SASB: CG-AA-430b.3
GRI: 2-25; 2-26; 3-3; 409-1
UN SDG: 8 F
S G | Published: April 20, 2023

A female Walmart associate smiles at the camera while hanging a shirt in the Men's section.

Our Aspiration

We respect human rights and seek to use our scale, capabilities and influence to help people and communities improve their lives, with a focus on our salient human rights issues.

Relevance to Our Business & Society

Our business is a people business: we employ approximately 2.1 million people, approximately 240 million people shop with us weekly across 20 countries, and people work for the tens of thousands of suppliers that make the products we sell.

Walmart believes business has a responsibility to respect human rights. We are committed to respecting human rights in our own operations and to holding our suppliers accountable for respecting the human rights of the people who make the products we source and sell.

Beyond respect, we believe Walmart’s business thrives when our associates, people in our supply chain, customers, and our communities thrive.

Walmart’s Approach

We strive to use our position as an employer, retailer, and community member to promote respect for human rights. The U.N. Guiding Principles on Business and Human Rights recognize four essential components of an effective human rights due diligence program. Walmart’s approach to human rights due diligence reflects those components: we assess actual and potential human rights impacts, integrate and act upon the findings of our assessments, track the effectiveness of our response to human rights impacts, and communicate how impacts are addressed.

Walmart’s human rights program includes:

  • Our Human Rights Statement, which is grounded in Walmart’s values and serves as the foundation of our approach to human rights; it confirms our commitment to respect human rights;
  • Governance, including appropriate oversight by management and the Walmart Board of Directors;
  • Identification of salient human rights issues and focus areas relevant to our business; and
  • Effective management of salient human rights issues through policies, stakeholder engagement, assessing impacts, integration of findings, performance tracking, and addressing concerns, including through remediation where required.

Walmart focuses its efforts on its identified salient human rights issues:

Salient Human Rights Issues

Treating Workers with Respect
  • Pay; working hours
  • Freedom of association and collective bargain-ing
  • Meaningful opportuni-ties for workers to be heard
Promoting a Safe & Healthy Work Environment
  • Physical safety and security of work prem-ises
  • Workplace abuse
  • Healthy work environ-ments
Providing a Fair & Inclusive Work Environment
  • Anti-discrimination and harassment
  • Diversity and inclusion
  • Gender equity
Combating Forced & Underage Labor
  • Forced labor, including debt bondage
  • Vulnerability of migrant workers; responsible recruitment
  • Human trafficking

Details on our approaches to these issues are discussed below.1

Key Strategies & Progress

Human Rights Commitment & Governance | Focus Areas | Salient Issue Management: Operations | Salient Issue Management: Supply Chains

Human Rights Commitment & Governance

Human Rights Commitment and Salient Issues

Our Human Rights Statement serves as the foundation of our robust human rights efforts. It confirms Walmart’s respect for human rights and articulates how our culture and values, as well as international instruments—including the U.N. Universal Declaration of Human Rights, the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work and the U.N. Guiding Principles on Business and Human Rights—guide our approach to human rights due diligence. The statement is posted alongside other foundational policies on the company’s website and has been shared with associates, suppliers, and other stakeholders. The principles set forth in the Human Rights Statement have also been embedded in our Code of Conduct (applicable to Walmart associates) and Standards for Suppliers (applicable to Walmart suppliers).

The Statement and Walmart's list of salient human rights issues were developed by a working group comprised of leaders from Walmart's associate relations, communications, diversity and inclusion, ethics and compliance, government affairs, human resources, legal, responsible sourcing, and sustainability functions. In preparing the Statement and salient issues list, the working group:

  • Reviewed a variety of international instruments including, but not limited to, the U.N. Universal Declaration of Human Rights, the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work, and the U.N. Guiding Principles on Business and Human Rights;
  • Reviewed stakeholder feedback from research and consultations;
  • Obtained and incorporated feedback from human rights subject matter experts and rightsholder representatives and considered analysis of Walmart conducted by a number of third parties;
  • Reviewed the work of other companies, both those in our peer industry group and those that are considered leaders in human rights, to understand and compare their approach to ours; and
  • Assessed our potential human rights risk areas.

The Statement was approved by a steering committee of officers from the same corporate functions and the Walmart Board of Directors.

Embedding Respect for Human Rights

Board and Management Oversight of Human Rights Issues

The Walmart Inc. Board of Directors and Board committees actively oversee and monitor the management of the most significant human rights issues relevant to our company. The Nominating and Governance Committee of the Board is responsible for overseeing Walmart's environmental, social, and governance agenda, including our overall approach to human rights, and receives updates on these initiatives from Walmart's Chief Sustainability Officer. Board committees are also charged with oversight of salient human rights issues and mitigating human rights impacts. For example:

  • The Compensation and Management Development Committee oversees the company's human capital management strategies and programs, including pay, benefits, talent attraction and retention, associate relations and engagement, and diversity, equity, and inclusion.
  • The Audit Committee oversees the company's ethics and compliance programs, which include health and safety, discrimination and harassment, and responsible sourcing; it also oversees the company's Enterprise Risk Management process, which covers human rights generally as well as specific human rights issues.
  • The Nominating and Governance Committee oversees the company's strategies and programs relating to social, community, and sustainability issues.

