The Sam’s Club NOligarchy Profile
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V
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NOligarchy Score
14.9
/ 100
samsclub.com
0
Ranked in
Warehouse Clubs
#3
Home Appliance Retailers
#7
Pharmacy & Drugstore Chains
#11
Grocery & Supermarkets
#13
Subsidiary of Walmart Inc
Sam’s Club, the membership warehouse chain operated by Walmart Inc, scores 14.35 out of 100 on the NOligarchy scale — placing it among the most accountable-deficit companies in its sector. The data below covers Q3 2024 through Q2 2026 (8 quarters — the two-year tracking period), drawing on federal lobbying disclosures inherited from its parent company, executive pay filings, and regulatory enforcement records.
Current Pillar Scores
Political Access and Wealth Extraction include disclosures reported at the Walmart Inc (parent company) level. Playing by the Rules reflects this company directly.
Political Access
10.4
Wealth Extraction
27.2
Playing by the Rules
3.4
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.
The Pillar Grades:
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Political Access Grade: 10.39/100. Sam’s Club operates under Walmart Inc’s lobbying and Political Action Committee (PAC) umbrella. Walmart spent $17.89 million on federal lobbying and channeled an additional $2.18 million through its PAC over the covered period — a combined political footprint that drags this grade to one of the lowest in the sector.
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Wealth Extraction Grade: 26.8/100. No stock buybacks or dividends are recorded for Sam’s Club directly, but the executive pay gap embedded in Walmart’s corporate structure is severe: the CEO earned 1,965 times what a median worker took home, by the best available measure.
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Playing by the Rules Grade: 1.48/100. $130.1 million in regulatory fines and penalties across 56 cases — including a $100 million Federal Trade Commission (FTC) action — leaves this grade barely above zero.
The Sector Context: Sam’s Club ranks 20th out of 21 companies sharing the warehouse clubs, supercenters, and other general merchandise retailers federal industry classification — the grouping our scoring uses for sector baselines. The sector average is 54.0; Sam’s Club scores 14.35, roughly one-quarter of that benchmark. For higher-scoring alternatives, see the Better Alternatives section below.
Fined $100 Million for Wage Violations While the CEO Earned a Median Salary Before Breakfast
The clearest signal in the Sam’s Club data is not any single number — it is the gap between what the company chose to take and what it chose to leave behind. Walmart’s lobbying machine spent nearly $18 million knocking on doors in Washington to shape the rules governing the business Sam’s Club runs. At the same time, Sam’s Club and its parent racked up $130 million in regulatory penalties over the two-year period — with more than $100 million of that coming from a single FTC enforcement action tied to worker pay. Meanwhile, a median Sam’s Club employee earned so little that the company’s chief executive matched that annual paycheck in the first hour of the first workday of the year.
$20.1 million in political spending
Statue of Liberty · 151 ft
0.5×
Stacked as $100 bills, Sam's Club's $20.1 million in political spending rises 72 feet — 0.5× the height of the Statue of Liberty (the statue alone, 151 ft).
Walmart’s Lobbying Machine Powers Sam’s Club’s Washington Presence
Sam’s Club does not file its own federal lobbying disclosures — it operates under the Walmart Inc corporate umbrella, and all political influence spending flows from that parent structure. That does not make the spending any less real for the business Sam’s Club runs.
Across Q3 2024 through Q2 2026, Walmart’s registered lobbyists filed disclosures totaling $17.89 million in federal lobbying expenditures — that is $17.89 million deployed to put company representatives in rooms with lawmakers and regulators. To put that in terms a Sam’s Club associate could recognize: it is the equivalent of roughly 1,100 full-time workers earning $16,000 a year, spent entirely on access.
Federal Lobbying Spend by Quarter
$17.9M total
$1.9M
Q3 '24
$1.7M
Q4 '24
$2.3M
Q1 '25
$2.8M
Q2 '25
$1.8M
Q3 '25
$1.8M
Q4 '25
$3.5M
Q1 '26
$2.2M
Q2 '26
The spend accelerated sharply in 2025, climbing to $8.64 million for the year before settling at $5.69 million in the first half of 2026. On top of federal lobbying, Walmart’s PAC distributed $2.18 million to political candidates and party committees. Senior executives also contributed $50,743 directly to federal campaigns through the Federal Election Commission (FEC)-tracked contribution system.
No outside lobbying firms are recorded, and no former government officials appear on the registered lobbyist roster. The influence machinery here is built in-house and deployed at scale — the scale of America’s largest private employer.
A CEO Who Earns the Median Worker’s Year Before the Morning Coffee Break
Sam’s Club’s CEO pay ratio is not separately disclosed — the company is a private subsidiary of Walmart. The best available figure, drawn from Walmart’s SEC DEF 14A, is 1965:1, the 3-year average of Compensation Actually Paid. The CEO’s three-year average package was about $38.8 million against a median worker’s annual earnings. Sam’s Club is not required to publicly disclose its own CEO pay ratio separately from its parent.
CEO — MEDIAN-PAY MARKER
JANUARY
9:00
10:00
10:04 AM — a median year, earned
11:00
passes the median employee’s full annual pay
10:04 AM · January 1
1,965× the median employee’s pay
At 1965:1, Sam's Club's CEO earns the median employee's entire annual pay by 10:04 AM on the first workday of the year.
What that ratio means in plain terms: while a median Sam’s Club employee worked through an entire year to earn their paycheck, the person running the enterprise at the top of the corporate structure earned the equivalent in a single morning. Every hour of every workday represents what a typical associate earns in months.
No stock buybacks and no dividend payments are recorded for Sam’s Club over the covered period. That means no pre-computed per-worker raise calculation applies here — the wealth extraction concern in this profile is concentrated entirely in the pay structure at the top, not shareholder distributions. The absence of buyback and dividend data reflects the limits of what is publicly disclosed for a private subsidiary rather than a confirmed finding of shareholder restraint at the Walmart parent level.
$130 Million in Fines — and Still Collecting Government Checks
Sam’s Club’s regulatory record over the two-year tracking period is defined by volume, severity, and pattern. Across 56 documented cases, regulators and courts imposed $130.1 million in penalties — a total that ranks third-worst among the 21 companies in this sector. These are not scattered, unrelated incidents. They cluster into recognizable offense categories that repeat across years.
The single largest category is wage and hour violations, which account for $104.8 million — more than 80% of the entire penalty total — across just five cases. The dominant case is a 2026 FTC enforcement action carrying a $100 million penalty for wage and hour violations. That is a penalty equal to roughly $1.36 for every Sam’s Club member in the United States — paid not to workers directly, but to the federal government for breaking rules designed to protect workers.
Beyond wages, the FTC issued a separate $10 million consumer protection penalty in 2025. A 2024 California hazardous waste enforcement action added $7.5 million. And 30 separate workplace safety and health violation cases — the single largest case count of any offense category — together resulted in $555,796 in fines over the period. Thirty cases in two years in workplace safety alone is not an accident; it is a frequency that describes routine conditions.
WORKPLACE SAFETY OR HEALTH VIOLATION
30 SEPARATE CASES
2024–2026 · $555,796 in penalties
30 separate workplace safety or health violation penalties in 2024–2026 — Sam's Club paid $555,796 for the same category of offense, case after case.
While regulators were issuing those penalties, state and local governments were simultaneously handing the company public money. Across 2024 and 2025, Sam’s Club and its Walmart affiliates received $12.4 million in public subsidies across nine recorded grants. The single largest was $8 million from Texas in 2024, followed by $1.85 million from New York in the same year. Public funds flowed in one door while enforcement penalties went out another.