Lobbying Expenditures Disclosure

2017 – Walgreens Boots Alliance

WHEREAS, we believe in full disclosure of Walgreens Boots Alliance direct and indirect lobbying activities and expenditures to assess whether Walgreens’ lobbying is consistent with Walgreens’ expressed goals and in the best interest of stockholders.

RESOLVED, the stockholders of Walgreens Boots Alliance request preparation of a report, updated annually, disclosing:

1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.

2. Walgreens’ payments used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including amount of payment and recipient.

3. Walgreens’ membership in and payments to any tax-exempt organization that writes and endorses model legislation.

4. Description of management’s decision process and Board oversight on payments described in number 2 above.

For purposes of this proposal, a “grassroots lobbying communication” is communication directed to the general public that (a) refers to specific legislation or regulation, (b) reflects a view on the legislation or regulation and (c) encourages communication recipient to take action on that legislation or regulation.  “Indirect lobbying” is lobbying engaged in by a trade association or other organization in which Walgreens holds membership.  Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at local, state and federal levels.

The report shall be presented to the Audit Committee or other relevant oversight committees and posted on Walgreens’ website. 

Supporting Statement:  As stockholders, we encourage transparency and accountability in use of corporate funds to influence legislation and regulation. Walgreens’ website under “Public Policy and Political Activities” provides limited information on lobbying and public policy advocacy.  In contrast, peers CVS and Express Scripts publish clear policies and payments for political contributions and lobbying, as well information on trade association participation.  We believe Walgreens strives to be responsible regarding environment, health and employee relations but investors are unaware if our corporate goals are reflected in our lobbying activities and expenditures.

Additionally, CVS withdrew membership in the U.S. Chamber of Commerce when the NYT exposed Chamber lobbying internationally to protect tobacco interests.  Does Walgreens evaluate whether its trade associations are taking responsible positions on issues such as climate change, drug pricing and smoking?

Walgreens spent $5.44 million in 2014 and 2015 on direct federal lobbying activities (opensecrets.org). This figure omits lobbying expenditures to influence legislation in states, where Walgreens also lobbies but disclosure is uneven or absent.  For example, in 2015 Walgreens lobbied in some 29 states (National Institute on Money in State Politics) and spent more than $360,000 lobbying in California, New Jersey and Texas.

Also, Walgreens belongs to the Business Roundtable, which spent more than $34 million on lobbying in 2014 and 2015.  To repeat, Walgreens does not disclose memberships, payments to trade associations, or amounts used for lobbying and lags its peers, CVS Caremark and Express Scripts.

Transparent reporting would reveal whether company assets are deployed for objectives contrary to Walgreens’ long-term interests.