Salient human rights issues are often a topic of Board Committee discussion. Examples in 2021 and 2022 include:

  • Compensation and benefits strategies and plans, including continued investments in wages, benefits, and training and pay equity;
  • The company's diversity, equity, and inclusion strategies and programs, as well as gender and racial/ethnic representation at various levels of the company;
  • Ethics and compliance program; and
  • Overall updates on our ESG priority issues, including human rights.

Walmart established a cross-functional human rights working group to support teams in advancing respect for human rights through our business. The company also established an ESG Steering Committee comprised of Walmart officers leading the functions relevant to our ESG priority issue set (including human rights), which receives updates on our human rights priorities and initiatives in order to ensure alignment on cross-functional human rights matters.

Additionally, Walmart identifies, assesses, and assigns responsibility for managing issues raised in its annual enterprise risk management process, which includes topics related to salient human rights issues.

Communicating Expectations

Walmart associates and suppliers—who are responsible for taking action to respect human rights within their spheres of responsibility and influence—are informed of our human rights positions and expectations through the dissemination of our Human Rights Statement, incorporation of principles into our foundational policies and standards, and through training and awareness on those policies and standards.

Digital and physical signage in Walmart Home Office showing Walmart's Core Values and advertisements for Bike-to-Work programs.

Associates—Basic Beliefs, Code of Conduct, Policies, and Training

Walmart's culture is grounded in four core values: respect for the individual, service to the customer, striving for excellence, and acting with integrity. These values guide our policies, practices, and decision-making, and are continually reinforced, including through leadership communications, team meetings, signage, and training. We believe that human rights are respected as our behaviors align with these values.

Walmart's Code of Conduct is the foundational document that translates our values into standards and expectations for our associates and the Walmart Board of Directors. The Code:

  1. Reiterates Walmart's commitment to respect human rights
  2. Sets foundational expectations on each of our salient human rights issues
  3. Explains when to speak up and how to speak up, and provides a prohibition against retaliation for speaking up
  4. Requires compliance with other applicable policies and our Standards for Suppliers

We maintain robust policies and procedures, which help to clarify expectations regarding our salient human rights. Policies relevant to our salient human rights issues are further described below.

Educating associates on expectations and keeping our salient human rights issues top-of-mind through tailored, effective training support a culture of respect for human rights. Walmart conducts training for all levels of the company, from frontline store associates to the Board of Directors. Training topics include our Code of Conduct, as well as salient human rights issues such as physical safety and security and discrimination and harassment. Additional relevant topics, such as freedom of association, labor compliance, and responsible sourcing are communicated to a more tailored audience. Training is supplemented by communication campaigns to keep the concepts top-of-mind. Walmart associates receive ethics training during onboarding and regularly thereafter. In FY2023, more than 1.4 million associates received Code of Conduct training.

Suppliers—Standards for Suppliers, Policies, Training, and Communication

Walmart’s expectations of suppliers are set out in our Standards for Suppliers, which are embedded into our supplier agreements and apply to all suppliers that sell their products to us for resale or for Walmart’s own use. Suppliers are provided with the Standards at onboarding and are expected to cascade the requirements outlined in our Standards for Suppliers throughout their supply chains—including raw material, component or ingredient suppliers, and subcontractors and agents.

Walmart may issue and communicate more specific requirements as a condition of sourcing when doing so would help to mitigate acute risks to human rights; for example, we have issued and communicated specific policies relating to supply chain transparency expectations and safety in Bangladesh. Beyond general publication, we engaged in targeted communication about these updates with strategic suppliers and suppliers in riskier geographies.

Walmart merchandising and sourcing associates are trained on our Global Responsible Sourcing Compliance Policy, our Standards for Suppliers, and our Responsible Sourcing expectations on an ongoing basis. This training introduces new merchants to the Responsible Sourcing program while updating understanding for experienced merchants. Walmart associates then provide references and resources to suppliers to clarify expected practices. Walmart associates also provide individual guidance, including when suppliers or merchants reach out with questions or when audit results are shared with suppliers.

Beyond compliance, we engage our suppliers to take specific actions where we believe human rights risks may be more acute. For example, we may ask certain suppliers to adopt and report on responsible recruitment practices [CL5474], ask suppliers in the North American produce corridor to adopt the Ethical Charter (see chart below), and have set certification targets for certain commodities (e.g., cotton, palm oil) to help ensure key human rights issues can be addressed. As discussed below, we also pursue strategies in collaboration with others to address systemic risk to human rights in global product supply chains.

Human Rights Focus Areas

As discussed above, Walmart identified its salient human rights issues—including key aspects of those issues—based on consultations with human rights and issue area experts, stakeholder consultations, risk management and grievance data, and peer benchmarking. The issues identified are relevant both for Walmart's operations and supply chain.

We consider three factors across our salient issue set to determine where to focus our efforts within our business and supply chains:

  • Connection between the issue and Walmart's core business activities. For example, an issue's close connection to Walmart's ability to attract and retain talent or source products heightens its relevance.
  • The nature, severity, and prevalence of the issue and the current state of practices with respect to the issue. For example, forced labor is a significant infringement of human rights, can be prevalent in key geographies and supply chains, we believe current practices to mitigate forced labor risks are less mature than those used to address other issues; and certain populations, including minority groups, children, women, migrants, and indigenous people, are more vulnerable than others.
  • Walmart's opportunity to have an impact through the deployment of business and philanthropic assets and capabilities.

