approach to supporting and shaping public policy includes:

* **Governance** of Walmart's public policy strategies to ensure alignment with our business priorities and company values, promote transparency, and ensure legal compliance
* **Advocating for policies** that promote our business interests
* **Engaging in the political process** via our employee-funded Walmart Inc. Political Action Committee for Responsible Government (WALPAC), and
* **Working with business coalitions** to prioritize and advance key issues that strengthen our business and affect our stakeholders.

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Key Strategies and Progress

### Governance and Transparency

We govern our public policy activities to ensure alignment with Walmart business priorities and company values, to promote transparency, and to comply with relevant laws and our political spending policies. Governance includes Walmart Board of Directors and Board Committee oversight, management oversight, and regular, transparent reporting on policy activities.

#### Board and Board Committee Oversight

By charter, the 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. Consistent with Walmart's Government Relations Policy, management provides annual updates to the NGC concerning the company's public policy strategy.

In fiscal 2024, management discussions with the NGC included:

* Walmart's planned U.S. federal government affairs and policy priorities for 2023-2024;
* Examples of 2022-2023 activities;
* WALPAC political contribution strategy and plans for 2023-2024; and
* International government affairs strategies.

Highlights from these discussions were shared with the full Board.

#### Management Oversight

Walmart's management team designs and implements our public policy activities day-to-day, while our Government Relations Policy guides the company's interaction with elected officials, legislative, and regulatory bodies at all levels. Among other things, the 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. Our approach to these issues is further described below.

#### Transparency

Walmart is committed to transparency regarding our public policy activities. We submit quarterly reports to Congress that outline our federal lobbying activities, including lobbying expenditures and the specific legislative items and public policy issues that were the topics of communication. In each quarterly report, we identify the specific registered lobbyist who acted on behalf of the company. We also submit biannual contribution reports.

* Federal lobbying activities (LD-1 & LD-2 Reports): US Senate Lobbying Disclosure - Registrations & Quarterly Activity
* Federal political contributions (LD-203 Reports): US Senate Lobbying Disclosure

Beyond these required reports, Walmart's Government Relations Policy commits the company to reporting at least annually on our public policy priorities, strategies, and activities, as well as transparency in our trade association memberships and lobbying activities. To that end, Walmart has:

* Published a discussion on our public policy priorities, advocacy strategy, and external engagements
* Provided state and federal lobbying information on our Investor Relations website
* Disclosed our philosophy on trade association memberships, and our approach to dealing with trade association policy misalignments, and
* Published a list of trade associations to which Walmart contributes funds of $25,000 or more per year, and committed to updating this list at least annually.

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### Engagement in the Political Process

Walmart supports our associates' engagement in the political process, including by facilitating voting and providing opportunities to contribute to WALPAC, which supports the election of lawmakers who can help advance policy priorities critical to the interests of our customers, associates, suppliers, communities, and shareholders.

#### WALPAC Governance

WALPAC's activities are governed by the WALPAC Advisory Board, comprising Walmart Inc. officers and senior management. This Board sets the overall budget each calendar year and reexamines and adjusts the overall WALPAC strategy at the close of each election cycle (every two years). WALPAC senior management determines how to disburse annual WALPAC funds in alignment with this strategy. In accordance with federal election regulations, a report of WALPAC receipts and contributions is disclosed to the Federal Election Commission on a monthly basis. See above for direct links to these reports.

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### Working Through Business Organizations

In addition to direct advocacy and political engagement, Walmart is a member of various trade associations and business organizations that we believe can assist us in achieving our long-term strategic objectives. These organizations allow us to work with peers on policy issues that impact the retail sector and beyond.

**Our Approach to Engagement:** Walmart supports trade associations for many reasons, including development and sharing of best practices, advocacy on behalf of industry interests, promotion of public policy, and/or general support for an association's mission. Our engagement model depends on the role the trade association plays in helping Walmart achieve its strategic objectives, and may include varying levels of financial support, involvement on the Board and/or with key committees, or targeted financial support for initiatives within a broader organization. We communicate our strategic priorities and perspective on matters of public policy where appropriate with our trade associations, policymakers, and the public so that our positions are clearly known.

**Membership, Financial Support, and Alignment Reviews:** We periodically review 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. Where we generally support the organization's priorities and the positions the organization has taken on key issues, we may maintain general membership in the organization while working to influence the organization's direction.

But trade associations and business organizations have broad memberships and may prioritize initiatives that are not priorities for individual members and may take positions that conflict with any individual member's. Where substantial concerns arise, we work to influence the direction of the organization and convey any concerns to the organization's leadership. Usually those misalignments are resolvable. Where they are not, we may choose to modify our engagement with and/or funding for the organization's initiatives. If an organization, on balance, becomes significantly misaligned with our strategic priorities, viewpoints, and/or corporate values, we would end ties with the organization altogether.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Walmart is committed to policy advocacy aligned with the Paris Climate Agreement. Our advocacy has been consistent with that agreement since 2016. In 2021, we memorialized our commitment in a Board-approved Statement on Climate Policy. The Statement frames our advocacy around achieving 1.5° Celsius-aligned, science-based national and international climate policies that are consistent with achieving net-zero emissions by 2050 and that equitably address the needs of all stakeholders.

We believe market-based and economy-wide emissions-reduction policies, like a price on carbon, are critical to achieving ambitious reductions in greenhouse gas emissions while supporting economic prosperity. We also recognize that market-based, technology-neutral approaches for hard-to-decarbonize sectors can play a valuable role in the absence of economy-wide action. The Nominating and Governance Committee (NGC) of the Walmart Inc. Board of Directors—a Board committee comprised of independent directors—oversees our public policy strategies and activities, including those related to climate change. Management provides regular updates at least annually to the NGC concerning the company's public policy strategy and highlights of the committee's discussions with management are shared with the full Board of Directors. In 2021, NGC/management discussions included Walmart's planned U.S. federal government affairs and policy priorities for 2021-2022 and a review of 2020-2021 activities, including engagement with and through key trade associations on climate change and other priority topics.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Walmart is committed to policy advocacy aligned with the Paris Climate Agreement. Our advocacy has been consistent with that agreement since 2016. In 2021, we memorialized our commitment in a Board-approved Statement on Climate Policy. The Statement frames our advocacy around achieving 1.5° Celsius-aligned, science-based national and international climate policies that are consistent with achieving net-zero emissions by 2050 and that equitably address the needs of all.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes