Walgreens does not explicitly prohibit discrimination based on viewpoint or ideology in its written EEO policy.

Walgreens’ lack of a company-wide best practice EEO policy sends mixed signals to company employees and prospective
employees and calls into question the extent to which individuals are protected due to inconsistent state policies and the
absence of federal protection for partisan activities. Approximately half of Americans live and work in a jurisdiction with no legal protections if their employer takes action against them for their political activities.

Companies with inclusive policies are better able to recruit the most talented employees from a broad labor pool, resolve
complaints internally to avoid costly litigation or reputational damage, and minimize employee turnover. Moreover, inclusive
policies contribute to more efficient human capital management by eliminating the need to maintain different policies in
different locations.

There is ample evidence that individuals with conservative viewpoints may face discrimination at Walgreens and need
formal protections.

Liberal activists have targeted the Company for boycotts over allegations that some employees have declined to sell birth
control products to customers.6 Calls for boycotts have only increased due to Walgreens’ decision to decline to sell the abortion pill in certain states.7

Such calls to boycott the Company have included extreme rhetoric designed to disparage and vilify individuals who do not share a leftwing or pro-abortion worldview.

For instance, leftwing filmmaker and Democrat activist Michael Moore said Walgreens “caved into threats from the extremist anti-abortion/Forced Birth movement” and is “further cement[ing] women’s status as second-class citizens.”8 Democrat California Governor Gavin Newsom said his state would cut ties with the Company. “California won’t be doing business with Walgreens - or any company that cowers to the extremists and puts women’s lives at risk...We’re done,” he tweeted.9

Although federal law generally protects employees from retribution for religious beliefs, it does not protect them from reprisal for social or political ideologies.10 Given the hostilities against the Company in recent years, protecting employees who do not subscribe to the boycotters’ worldview is more important than ever.

Presently, shareholders are unable to evaluate how Walgreens prevents discrimination towards employees based on their
ideology or viewpoint, mitigates employee concerns of potential discrimination, and ensures a respectful and supportive work atmosphere that bolsters employee performance.

Without an inclusive EEO policy, Walgreens may be sacrificing competitive advantages relative to peers while simultaneously increasing company and shareholder exposure to reputational and financial risks.

We recommend that the report evaluate risks including, but not limited to, negative effects on employee hiring and retention, as
well as litigation risks from conflicting state and company anti-discrimination policies.
(6) https://www.newsweek.com/walgreens-hit-boycott-calls-amid-claims-birth-control-sale-hassles-1725785; https://abc7.com/walgreens-boycott-customersdenied-birth-control/12067835
(7) https://www.forbes.com/sites/alisondurkee/2023/03/07/walgreens-sparks-calls-for-boycotts-after-refusing-to-dispense-abortion-pills-in-some-states/?sh=1dc039fe76f0; https://www.latimes.com/opinion/story/2023-03-08/editorial-walgreens-despicable-medication-abortion-pills
(8) https://www.forbes.com/sites/alisondurkee/2023/03/07/walgreens-sparks-calls-for-boycotts-after-refusing-to-dispense-abortion-pills-in-some-states/?sh=1dc039fe76f0
(9) https://www.kcra.com/article/gov-newsom-california-will-no-longer-do-business-with-walgreens-abortion-pill-stance/43222911#
(10) https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#:_:text-itle%20VII%20requires%20employers%20to.undue%20hardship%20on%20the%20employer.