We assess the nature, severity, and prevalence of human rights issues through a number of means, including:

  • Ethics, Open Door, and associate engagement data and insights: These data and insights can reveal gaps, trends, and emerging areas of focus.
  • Responsible Sourcing audit and case management data and findings: We review data from thousands of audits and hundreds of cases per year. In financial years 2022 and 2023 we reviewed data from approximately 13,000-14,000 annual third party social audits and approximately 700-800 cases and investigations.
  • Internal analyses and progress reporting: Walmart assesses risks to our business and to people through various means, including our Enterprise Risk Management process, Responsible Sourcing risk assessment, diversity and inclusion measurement and reporting, and pay equity analyses.
  • Prevalence studies and external analyses: We consult external resources, including studies produced by NGOs, governmental agencies, and industry groups such as the U.S. Department of State Trafficking in Persons Report, World Bank Governance Indicators, Verité Forced Labor Commodity Atlas, the Leadership Group on Responsible Recruitment findings, McKinsey's Women in the Workplace and Race in the Workplace reports, and Seafood Task Force data. Often, however, data do not always exist to provide sufficient direction on where to focus efforts or the types of interventions necessary to have an impact. The Walmart Foundation has commissioned studies and tools, including the first comprehensive study documenting the prevalence of forced labor on Thai fishing vessels.
  • Stakeholder engagement: Stakeholder engagements like those described above help us obtain new insights, spot emerging issues, and confirm focus areas.

Management of Salient Issues: Walmart's Operations

We help advance respect for human rights relevant to our associates by:

  1. Setting expectations through policies, procedures, and standards
  2. Engaging stakeholders and assessing their feedback, insights, and concerns
  3. Designing and implementing strategies to address an issue and relevant underlying systems

Example strategies relevant to our salient human rights issues are set forth below. For additional details, please see our ESG disclosures on Human Capital: Good Jobs & Advancement for Associates, Equity & Inclusion at Walmart & Beyond, and Ethics & Compliance.

Policies and Standards

Walmart's Code of Conduct is the foundational document that translates our values into standards and expectations for our associates and the Walmart Board of Directors. The Code sets foundational expectations regarding each of Walmart's salient human rights issues as relevant to our business and requires compliance with other applicable policies. For example, the Code specifically addresses:

  • Pay and working hours
  • Freedom of association
  • Health and safety
  • Violence and threats
  • Discrimination and harassment
  • Forced labor
  • Sourcing responsibly
  • Speaking up and access to grievance

Robust internal and external policies and procedures help to clarify expectations regarding salient human rights. Examples include:

  • Treating workers with respect: Pay policies (overtime, family care, holiday, etc.); Open Door Communications Policy
  • Promoting a safe and healthy work environment: Global Environmental, Health and Safety Policy; Safety & Health in the Workplace Policy; Violence-Free Workplace Policy; COVID-19 leave and vaccination policies; Associate Work-Related Injury Policy; Occupational Safety and Health Act Policy
  • Providing a fair and inclusive work environment: Global Discrimination & Harassment Prevention Policy; Global Labor & Employment Policy; Workplace Gender Transition Guidelines
  • Combating forced and underage labor: Conflict Minerals Policy, Global Forced Labor Prevention Policy; Global Responsible Sourcing Compliance Policy; Associate Pay Policy; Minors in the Workplace Policy

Stakeholder Engagement

Feedback and insights we get from stakeholders—including Walmart associates, civil society organizations, customers, and communities—shape our approaches to managing salient human rights issues.

Two Walmart associates share a laugh while restocking shelves in the toy department.

Walmart Associates

Listening to our associates has been core to Walmart's culture since Sam Walton founded the company. We have created a continuous ecosystem of listening that actively solicits associate questions, concerns, feedback, and ideas; makes it simple for associates to provide feedback; and ensures accountability and responsiveness. For more, see Human Capital: Good Jobs & Advancement for Associates.

We have a variety of channels and systems for engaging associates, whether on concerns, innovative ideas, development, or other topics. These channels provide useful insight into our salient human rights issues, including through:

  • Direct interactions between associates, their managers, and company leaders
  • Periodic formal Associate Engagement Surveys
  • Associate engagement pulsing surveys
  • Walmart’s Open Door policy and process, which allows any associate to raise concerns, share ideas, and ask questions without fear of reprisal
  • Our Ethics channels, including a hotline, website, and email address

We seek to make it as easy as possible to engage on human rights and other issues through these channels. For example, Walmart designed and launched a digital portal called MyFeedback for US-based associates as an intuitive, self-service site where associates can share ideas, Open Door feedback, and ethics concerns in one place.

Finally, Walmart engages with labor unions in the countries in which Walmart associates are represented by some form of third party (10 of the 20 countries in which Walmart operates as of the end of CY2022). While Walmart continues to have interaction with associates in those locations, labor unions raise issues related to wages and working conditions through collective bargaining and ongoing dialogue.

Civil Society

Walmart and the Walmart Foundation have worked and engaged with rightsholder representatives and civil society organizations who are experts in their field to build knowledge and understand perspectives. Select civil society organizations with whom we have engaged on issues related to salient human rights include:

  • Retail Opportunity: Achieving the Dream, American Enterprise Institute, Aspen Institute Economic Opportunities Program, Brookings Institution, Center on Rural Innovation, Goodwill Industries International Inc., Markle Foundation, Southern Rural Development Center, and the Urban Institute
  • Equity and inclusion: The American Association of People with Disabilities, C2FO, OneTen Coalition, Operation Hope, PFLAG, Prison Fellowship, Second Chance Business Coalition, Welcoming America, and Women’s Business Enterprise National Council
Customers and Communities

As an omni-channel retailer with a physical presence in thousands of communities around the world, Walmart seeks to help those communities thrive. Our business success depends on meeting the needs and expectations of our customers, associates and other stakeholders by contributing to these communities in ways that create lasting value.

