The Bath & Body Works NOligarchy Profile
C
O
N
C
E
R
N
I
N
G
Bath & Body Works scores 47.04 out of 100 on the NOligarchy scale — meaning the closer to zero, the worse the behavior. That number places a $7.29 billion retail fragrance giant in the middle of its peer group, sitting just above a sector average of 42.7. The company’s regulatory record is its strongest pillar; the weight dragging the score toward zero is a CEO pay gap and a shareholder payout machine that has little parallel in the sector.
Current Pillar Scores
Political Access
55.2
Wealth Extraction
9.3
Playing by the Rules
95.0
Score history — 23 quarters
Tier bands show where each quarter's score falls — no numeric y-axis needed. The dashed ring marks the year-over-year comparison point. Tap any quarter but the first to see its pillar breakdown.
•
Political Access Grade: 55.23/100. From Q3 2024 through Q2 2026 (8 quarters — the two-year tracking period), Bath & Body Works channeled $390,000 into federal lobbying, touching everything from chemical safety rules to tariff policy. The company runs no Political Action Committee (PAC) — confirmed at zero — though $3,500 in executive donations to federal campaigns is recorded for the period.
•
Wealth Extraction Grade: 9.11/100. This is the most damaging number in the profile. A chief executive whose three-year average compensation runs more than 1,100 times the median worker’s annual earnings, hundreds of millions in stock buybacks, and a steady dividend stream to shareholders tell the story of a company that chose to richly reward those at the top of the capital structure while the people staffing its stores saw little of that wealth flow their way.
•
Playing by the Rules Grade: 95.0/100. Bath & Body Works carries a single recorded federal violation — a workplace safety penalty from the Occupational Safety and Health Administration (OSHA) in 2024 totaling $6,913. It is a thin file, and the dollar amount sits at the very bottom of its sector peers, ranking fourth out of five companies in total fines — which, in this case, means the lightest penalty record in the group.
Bath & Body Works ranks 3rd out of 5 companies in the Health and personal care retailers sector, with a NOligarchy score of 47.04 against a sector average of 42.7. That edges above the mean — but the sector is pulled down sharply by the poorest performers. Measured against the two companies above it, Bath & Body Works still trails on accountability. This is middle of the pack, not a clean bill. Because this score falls below 50, readers looking for higher-scoring alternatives in this sector can find them in the Better Alternatives section below.
The Bottom Line: A Billion-Dollar Payout Machine Hiding Behind a Thin Lobbying File
Bath & Body Works generated $7.29 billion in annual revenue, according to SEC EDGAR 10-K (CIK 0000701985). In its two most recently reported fiscal years, it handed $802 million back to shareholders through stock buybacks — buying back its own shares to deliberately reduce shares outstanding, inflate per-share metrics, and trigger executive performance bonuses — on top of another $344 million in dividends. Meanwhile, the median Bath & Body Works employee earned less than $9,603 in a year — a figure that, spread across twelve months, amounts to less than $800 a month. The company’s lobbying operation is modest by Fortune 500 standards, but its wealth extraction machinery is not: the gap between what the CEO collected and what the person folding lotion sets on a retail shelf took home is among the starkest findings in this sector.
Spending to Stay in the Room
Bath & Body Works spent $390,000 on federal lobbying from Q3 2024 through Q2 2026, filing with both the House of Representatives and the Senate across the two-year period, according to Senate Lobbying Disclosure Act (LDA) disclosures. That averages roughly $49,000 per quarter — not enormous by Washington standards, but steady and purposeful. During that span, lobbyists filed contacts with the House and Senate 41 times each — roughly once every 12 business days for each chamber.
FEDERAL CONTACT LOG
HOUSE OF REPRESENTATIVES
41
≈ every 12th business day
SENATE
41
≈ every 12th business day
2 federal bodies named in federal lobbying filings · 2024-Q3–2026-Q2
Between 2024-Q3 and 2026-Q2, Bath & Body Works was named in lobbying filings reaching 2 federal bodies — from HOUSE OF REPRESENTATIVES to SENATE.
The issue portfolio reads like a map of Bath & Body Works’ most pressing business risks. Lobbyists filed eight disclosures each on chemicals and chemical industry concerns, law enforcement and organized retail crime, trade and tariff policy, and consumer safety and products — and seven on taxation. The chemicals docket is not abstract: Bath & Body Works sells candles, soaps, and personal care products loaded with fragrance compounds and synthetic ingredients that sit squarely in the crosshairs of federal chemical management regulation. Any tightening of rules on what can go into a three-wick candle or a hand sanitizer directly threatens the company’s supply chain and product formulations.
On organized retail crime, lobbyists filed under law enforcement and crime, citing both the Combating Organized Retail Crime Act of 2023 — introduced in the House as H.R. 895 and in the Senate as S. 140 — each referenced twice in filings. These bills, still in progress at last filing, would create a federal task force and new criminal penalties targeting coordinated shoplifting rings. For a specialty retailer with hundreds of mall-based stores, shrink from organized theft is a real margin problem, and the company’s lobbyists made sure Congress heard about it across multiple quarters.
Trade and tariff filings tracked issues of international trade and tariff policy — a direct signal of Bath & Body Works’ exposure to import costs on raw materials and finished goods sourced outside the United States. Lobbyists also filed under consumer issues and data privacy, reflecting the retail industry’s broad concern about state-level and federal privacy legislation that would reshape how companies collect and use customer data from loyalty programs and digital storefronts.
