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| Overall Assessment |
Comment |
Score |
| Limited |
Best Buy provides only limited transparency around its climate-policy lobbying. It names one specific initiative—the Department of Energy’s “Home Energy Rebate Program … authorized through the Inflation Reduction Act Section 50122: High Efficiency, Electric Home Rebate Program”—but otherwise refers only broadly to supporting “policies that encourage energy-efficient design, innovation and use” or to “advocat[ing] for a cleaner grid,” without identifying additional bills or regulations. The company outlines several ways it engages, such as belonging to trade associations, filing federal lobbying reports and making corporate political contributions, and it discloses one direct interaction, stating that “Best Buy met with DOE representatives in 2022 to share how Best Buy expects the proposed implementation of the program to influence consumer behavior.” Beyond this single mention of the DOE, however, it does not identify which legislators, agencies or jurisdictions it routinely targets, so its description of mechanisms and audiences remains high-level. Finally, while it expresses broad aims—promoting responsible e-waste recycling, backing energy efficiency and hoping the rebate program will boost sales of efficient products—it does not spell out the concrete policy changes, amendments or numeric targets it is seeking. Together, these disclosures offer only a general picture of the company’s climate lobbying activities and objectives.
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1
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| Overall Assessment |
Comment |
Score |
| Strong |
Best Buy discloses a structured process to keep its lobbying practices—both direct and through trade bodies—aligned with its climate objectives. The company states that “members of the Environmental Sustainability and Compliance team annually review direct and indirect activities that influence policy to establish whether the activities are consistent with our overall position on climate change,” indicating a recurring, climate-specific alignment check rather than a one-off pledge. Oversight is clearly assigned: the “Nominating, Corporate Governance and Public Policy Committee of the Best Buy Board of Directors” conducts an annual review of “this report and the Best Buy Political Activity & Government Affairs Policy,” while the “Vice President of Government Affairs and Corporate Responsibility” directs the monitoring of legislative activity, and a five-member “Contributions Steering Committee” approves major political expenditures. For indirect lobbying, Best Buy affirms that it “monitors the use of dues or payments to trade associations and other organizations to ensure consistency with the company’s stated policies, practices, values and long-term interests,” and notes that “potential conflicts are examined on a case-by-case basis… to determine the most appropriate mitigation strategy,” demonstrating an active mechanism to manage misalignment. Direct lobbying is governed through a process in which the Government Affairs team “develops public policy positions” and “manages these issues throughout the local, state and federal legislative sessions,” under board-level scrutiny. The company also makes the high-level public commitment that its “engagement activities” will be “in line with the goals of the Paris Agreement.” However, Best Buy does not provide a public, association-by-association climate-lobbying alignment report, nor does it disclose specific examples of engaging or exiting organizations over climate positions, leaving the depth of implementation and transparency less clear. Overall, the combination of stated procedures, coverage of both direct and indirect channels, and named oversight bodies indicates strong governance, though disclosure could be more granular and externally validated.
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3
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