We use a variety of channels to solicit feedback from our customers. These include:

  • Focused research through surveys and in-person discussions
  • Social media engagement through managed Facebook, Twitter, LinkedIn and Instagram pages
  • In-person communication in our stores
  • Outreach through email and phone, including communication through our customer call centers

Our State and Local Government Relations and Community Relations teams are deployed geographically throughout the United States and—partnering with our operators in those communities—work with state and local government leaders, community leaders, and local organizations to help ensure our business meets community needs. Example issues on which these teams have collaborated with local leaders include disaster preparedness and response and vaccine distribution in underserved communities. Additionally, in 2023, Sam's Club hosted its first ever Day of Service further highlighting its ongoing commitment to communities.

Additionally, Walmart’s Constituent Relations team collaborates with organizations close to underrepresented and underserved communities on issues of mutual concern. For example, we have hosted stakeholder summits that bring Walmart together with partner organizations representing different constituent groups, including the National Urban League, UnidosUS, OCA National, National Congress of American Indians, Women Impacting Public Policy, Asian Americans Advancing Justice, LULAC, NAACP and DisabilityIN. We also discussed specific topics with community organizations. For example, the Constituent Relations team discussed COVID-19 vaccination issues with Asian-American and Pacific Islander, Latinx, and African-American organizations and institutions, leading Walmart to hold several COVID-19 vaccination events focused on underserved neighborhoods and groups and to develop a virtual toolkit in several languages.

Strategies for Addressing Our Salient Issues

Assessing Impacts and Risks

We assess the nature, severity, and prevalence of human rights issues through a number of means, including:

  • Ethics, Open Door, and associate engagement data and insights: These aggregated data and insights can reveal gaps, trends, and emerging areas of focus.
  • Internal analyses and reporting: Walmart assesses performance and progress through various means, including our Enterprise Risk Management process, diversity and inclusion measurement and reporting, pay equity analyses, and deeper dives into risks in particular areas of the business (e.g., fresh food manufacturing).
  • Prevalence studies and external analyses: We consult external resources, including studies produced by civil society, government agencies, and industry groups. Where data do not exist to provide sufficient direction, Walmart and the Walmart Foundation have funded studies to help fill the gap. See, e.g., McKinsey & Company, Race in the Workplace: The Black Experience in the US Private Sector (February 2021). We then factor the results of these studies and consider opportunities for enhanced awareness or tailored initiatives.
  • Stakeholder engagement: Stakeholder engagements like those described above help us obtain new insights, spot emerging issues, and confirm focus areas.
Practices to Embed Respect for Human Rights

Based on the assessments and engagements noted above, we have created and enhanced practices to embed respect for salient human rights issues in our business. In each instance, we lead with our business, collaborate and use philanthropy to extend the societal impact of our initiatives, and advocate for an enabling policy environment. The below descriptions of practices are for illustrative purposes only; for additional details on our practices and initiatives, see our other ESG issue briefs including Human Capital: Good Jobs & Advancement for Associates; Equity & Inclusion at Walmart & Beyond; Ethics & Compliance; Disaster Preparedness & Response; and Engagement in Public Policy.

Example business practices:

  • Pay, benefits, and scheduling: Significant investments in wages (e.g., Walmart hourly associates earned 54% more per hour in FY2023 than in 2015) and benefits (paid time off for all associates in the U.S., low-cost medical coverage, retirement plan for all associates, parental leave, adoption benefits), maintaining approximately 70% of our associates in the U.S. as full-time, providing stable and flexible scheduling.
  • Diversity, equity, and inclusion: Robust efforts to enhance diversity and inclusion at all levels of the company; equitable hiring and advancement; pay equity across racial and gender lines (validated through pay equity analyses); advancing equity in society through Shared Value Networks (SVNs) focused on the U.S. criminal justice, education, finance, and health systems.
  • Associate listening: Maintaining associate feedback channels, including the ability to raise concerns anonymously; expanding access to channels through digital platforms; respecting freedom of association and collective bargaining.
  • Health and safety: Robust health and safety policies, training, and practices; auditing practices to ensure effectiveness; programs to prevent injury; disaster planning and preparedness to promote associate safety and well-being; enhancing policies and practices to keep associates and customers safe during the COVID-19 pandemic.
  • Discrimination and harassment: Code of Conduct and Global Harassment & Discrimination Prevention Policy to create a consistent understanding across Walmart's global markets; Discrimination and Harassment Prevention Plan including training, communication, and case handling guidelines.
  • Forced labor and human trafficking: Creating a Global Forced Labor Prevention Policy to prohibit worker-paid recruitment fees; leveraging Walmart's stores and fleet to raise awareness of human trafficking risks and resources for human trafficking victims; trafficking awareness training for drivers.