The taxation docket cited domestic manufacturing tax incentives and, explicitly, An act to provide for reconciliation pursuant to title II of H. Con. Res. 14 — the legislation that became Public Law 119-21 on July 4, 2025. Lobbyists cited this bill across the chemicals, law enforcement, trade, consumer, and taxation dockets simultaneously, referenced three times across filings, making it the single most cited legislation in Bath & Body Works’ disclosures during the period. The bill was enacted — meaning lobbyists were engaged on live legislation with real stakes as it moved through Congress.
Rail safety appeared in early filings covering Q3 and Q4 of 2024, citing the Railway Safety Act of 2023 (S. 576, still in progress) and the RAIL Act (H.R. 1633, still in progress). A fragrance retailer lobbying on rail safety may seem out of place, but it reflects supply chain reality: Bath & Body Works moves product through freight rail, and major derailments involving hazardous materials put the entire retail sector on notice about logistics vulnerability.
Bath & Body Works hired two outside lobbying firms, including OGR, which also lobbies for AT&T and Tapestry Inc — giving that vendor a direct window into the priorities of multiple large corporate clients at once.
Shared Lobbying Exposure
Bath & Body Works
client
OGR
lobbying firm
AT&T
also a client
Tapestry Inc
also a client
Why it matters: the same firm argues Bath & Body Works’s case and its rivals’ — one hire buys a web of shared access that can’t be seen from outside. This network worsens Bath & Body Works’s political-access score (see methodology for the exact factor).
The company runs no corporate PAC, and Federal Election Commission (FEC) records confirm zero PAC spending for the period. Executive donations of $3,500 to federal campaigns are on record — a negligible sum. The political access footprint here is the lobbying spend, not campaign cash.
Two of Bath & Body Works’ lobbyists previously held senior government positions, according to Lobbying Disclosure Act (LDA) filings. Jennifer Daulby served as Chief of Staff to Rep. Rodney Davis and in multiple House counsel and legislative roles. Stanton Bullock served as Chief of Staff to Senator Daniel Moynihan. These are not entry-level congressional staffers — they are people with direct relationships inside the committees and leadership offices that write the rules Bath & Body Works is paying to influence.
A $10.7 Million CEO Package, a $9,603 Median Worker, and $802 Million for Wall Street
The single most damaging number in this profile is not the lobbying spend. It is this: the median Bath & Body Works employee earned $9,602.99 in the most recently reported fiscal year, according to the company’s own SEC DEF 14A filing. That is not a yearly salary for a comfortable life — that is $800 a month before taxes, the kind of paycheck that forces workers to choose between rent and groceries.
Against that figure, the CEO pay ratio stands at 1109:1, the 3-year average of Compensation Actually Paid, as disclosed in the same SEC DEF 14A. The CEO’s three-year average package was about $10.7 million. The person at the top of the corporate structure collected — averaged across three years, accounting for equity payouts as they actually landed — more than eleven hundred times what the person at the bottom of the payroll received. That is not a rounding error. That is a structural decision about whose labor the company values.
The Shareholder Payout. In fiscal years 2024 and 2025 combined, Bath & Body Works spent $802 million buying back its own stock, according to SEC 10-K filings. Each buyback is a deliberate reduction in shares outstanding that inflates per-share metrics and triggers executive performance bonuses — a mechanism that overwhelmingly benefits the wealthiest shareholders and the executives whose bonuses are tied to earnings-per-share targets. Over the same two fiscal years, the company paid out an additional $344 million in dividends. Combined, that is $1.146 billion channeled to capital owners in just two fiscal years — all while the company generated $7.29 billion in annual sales.
The Missed Raise. The company’s SEC proxy filing does not disclose total employee headcount — which means a precise per-worker raise calculation cannot be computed. What can be said plainly: $802 million in buybacks over two fiscal years is a deliberate choice. That money existed. It was real cash. The company decided to use it to reduce its share count rather than increase earnings for the workers whose labor generated it.
The Dividend Factor. Bath & Body Works did not abandon traditional investor payouts in favor of buybacks — it ran both simultaneously. The company paid $177 million in dividends in fiscal 2024 and $167 million in fiscal 2025, on top of $401 million in buybacks each year. That means the company’s leadership chose to operate two parallel shareholder return programs at the same time. The data shows they were not forced to choose between investors and workers — they simply prioritized the former.
Executive Bonuses. The buyback program and the CEO pay gap are not unrelated. When Bath & Body Works buys back its own stock and reduces the number of shares outstanding, earnings per share rises automatically — even if total company earnings stay flat. Many executive compensation packages tie performance bonuses directly to Earnings Per Share (EPS) growth. The same executives who approved the $802 million in buybacks are the same executives whose pay packages benefit when those buybacks cause per-share metrics to climb. The 1109:1 ratio is not just a gap — it is the output of a system the executives at the top designed and then ran.
One OSHA Fine — and $802 Million Speaks Louder
Bath & Body Works carries a single recorded federal violation over the two-year tracking period from Q3 2024 through Q2 2026: a 2024 workplace safety penalty of $6,913 issued by OSHA, according to Good Jobs First. The full details of the case on record show one agency, one year, one incident — this is not a pattern of serial regulatory infractions.
But context matters. That $6,913 penalty — the kind of fine OSHA issues for a serious safety violation — represents what a federal agency extracted from a $7.29 billion company for putting a worker at risk. The ratio of buyback spending to the total penalty paid sits at roughly 116,013 to one. At this scale, the fine is not a deterrent — it is a rounding error on the balance sheet.
Bath & Body Works ranks fourth out of five companies in its sector for total fines — meaning it has one of the lowest recorded penalty totals among its Health and personal care retailers peers. That is, on its face, a point in the company’s favor. This two-year window is a fraction of the company’s full docket on the source site. No public subsidy data is recorded for Bath & Body Works, so no public-money-versus-fines contrast is available here.