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WW Grainger Inc does not disclose any formal governance framework for lobbying activities related to climate change. It states that “It is Grainger’s policy not to actively engage with policymakers” and that “Grainger’s Business Conduct Guidelines prohibit the use of company funds or assets for political purposes, including for contributions to any political party, candidate, or committee,” reflecting a stance of non-participation rather than structured oversight. The company notes it “may engage indirectly in activities that could influence policy, law, or regulation that impacts the climate through membership in trade associations” such as the United States Chamber of Commerce and the National Association of Wholesaler-Distributors, but asserts “To the best of our knowledge, our support of these organizations does not play an indirect or direct role in activities that influence climate change policy,” without describing any process to monitor or align these associations’ positions. When asked if it has a public commitment to align engagement with the Paris Agreement, the company responds “No, and we do not plan to have one in the next two years,” indicating it does not disclose any process, responsible party, or oversight mechanism to ensure its lobbying is consistent with its climate strategy.
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