Collaboration and philanthropy:

  • The Walmart.org Economic Opportunity in Retail Initiative seeks to promote equitable advancement with a focus on America’s frontline talent. From 2015-2022 Walmart and the Walmart Foundation invested over $190 million to accelerate career mobility across the retail sector. Investments have included training for adult workers, building a skills-based hiring and advancement system, and promoting equity in hiring and advancement. Read more: Human Capital: Good Jobs & Advancement for Associates.
  • Walmart and the Walmart Foundation committed $100 million over five years to fund the Walmart.org Center for Racial Equity, which is focused on eradicating systemic disparities experienced by Black and African American communities in the U.S. The Center has invested $59 million as of January 2023 across the U.S. criminal justice, education, finance, and health systems. The center supports efforts such as research, advocacy, innovation of practices and tools, stakeholder convening and nonprofit capacity building. Read more: Equity & Inclusion at Walmart & Beyond.
  • We engage lawmakers, peers, and business associations to create a policy environment that promotes respect for human rights relevant to our operations, including advocating for an increase in the federal minimum wage, engaging in business collaboratives such as the Business Roundtable’s Multiple Pathways Initiatives and the Markle Foundation's Rework America Alliance to build a movement around skills-based mobility, and advocating for state and federal policies that would advance equity in criminal justice, education, finance, and health systems. Read more: Engagement in Public Policy.
A female Walmart truck driver laughs while standing in front of a colorful Walmart tractor trailer.
Truckers Against Trafficking

In the U.S., Walmart has incorporated training from Truckers Against Trafficking (TAT) that helps transportation professionals recognize and report suspected human trafficking incidents. Since 2019, TAT training has been a part of both the recurring driver training program and the new-driver onboarding process for our private fleet drivers. In FY2023, we completed TAT training for over 7,200 drivers on how they can combat human trafficking while operating their vehicles.

Tracking and Reporting Progress

We have tracked and publicly reported on our progress on salient human rights issues relevant to our operations. Examples include:

  • Pay, benefits, and scheduling: Year-over-year reporting on starting wage ranges, average hourly wages, benefits availability and participation, full-time/part-time ratios.
  • Diversity, equity, and inclusion: Twice annual reporting on representation and promotions, annual reporting on pay equity, annual public release of EEO-1 form.
  • Associate listening: Reporting on Associate Engagement Survey participation and third-party representation.
  • Ethics & Compliance (including health and safety, discrimination and harassment, and forced labor): Annual reporting on training and practices.
A smiling male Walmart associate shows a customer some back-to-school supplies.

Grievance and Remedy

As noted above, Walmart maintains channels for raising concerns and grievances; each has an associated process for addressing grievances.

  • Ethics: Channels include a hotline, website, and email address. These channels are confidential and associates can remain anonymous if they choose. Walmart strictly forbids retaliation against any associate who reports a concern in good faith. Cases may be referred to business units for follow-up, investigated by our Global Investigations team or another investigative unit, or escalated to our Legal Investigations Team for handling as appropriate. Violations of our Code of Conduct and ethics and compliance program policies can lead to discipline up to and including termination. Other remedial action taken as a result of violations can include a reduction of associates’ annual cash incentive payment, training and/or counseling, changing policies or procedures, or implementing additional processes or controls.
  • Periodic formal engagement surveys: Our confidential engagement surveys ask associates about their relationship with their manager and team, career growth and opportunities, belonging, inclusion, and company culture, among other issues. They also allow associates to submit open-text feedback. Approximately 1 million U.S. associates took part in the fall 2022 engagement survey and nearly 500,000 submitted open-text comments.
  • Open Door: Walmart’s Open Door policy and process allows associates to raise concerns, share ideas, and ask questions without fear of reprisal.

Additionally, legal grievance mechanisms exist in all locations where Walmart does business, including opportunities for Walmart associates represented by a third party to raise grievances through their representatives.

Management of Salient Issues: Supply Chain

We work across industries, geographies, and stakeholder groups to help advance respect for human rights in supply chains with a focus on our salient issues by:

  1. Setting expectations through policies and standards
  2. Engaging stakeholders and assessing their feedback, insights, and concerns
  3. Designing and implementing strategies to address the issue and relevant underlying systems

Example strategies relevant to our salient human rights issues are set forth below. For additional details, please see our ESG disclosures on People in Supply Chains, Product Supply Chain Sustainability, and Supplier Opportunity.

Aerial view of a small commercial fishing vessel anchored in calm, blue-green water.

Policies and Standards

Walmart’s Standards for Suppliers set forth Walmart's expectations on each of our salient human rights issues for product suppliers. The Standards are embedded into our supplier agreements and apply to all suppliers that sell their products to us for resale or for Walmart’s own use. Suppliers are provided with the Standards at onboarding and expected to cascade the requirements outlined in our Standards for Suppliers throughout their supply chains—including raw material, component or ingredient suppliers, and subcontractors and agents.

The Standards were last updated in October 2022. The standards include detailed expectations in certain areas where we believe human rights risks can be most acute, including forced labor (to make explicit Walmart's ban on worker-paid recruiting fees and requirement that suppliers repay them) and discrimination and harassment (to clarify that discrimination based on any listed characteristic or other protected status is prohibited). The Standards also clarify that suppliers are responsible for creating and maintaining risk management and grievance mechanisms and for following up on reports of violations of Walmart's standards.

