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Responsible Engagement in Public Policy

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Last updated: Apr. 26, 2024

At a Glance

Relevance to Our Business and Society

Effective public policy supports our business and fosters a stable business environment. Businesses play a vital role in tackling challenging issues. Stakeholders, including our customers, associates, communities, and investors, expect transparent engagement in public policy to address these challenges while supporting business objectives.

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.
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.



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.

Public Policy Advocacy


Walmart engages in public policy discussions to promote the interests of our company and our stakeholders by focusing on issues that align with our shared value approach, without regard for the private political preferences of any associates (including senior leadership and executives). We determine whether and how to weigh in on these matters by considering the relevance to our business and brand, shareholder expectations, and our ability to be an effective, credible actor.


Key issues on which we engage in public advocacy include:

Energy Transformation and Climate Change

A sound energy transformation and climate strategy supports the resilience of our global business and the many communities we serve. Our Board-approved Statement on Climate Policy frames our overall approach to engaging on these issues.


Walmart continues to advocate for strong climate policy. We support policies that, among other things, promote investment in the kinds of clean energy and transportation initiatives we support through our business. For example, alongside other retailers at COP28 in 2023, we encouraged world leaders to triple renewable electricity capacity by 2030.


Walmart’s energy transformation and climate advocacy are part of our broader climate strategy that also includes governance, climate risk assessments, science-based targets and supporting mitigation initiatives, adaptation, and reporting.

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.


Associate Participation in the Electoral Process

Walmart joined and continues to support the efforts of Time to Vote, a business-led, non-partisan coalition of over 2,000 companies aiming to increase voter participation in U.S. elections. We encourage our associates to vote and provide paid time off to vote, where needed. At appropriate times in the electoral cycle, we also provide resources that help our associates and customers stay informed and participate in elections (e.g., information on requesting an absentee ballot, voter registration deadlines, polling locations).


WALPAC

In the United States, campaign finance laws at the federal level and in many states govern the use of corporate funds in the election process. WALPAC is funded solely with voluntary contributions from eligible associates and provides our team members an opportunity to collectively participate in the political process.


WALPAC Contributions

Further details: WALPAC Federal Donations

U.S. States Featuring WALPAC Contributions to State-level Candidates and Committees (2023)

 

U.S. States Featuring WALPAC Contributions to State-level Candidates and Committees in 2023 includes Arizona, Arkansas, Iowa, Indiana, Kentucky, Louisiana, Maine, Mississippi, North Carolina, New Jersey, Ohio, Oklahoma, Pennsylvania, Texas, Virginia, and Wyoming

Contributions to state and federal candidates and committees are made considering a wide range of criteria such as voting records, leadership positions, committee membership, and legislative activity. WALPAC’s campaign contributions to elected officials are not an endorsement of all their individual beliefs, voting records or comments, and WALPAC may examine candidates’ public statements, social media posts, and other communications when making contribution decisions.


Read More: WALPAC Contributions (FEC.gov)


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.

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.1 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.


Our Trade Associations and Member Organizations List includes examples of domestic and international trade associations, business coalitions, and other organizations in which we participate and—as relevant—the ways they help to further our objectives. This list also highlights those trade associations to which we contributed funds of $25,000 or more in 2023.

Challenges
  • Walmart is a complex business operating across multiple sectors to bring essential products and services to people who need them. There are many public policy issues that bear on our ability to deliver on our mission and it can be challenging to optimize outcomes across all issues.
  • The public expects a company's political engagement to align with its values. At the same time, there can be pressure to weigh in on issues that are not core to our business nor critical to a majority of our stakeholders. We have decision-making processes to determine whether and how to get involved in an issue, but we may not always meet all stakeholders’ expectations.
  • The political process is subject to many influences. Walmart is but one actor and may not be able to influence public policy. Walmart is often in the position of supporting certain aspects of legislation or regulation while opposing other aspects. Stakeholders may not fully appreciate nor recognize these nuances.
  • Walmart may not agree with every position or lobbying action taken by trade associations to which we belong. We work to influence these associations, but they ultimately set their own agendas and are subject to a wide array of member views. As discussed above, we have processes for handling any such misalignment, but we may not always meet all stakeholders’ expectations.

1. For example, we are not a member of, nor do we pay general membership dues to, the U.S. Chamber of Commerce, but we do financially support specific Chamber initiatives that align with our corporate strategy (e.g., Institute for Legal Reform, international programs/councils).

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