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:
- Reiterates Walmart's commitment to respect human rights
- Sets foundational expectations on each of our salient human rights issues
- Explains when to speak up and how to speak up, and provides a prohibition against retaliation for speaking up
- 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:
- Setting expectations through policies, procedures, and standards
- Engaging stakeholders and assessing their feedback, insights, and concerns
- 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
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.