Additionally, Walmart has developed more specific policies, standards, and expectations for suppliers on certain salient human rights issues where our assessments of impact and risk have indicated a more detailed approach is appropriate. For example:

  • Global Forced Labor Prevention Policy: Details the prohibition of any form of forced or trafficked labor anywhere in our own operations and supply chain.
  • Responsible Recruitment Expectations: Establishes expectations that suppliers implement responsible recruitment practices within their business operations related to hiring, recruitment fees, and the repayment of fees.
  • Bangladesh safety requirements: Facilities located in Bangladesh that fall within the Walmart Responsible Sourcing Compliance program disclosure scope are required to participate and be in good standing with a Walmart-approved safety initiative.
  • Supplier Requirements for Supply Chain Transparency: Sets requirements that suppliers document their production and procurement processes, maintain strong management systems for gaining supply chain transparency, and manage compliance in higher-risk upstream supply chains.
  • Conflict Minerals Policy: Outlines efforts to ensure product suppliers actively support Walmart’s conflict minerals compliance efforts.

The Responsible Sourcing program also includes disclosure and auditing policies to enable Walmart's risk monitoring program.

Stakeholder Engagement

Walmart engages with stakeholders—including workers in supply chains, rightsholders representatives, and civil society organizations—to get feedback, perspectives, and insights that help us better understand our salient issues and approaches to addressing them.

Workers in Supply Chains

Walmart has several mechanisms to hear from workers in supply chains and gain insights into their experiences. For example, Responsible Sourcing audits include worker interviews and must be conducted by an Association of Professional Social Compliance Auditors (APSCA)-registered auditor who has demonstrated competency and skill in interviewing workers to determine if suppliers are respecting human rights. These interviews are reflected in the audit reports we receive and review. Workers also contact us via our Ethics channels.

Walmart and the Walmart Foundation support studies and analyses that aim to improve understanding of the nature and prevalence of human rights issues in supply chains from workers' point of view. Examples include funding IJM to conduct a study on migrant labor in Thai seafood industry; an IOM study on migrant labor in Thailand and Malaysia; and a Wilson Center study on wages, working conditions, and recruitment in North America. Additionally, grantees participating in the Walmart.org Market Access program generated insights into the experiences of smallholders in Central America, India, and Mexico, which Walmart.org collected and published.

Civil Society

We have engaged in forums for the sharing of best practices and spurring collective action to help advance human rights in supply chains, including the Bali Process: Government and Business Forum and the Global Forum for Responsible Recruitment.

Additionally, Walmart and the Walmart Foundation have engaged with civil society organizations and rightsholder representatives on human rights issues, including:

  • Treating Workers with Respect: Woodrow Wilson International Center for Scholars; Stronger Together; and Avina Americas.
  • Promoting a Healthy and Safe Working Environment: FishWise; Nature Conservatory; and CIERTO.
  • Providing a Fair and Inclusive Work Environment: Equitable Food Initiative and Oxfam.
  • Combating Forced and Underage Labor: International Justice Mission; Global Fund to End Modern Slavery; LaMP; Issara Institute; Polaris; and the Responsible Business Alliance.

Strategies for Addressing Our Salient Issues

Assessing Impacts and Risk

We assess the nature, severity, and prevalence of human rights issues in supply chains through a number of means, including:

  • Responsible Sourcing audit and case management data and findings: We review data from thousands of audits and hundreds of cases per year. In financial years 2022 and 2023 we reviewed data from approximately 13,000-14,000 annual third-party social audits and approximately 700-800 cases and investigations.
  • Responsible Sourcing risk assessment and external analysis: Responsible Sourcing conducts regular risk assessments to better understand social compliance risks in the supply chain. This assessment analyzes Walmart's internal audit and case management data, along with publicly available data (e.g., US State Department's Trafficking in Persons Report and the World Bank Governance Indicators), to identify the likelihood of issues occurring in countries where Walmart has significant sourcing activity and/or retail operations. Where data do not exist to provide sufficient direction, Walmart and the Walmart Foundation have funded publicly-available studies to help fill the gap as described in the Workers in Supply Chains section of this brief.
  • Stakeholder engagement: Stakeholder engagements like those described above help us obtain new insights, spot emerging issues, and confirm focus areas.
A Hispanic woman in a gray shirt smiles from a row of orange trees, in front of baskets full or oranges.

Practices to Embed Respect for Human Rights

Walmart works with suppliers and others not only within the company's product supply chains but also beyond, to address systemic issues in industry supply chains (such as forced labor in Southeast Asia). The table below shows how Walmart combines sourcing and supplier engagement with philanthropic and industry efforts focused on building supply chain capacity to facilitate systematic improvement in respect for human rights.

