Home Depot Inc/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Home Depot Inc/The has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly identified multiple specific climate policies it has engaged with, including the 'HR4447, Clean Economy Jobs and Innovation Act,' the 'Energy Savings Through Public-Private Partnerships Act of 2019,' the 'Ceiling Fan Improvement Act of 2020,' the 'Port Infrastructure Development Grant Programs,' the 'Surface Transportation Reauthorization Act of 2021,' and provisions 50122 and 50123 of the Inflation Reduction Act. Additionally, it has disclosed its engagement with state-level policies such as the 'Florida: ENERGY STAR Sales Tax Holiday' and California's 'Battery Powered Lawn Equipment Rebates' associated with the small off-road engine (SORE) ban. These disclosures provide detailed information about the policies' focus areas, legislative processes, and geographical scope. The company has also been transparent about its lobbying mechanisms, detailing specific actions such as writing letters of support for the US Department of Transportation's PIDP grant program, providing feedback to the Florida Department of Revenue, and engaging with the US Department of Energy and state energy offices on the implementation of point-of-sale rebates under the Inflation Reduction Act. It has identified its lobbying targets, including federal policymakers, agencies like the Department of Energy, and state-level entities such as the Florida Department of Revenue and California policymakers. These disclosures illustrate a clear and detailed approach to its lobbying mechanisms and targets. Furthermore, Home Depot has been explicit about the outcomes it seeks through its lobbying efforts. It has disclosed specific goals, such as advocating for revisions to energy conservation standards for ceiling fans, eliminating the customer affidavit requirement during the ENERGY STAR Sales Tax Holiday, and influencing the implementation of point-of-sale rebates under the Inflation Reduction Act. The company has also outlined broader objectives, such as decreasing emissions by improving supply chain efficiency and facilitating the adoption of new standards. These disclosures demonstrate a clear alignment between its lobbying activities and its climate-related goals, providing transparency about the desired policy changes and their rationale.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	The Home Depot discloses that it "engages with policymakers regarding business-relevant legislation, regulations, and initiatives" both "direct and indirect, via trade associations and coalitions," and notes that "when engaging on matters related to climate, the Government Relations department reviews policies for alignment with the Company's climate strategy." This indicates strong governance of climate lobbying, as The Home Depot demonstrates a defined process for ensuring alignment and identifies the Government Relations department as responsible for overseeing these activities. While the evidence does not elaborate on specific monitoring or accountability mechanisms, the stated approach signifies a structured framework that helps ensure lobbying efforts remain consistent with the company's broader climate objectives.	3