The Sears Holdings Corporation NOligarchy Profile
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Sears Holdings Corporation scores 62.67 out of 100 on the NOligarchy scale — where 100 represents a company with zero measurable footprint in political influence, executive excess, or regulatory misconduct. That score is driven sharply downward by a single massive adjudicated event: a $3.646 billion extraction and settlement that collapses the Wealth Extraction pillar to zero and tells a story about how enormous sums of money were moved — away from creditors and workers — by the same ownership that steered this company into collapse.
Current Pillar Scores
Political Access
100.0
Wealth Extraction
0.0
Playing by the Rules
78.4
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.
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Political Access Grade: 100/100. No lobbying dollars. No Political Action Committee (PAC) contributions. No executive donations to federal candidates. From Q3 2024 through Q2 2026 (8 quarters — the two-year tracking period), Sears Holdings Corporation spent nothing to shape federal policy. One former government insider appears on the lobbying roll, but no money moved.
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Wealth Extraction Grade: 0/100. An adjudicated $3.646 billion extraction and settlement event — documented in the Seritage Growth Properties 2022 annual report and traced to conduct originating in 2015 — drives this score to the floor. Add an industry-benchmark CEO pay gap estimate of 552:1 and a complete absence of public financial disclosures, and the picture of how money flows inside this organization is both stark and largely unverifiable.
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Playing by the Rules Grade: 78.37/100. Two Occupational Safety and Health Administration (OSHA) workplace safety violations at Kmart locations in 2025, totaling $15,255 in penalties, mar what had previously been a clean regulatory docket.
Sears Holdings Corporation ranks 6 out of 7 among companies sharing its federal industry classification (Department stores), trailing a sector average NOligarchy score of 73.4. This company sits below the industry baseline — not because it is an active political spender or aggressive share repurchaser, but because the adjudicated wealth extraction event carries full scoring weight and drags the overall grade well below its peers. Because the score falls below 50 on the Wealth Extraction pillar alone, readers looking for higher-scoring alternatives in this sector should see the Better Alternatives section below.
The $3.6 Billion Question: Who Got Paid When Sears Fell Apart
The sharpest imbalance in this profile has nothing to do with lobbying or stock buybacks. It is a $3.646 billion extraction and settlement — an amount larger than the entire annual revenue of most mid-sized retailers — adjudicated and documented in connection with conduct originating in 2015, when Sears was still operating at significant scale. To put $3.646 billion in human terms: at the federal minimum wage, it would take a single full-time worker more than 240,000 years to earn that sum. The money moved. The workers whose jobs evaporated when Sears locations closed did not see it. That gap — between the billions extracted and the nothing left behind — is the defining fact of this company’s recent history.
No Active Footprint in Washington
Sears Holdings Corporation — now operating under the registered lobbying name Transform SR Holdings LLC — filed no substantive federal lobbying activity and ran no corporate PAC from Q3 2024 through Q2 2026. The Senate Lobbying Disclosure Act (LDA) filings show zero dollars spent. Federal Election Commission (FEC) records show no individual contributions tied to the company. No outside lobbying firms were retained.
One detail is worth noting: one of the eight lobbyists listed on the company’s filings — David Heil — previously served on the staff of Congressman Sam Johnson. That revolving-door hire signals that the infrastructure for political access exists, even if no money flowed through it during this period. No issue areas, no referenced legislation, and no government entities were approached in any substantive capacity across the full two-year span.
EXHIBIT — THE RESERVED SEAT
$0 in lobbying · $0 in PAC money
Sears Holdings Corporation filed no federal lobbying and ran no corporate PAC in this window — the reserved seat at the witness table sits empty.
$3.6 Billion Out the Door — Workers Got Nothing
The number that defines this profile is $3,646,500,000 — an adjudicated extraction and settlement event traced to conduct in 2015 and formally documented in the 2022 annual report of Seritage Growth Properties. This is the figure the scoring system treats at full weight. It reflects the movement of enormous wealth through a corporate structure controlled by the same ownership group — ESL Investments, Inc. — that presided over Sears’ collapse. The people who stocked the shelves, ran the registers, and serviced the appliances were not on the receiving end of that transaction.
Because Sears Holdings Corporation is private and carries no obligation to file executive compensation disclosures with the Securities and Exchange Commission (SEC), no confirmed CEO pay ratio exists. The best available figure is 552:1, based on AFL-CIO Executive Paywatch industry benchmarks for comparable companies in this sector. That is the only signal the data can offer about how pay is distributed internally — meaning, by industry norms, the person at the top likely takes home 552 times what a frontline worker earns. No stock buyback or dividend data is recorded for Sears Holdings Corporation, and no shareholder payout figures appear in any public source, because none are required.
Two OSHA Citations and a Kmart Paper Trail
Over the two-year tracking period, two OSHA workplace safety violations were recorded against Kmart locations operating under the Sears Holdings Corporation umbrella, both in 2025. The total in penalties: $15,255 — a figure so small it would not register as a rounding error in a large company’s legal budget. The first citation carried an $8,765 penalty; the second came in at $6,490. Both were workplace safety or health violations, both issued by OSHA, and both point to the reality that even a company in advanced operational retreat still has workers — and still has obligations to keep them safe.
These two cases represent the entirety of the company’s recorded regulatory infractions over this period. No public subsidies are recorded for Sears Holdings Corporation during the same span, so there is no public-money-versus-violations contrast to draw here. The Good Jobs First violations tracker covers the company’s full historical record well beyond this two-year window — this snapshot is a narrow slice of a much longer docket.