Setting Standards and Expectations for Suppliers
Setting Foundational Policies and Standards
  • Walmart Standards for Suppliers and supplier agreements (all)
  • Auditing program and case management (all)
  • Transparency standards (all)
Responsible Sourcing Program
  • Monitoring working conditions (all)
  • Compliance with Walmart's Standards for Suppliers through audits and investigations (all)
  • Engaging suppliers in remediation (all)
Adoption of Enhanced Standards
  • Encouraging adoption of Seafood Task Force Code of Conduct and Vessel Auditable Standards (UF)
  • Promoting the Responsible Business Alliance Code of Conduct (UF)
  • Advocating for the Ethical Charter on Responsible Labor Practices (all)
Product Specifications Supporting Human Rights
  • Including Fair Trade USA, Rainforest Alliance (all)
  • Roundtable for Sustainable Palm Oil (all)
Inclusive Sourcing
  • Sourcing products from diverse and under-represented suppliers (FI)
Build Capabilities of Under-represented Producers
  • Market Access program to promote inclusive production in Central America, India, and Mexico (FI)
Collaborating to Develop and Share Best Practices
Industry Collaboration
  • Leadership Group on Resp-onsible Recruitment (UF)
  • Seafood Task Force (UF)
  • Ethical Charter group (all)
  • RBA (all)
  • RBA Foundation program to incentivize ethical recruitment (UF)
Develop & Disseminate Worker‐facing Tools & Training
  • Engaging Southeast Asian governments on enforcement (UF)
  • Seafood Task Force government engagement (UF)
  • Bali Process (UF)
  • IOM training on recruitment (UF)
  • Responsible sourcing training (all)
Enhancing Worker Voice
Enhancing Voice
  • Polaris tool for Mexican migrant workers (all)
  • Issara hotline and Golden Dreams app (UF)
Strengthening Demand
Enhance Market Participant Awareness
  • Stronger Together awareness training for US produce suppliers (UF)
  • CIERTO training for Mexico/US produce corrridor actors (all)
  • FishWise awareness tools (all)
  • IREX program for Nepal, Myanmar, Thailand and Malaysia recruitment corridors (UF)
Product Specifications Supporting Human Rights
  • Set targets to source relevant commodities
Investing in Tools & Transparency
Promote Transparency and Understand Prevalence
  • IJM study on migrant labor in Thai seafood industry (UF)
  • IOM study on migrant labor in Thailand and Malaysia (UF)
  • Wilson Center study on wages, working conditions, and recruitment (all)
  • TNC seafood electronic monitoring (all)
Develop & Disseminate Worker-facing Tools & Training
  • GFEMS training for migrant workers in Malaysia (UF)
  • Issara worker training (UF)
Advocating for Good Public Policy
Advocating for Good Public Policy
  • Engaging U.S. government agencies to encourage action to root out forced labor (UF)
Salient Human Rights Issues

(WR) Treating Workers with Respect

(HS) Promoting a Safe & Healthy Work Environment

(FI) Providing a Fair & Inclusive Work Environment

(UF) Combating Forced & Underage Labor

To focus our efforts, we have identified 10 supply chains where human rights issues are most acute and Walmart has the greatest ability to make an impact; Walmart has committed to addressing major risks in these areas by 2025.

Worker Dignity in Retail Supply Chains
At Walmart and the Walmart Foundation, we’re focusing on 10 retail supply chains to address worker dignity.
1

Apparel
from Bangladesh

2

Tuna
from Thailand

3

Shrimp
from Thailand

4

Produce
from U.S. & Mexico

5

Electronics
from Malaysia

6

Hard Home
from Malaysia

7
+

Home Textiles & Apparel
from India

8
+

Home Textiles & Apparel
from Vietnam

9

Apparel
from Jordan

10

Apparel
from Guatemala

To demonstrate how these strategies are applied to help address human rights risks in a supply chain of focus, below is an illustration of the approach taken in the North American produce corridor. Similar approaches are employed in our other supply chains of focus. For further details, see People in Supply Chains.

Selected Work on Human Rights in Produce in the North American Corridor
Strategy: Strengthen worker dignity and tackle forced labor across the NAC through investments that drive systems change and support fair labor practices and responsible recruitment

Treating Workers with Respect

Promoting a Safe & Healthy Work Environment

Providing a Fair & Inclusive Work Environment

Combating Forced & Underage Labor

Setting Standards and Expectations for Suppliers
Setting Foundational Policies and Standards

Responsible Sourcing program: Share Standards and Responsible Sourcing policies with suppliers; implement facility auditing program and investigations. Provide auditing program options relevant to produce, including Equitable Food Initiative and FairTrade USA.

Encouraging Supplier Action

Walmart U.S. and Sam’s Club U.S. encouraged their produce and floral suppliers to endorse the Ethical Charter on Responsible Labor Practices by the end of 2022 and are participating alongside other buyers and suppliers in the Ethical Charter Implementation Program (ECIP).

Equitable Food Initiative

Develop and pilot non-audit approaches focused on management systems, such as self-assessment, self-guided actions and capacity building for managers and worker.

TRANSFAIR USA (also known as Fair Traide USA):

Maximize the impact and transparency of premium programs, improving support for farmers and workers (focusing on producers of berries, tomatoes and coffee).

Labor Mobility Partnerships

Support the growth and development of professional, quality H-2A recruitment operations in North American agriculture.

Collaborating to Develop and Share Best Practices
Ethical Charter on Responsible Labor Practices

Invest more than $2 million to support industry implementation of the Ethical Charter, a code of conduct that sets out key guiding principles and values and provides a framework for responsible labor practices.

Leadership Group for Responsible Recruitment

Member of this company-led collective advocacy platform, which creates demand for responsible recruitment, increases the supply of ethically sourced labor, and improves protection for migrant workers through effective regulation.

Responsible Labor Initiative

Member of the RLI Steering Committee through the end of 2022. RLI has the goal of bringing together stakeholders from multiple industries that share recruitment supply chains to promote due diligence in labor practices and ensure that the rights of vulnerable workers are upheld.

Strengthening Demand
Stronger2gether

Drive demand for responsible recruitment in U.S. produce by establishing a responsible recruitment association for farm labor contractors.

