Kroger Co/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Kroger discloses the specific climate regulations it has engaged on, naming California’s refrigerant rules in the “Final Regulation Order of California Code of Regulations, Title 17…,” “CA Senate Bill 1206,” and Washington’s “Chapter 173-443 WAC,” thereby providing clear visibility into the exact policies under discussion. The company explains that its facility engineering and Corporate Affairs teams “have engaged with relevant policymakers to share feedback on anticipated outcomes of implementing these requirements,” which confirms direct engagement but offers only a brief description of the method and does not identify the individual agencies or officials involved. Kroger is relatively explicit about what it wants from these engagements, stating that it “supports the bill with major exceptions that do not force replacement of existing equipment with significant useful life remaining” and voicing concern that the California bill “will strand existing systems,” while still backing a phased transition to lower-GWP refrigerants. Taken together, the company provides strong detail on the policies themselves and a reasonable picture of the outcomes it seeks, but it gives only limited insight into the precise mechanisms and targets of its lobbying activities.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Kroger has implemented a basic governance mechanism to align its lobbying with its climate plan, stating that “we do not advocate for policies, laws or regulations that are in conflict with Kroger’s stated Climate plan objectives,” and by ensuring “Kroger’s government relations team reports to the GVP of Corporate Affairs who also serves as Chief Sustainability Officer, ensuring consistency between the company’s advocacy positions and stated sustainability goals.” This reporting line provides a clear oversight role, but the company does not disclose any formal process for reviewing or managing indirect lobbying through industry or trade associations, nor does it publish an independent audit or periodic review of its climate-related lobbying. When asked about aligning engagement with the Paris Agreement, Kroger responded “No, and we do not plan to have one in the next two years,” indicating that broader alignment mechanisms and public commitments are absent, limiting the transparency and robustness of its climate lobbying governance.	2