Walmart Hits a Double on Responsible Climate Lobbying Disclosure

By Frank Sherman

“Climate change is one of the greatest challenges of our time, profoundly affecting all regions of the world and all sectors of society. . . . Companies need to be part of the solution to manage physical and transition risk, maintain societal license to operate and create value for business and society through mitigation and adaptation initiatives that draw on unique business capabilities.”

Walmart, 2021 ESG Summary

At first glance, this may be mistaken as an excerpt from an environmental NGO website rather than from the largest corporation in the world. But Walmart has long been recognized by many as a leader in climate action.  They were the first retailer to obtain SBTi certified greenhouse gas (GHG) targets and the first to make a zero emissions commitment that does not rely on carbon offsets for scope 1 & 2 emissions. Committed to 100% renewable electricity by 2035, they have also been recognized as the top retail partner by the U.S. EPA Green Power Partnership. EPA’s SmartWay Excellence Award for shipping performance recognized Walmart for the fifth year in a row. Their award winning Project Gigaton targets a reduction of at least 30% of estimated scope 3 emissions by 2030. No wonder they made CDP Climate’s ‘A List’ for several years.

But one area where Walmart, along with many other companies, has fallen short is in its engagement on climate public policy. That’s why SGI member, the School Sisters of Notre Dame, Central Pacific Province (SSND), filed a shareholder resolution with the Company, as part of a broader campaign coordinated by ICCR and Ceres. According to Influence Map, Transition Pathways Initiative and Ceres, Walmart’s direct lobbying is supportive of the Paris Agreement. The SSND proposal asked Walmart to evaluate whether their indirect lobbying activities through trade associations and social welfare and nonprofit organizations are aligned with the company’s support of the Paris Agreement goals. We also asked the company to be more public in their support of robust climate policies rather than engaging policy makers ‘in private.’ The proponents withdrew the proposal after the Company agreed to improve their disclosure.

Following the withdrawal, Walmart strengthened their Government Relations Policy and made extensive updates to their Engagement in public policy webpage, providing details on governance, policy positions, engagement process, and examples of positive advocacy. They published a list of trade associations to which Walmart contributed funds of $25,000 or more in 2021. They actively engage their trade associations to influence their public policy positions. They note that the Business Roundtable’s (BRT) position towards climate policy, although not as strong as we would like, improved as a result of Walmart’s CEO Doug McMillon’s influence when he chaired the BRT.

To be fair, the goalpost on what constitutes “responsible climate lobbying” has been moving due to a number of factors including increasing calls from scientists for urgent action, such as the recent IPCC report. This culminated in the recently released Global Standard on Corporate Climate Lobbying describing 14 indicators to assess a company’s direct and indirect lobbying alignment with the Paris goal of limiting global temperature rise  to 1.5 degrees.

To be sure, there are areas where Walmart’s disclosure and practices can be improved. The main shortfall vs. the new global standard is the lack of a detailed public assessment of each trade association’s climate policy positions and how well it aligns with the Paris goals and the Company’s position. An increasing number of multinational companies are doing this assessment of their indirect climate lobbying through trade associations and nonprofits they fund, evaluating the actions they are taking to support or undermine the Paris Agreement goal of 1.5 degrees. The Company states, “If a relationship—on balance—does not align with our priorities, we would end ties with the organization altogether,” which they did a few years ago when they exited the Chamber of Commerce. “I wouldn’t say they hit a homerun, but it’s safe to say they made it to second base,” said Tim Dewane, Director of Shalom – the Office of Justice, Peace, and Integrity of Creation for the School Sisters of Notre Dame, Central Pacific Province, the lead proponent of the resolution. “We have to continue to work to get them home.