CIERTO

Build capacity around the responsible recruitment of H-2A migrant workers through the Mexico/U.S. corridor to U.S. farms and support implementation of the “Employer Pays Principle.”

Coalition of Immokalee Workers

Scale worker-driven social responsibility model beyond tomatoes in Florida.

Avina Americas

Build the capacity of civil society organizations to support and train workers in key corridors for agricultural migration between Mexico and the United States on their rights and how to exercise them throughout their recruitment and employment, develop policy recommendations around labor rights through collaboration with sector stakeholders, and engage agriculture suppliers to adopt responsible recruitment practices.

Enhancing Worker Voice
Polaris

Fund Polaris’s implementation of Nonechka, a mobile multilingual tech tool to engage Mexican agricultural migrant workers and strengthen their knowledge around potential exploitation.

Investing in Data & Technology
TRANSFAIR USA (also known as Fair Trade USA)

Streamline and accelerate producer engagement with Fair Trade USA and strengthen worker voice by simplifying access to capacity building resources through the implementation of a partner portal .

Promoting Measurement and Reporting

Developed a set of practices across three priority areas to help suppliers engage in, and continuously improve on, responsible recruitment.

Advocating for Enforcement
Wilson Center

Better focus domestic Mexican labor enforcement efforts.

Tracking and Reporting Progress

We annually publish substantial information on the performance of our Responsible Sourcing program in our People in Supply Chains brief, including:

  • Number and results of supply chain audits, including the severity of identified issues
  • Number and nature of non-compliance allegations
  • Progress towards remediation of identified issues
  • How issues are resolved with suppliers
Grievance and Remedy

Because of Walmart's indirect relationship with workers in supply chains, the primary mechanisms for raising grievances are with the workers' employers, Walmart's suppliers, applicable trade unions, and relevant local authorities. As a retailer, Walmart's role is to promote the effectiveness of such grievance mechanisms and remedies by:

  • Promoting worker voice: Walmart and the Walmart Foundation have invested in tools, technology, and organizations that encourage workers in supply chains to speak up, share knowledge, and have their concerns addressed, through mechanisms such as improving the reach and capacity of North American migrant worker helplines and the Issara Institute helpline.
  • Supporting supplier accountability: Walmart also receives information regarding potential human rights infringements through its facility auditing program and Walmart's Ethics channels (which are open to workers in supply chains, their representatives, human rights defenders, and civil society organizations). For example, we provide a 24/7 global helpline that is available in 29 languages. This is in addition to the globally accessible email (ethics@walmart.com) and website (walmartethics.com). We provide posters to suppliers to place in their facilities in the local language detailing how workers can use these mechanisms.
  • We follow up on allegations through our case management and investigations processes. While cases are opened based on higher-risk audit findings, nearly 50 percent of cases arise from sources other than the audit process, indicating functioning worker voice systems. Where issues are identified, we typically work with the supplier to ensure the issue is remedied. For example, higher-risk facility ratings must be remediated over time and severe risk facility ratings force remediation if the supplier is to use the facility to produce products for Walmart again. We have a strong track record of remediation: less than 2 percent of assessed facilities received successive orange ratings. Where the supplier cannot or will not remedy the issue, Walmart can and does end business ties with the supplier and/or prohibit sourcing from the facility at issue.
  • Strengthening rule of law and remedial systems: Walmart has engaged with governments directly and with trade associations to strengthen laws and encourage enforcement, and the Walmart Foundation funded IJM's efforts to gather evidence to bring cases against labor traffickers in Thailand.

Challenges

  • Human rights risks are complex and are often the result of systemic issues including deeply entrenched economic practices, workers lacking knowledge, support or tools to safeguard their rights, and inconsistent government regulation and enforcement across countries. Issues such as forced labor, unsafe working conditions, and gender inequity require collective efforts to bring about significant, positive and lasting transformation for the well-being of workers. These factors make it challenging for any single organization to have an impact.
  • Progress in addressing human rights issues is dependent on the maturity, rigor, and efficacy of third-party standards and initiatives, which requires a critical mass of suppliers and other businesses to align on common standards and best practices. For certain practices, there currently is no universal set of standards for responsible or sustainable production and/or certification beyond compliance with the law (e.g., responsible recruitment, wage/hour). Furthermore, there are limits to the efficacy of tools used to monitor compliance with expectations.
  • The success of Walmart’s programs is dependent on suppliers’ and contractors’ capacity and willingness to meet high standards, as well as their performance.
  • Human rights risks are often upstream and beyond the reach of traditional retailer oversight and monitoring tools. The use of technology to improve transparency and traceability can help, but adoption takes time and further innovation is necessary to meet these challenges.
  • The breadth of Walmart's global product offerings and dispersed geographical reach of supply chains can present challenges for supplier engagement and risk identification and mitigation. Moreover, certain products can only be obtained from specific regions of the world, limiting options for alternative sources.

About Our Reporting

Endnotes

1. Walmart developed its approach to human rights due diligence in 2018. In alignment with UNGP guidance, in 2022 Walmart (supported by a third party) began a periodic review of its human rights due diligence approaches, including salient issues and focus areas, governance, policies, and practices. The effort includes internal and external stakeholder consultation, including rightsholder representatives, NGOs, academics, intergovernmental agencies, and the investment community. Insights from this ongoing review will be reflected in future updates to this disclosure.

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