RESOLVED

Shareholders request that the Board of Directors conduct an evaluation and issue a report within the next year (at reasonable cost, omitting proprietary information) describing if, and how, Walmart’s indirect lobbying activities through trade associations and social welfare and nonprofit organizations align with the Paris Climate Agreement’s aspirational goal of limiting average global warming to 1.5 degrees Celsius. The report should also address plans to mitigate the risks presented by any misalignment between its indirect lobbying and the company’s positions.

SUPPORTING STATEMENT

The recent Emissions Gap Report from the United Nations Environment Programme1 indicates critical gaps remain to prevent the worst effects of climate change. The Build Back Better Act calls for climate investment to support the United States goal to reduce emissions by 50% by 20302. Companies have a crucial role to play in empowering policymakers to close these gaps.

Investors and stakeholders are increasingly scrutinizing potential misalignment between companies’ climate commitments and policy advocacy.3 Corporate lobbying activities that are inconsistent with meeting the goals of the Paris Agreement to hold global warming to 1.5 degrees Celsius over pre-industrial levels present regulatory, reputational and legal risks. Such policy engagement also presents systemic risks to the economy, as delays in implementation of the Paris Agreement increase the physical risks of climate change, undermine economic stability, and introduce uncertainty and volatility into investment portfolios.

Walmart actively supports the goals of the Paris Agreement4, has committed to science-based targets for emissions reduction5, co-leads the Retail Race to Zero campaign6, and advocates for 1.5 degree aligned, science-based national and international climate policies7, including the Infrastructure Investment and Jobs Act and the Build Back Better budget reconciliation proposal.8 The Company discloses its public policy positions on its website and a partial list of trade associations and coalitions that engage in political activities.9 Although the Company states that it “periodically reviews its memberships to determine if any adjustments are needed”, it is not transparent in disclosing a full list of its major trade associations or identifying any misalignments with its own policy positions. Influence Map provides examples of company review processes of industry association policy positions and how well they meet investor expectations.10

Of particular concern are industry and policy organizations that speak for business but, unfortunately, too often present forceful obstacles to meaningful climate public policy. These organizations have consistently opposed legislative and regulatory intervention on climate change in the past and continue to oppose the Build Back Better budget reconciliation proposal.1112 An alignment assessment can help to identify and address risks presented by misalignment and protect the credibility of Walmart’s leadership efforts on climate.

Thus, we urge the Board to conduct a comprehensive review of Walmart’s lobbying and public policy activity and publicly disclose plans to address any misalignment with the Paris Agreement’s objectives.

1 https://www.unep.org/resources/emissions-gap-report-2021

2 https://www.nrdc.org/experts/manish-bapna/house-passes-historic-climate-action-build-back-better-act

3 https://www.politico.com/news/2021/04/20/investors-corporate-climate-lobbying-activity-483429

4 https://www.c2es.org/press-release/42-companies-urge-biden-congress-to-work-together-on-climate-solutions/ 5 https://corporate.walmart.com/global-responsibility/sustainability/planet/climate-change

6 https://corporate.walmart.com/newsroom/2021/07/07/retailers-join-forces-to-tackle-climate-change-in-the- race-to-zero

7 https://corporate.walmart.com/policies#climate-policy

8 https://www.linkedin.com/pulse/we-need-strong-climate-policy-now-enable-decade-kathleen-mclaughlin/

9 https://corporate.walmart.com/esgreport/esg-issues/engagement-in-public-policy

10 https://lobbymap.org/filter/List-of-Companies-and-Influencers#7

11 https://www.axios.com/big-business-sharpens-attack-build-back-better-51323e3b-286a-495d-acf7- 026ac3b513cc.html

12 https://www.wsj.com/articles/some-companies-sit-out-the-fight-over-democrats-tax-increases-11636367400