Walmart’s Global Ethics & Compliance program is designed to manage the compliance risks associated with different subject areas, ranging from anti-corruption to food safety.
- Consumer Protection
- Environmental Health & Safety
- Food Safety
- Health & Wellness
- Product Safety
- Responsible Sourcing
- Global Sanctions & Conflict Minerals Compliance
- Supply Chain Security
Walmart believes in fair, free and open markets. We also believe in promoting good government. We do not tolerate bribery, corruption or unethical practices of any kind.
Our stance on improper benefits is firm — regardless of local practice or custom, or even harm to our business.
Walmart strictly prohibits anyone acting on behalf of Walmart, whether directly or indirectly, from making or receiving bribes or improper payments. Walmart’s Global Anti-Corruption Policy forbids us from paying, offering or authorizing payment of money (or anything that has value) to improperly influence anyone. This also applies to payments made through someone unaffiliated with Walmart, such as a third party acting on Walmart’s behalf. Our prohibition also covers small or minor benefits to influence someone improperly. Our stance on improper benefits is firm — regardless of local practice or custom, or even harm to our business.
Never Engage in Bribery
We expect suppliers to support Walmart’s compliance with applicable anti-corruption laws and policies. We also expect suppliers to uphold these same values in their business.
- Never offer, pay, or receive a bribe.
- Do not give, offer, authorize, or promise to give money or anything else of value to any person—including any government official—in order to improperly influence any act or decision or to otherwise gain an improper benefit.
- Comply with relevant anti-corruption laws. These may include the United States Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act.
- Report bribery to Walmart, even if the attempted bribe was not successful.
You can find a copy of Walmart’s Anti-Corruption Policy here.
Walmart is committed to complying with all antitrust and competition laws and the conduct of its suppliers plays a critical role in this compliance. Walmart expects its suppliers to understand and fully comply with antitrust and competition laws. These laws are designed to promote free and fair competition, and they help enable open markets, enhance productivity, and promote innovation and value for customers. Violations of these laws can lead to severe financial and reputational consequences for individuals and companies. If you have any questions about how to ensure full compliance, speak to your company’s legal counsel.
Walmart takes the following prohibitions seriously and violations will be treated accordingly, including potential termination and reporting to appropriate authorities.
No Anticompetitive Agreements with Competitors
Suppliers are prohibited from….
- Reaching anticompetitive agreements with your competitors regarding sales made to Walmart.
- Sharing pricing, costs or other competitively sensitive information with your competitors regarding doing business with Walmart.
Appropriately Protect Sensitive Information – both Walmart’s and that belonging to others!
Suppliers are prohibited from….
- Providing or offering to share with Walmart another third party’s non-public, commercially sensitive or proprietary information. This includes a competitor’s future pricing plans.
- Sharing confidential information received from Walmart with any third party, including other retailers. This includes terms of supply, product rollout or development plans, Walmart’s future or otherwise non-public retail prices, promotions, sales, marketing or promotional plans or strategies, category advisor recommendations, production or sales volumes or forecasts, or trade secrets.
- Asking a Walmart category advisor to share non-public, sensitive information.
- Discussing your non-public sales plans or strategies via any other channel (whether direct sales to customers or sales through another retailer).
Proper Independence in Decision Making
Suppliers are prohibited from….
- Attempting to influence Walmart’s retail price. Walmart independently sets its retail prices.
- Recommending or suggesting that Walmart agree to limit sales of its private label products.
Walmart is committed to complying with consumer protection laws everywhere we do businesses. Providing clear and accurate information to our customers and members is an important component to maintaining their trust and loyalty.
As a supplier to Walmart, we expect you to meet our expectations of complying with all consumer protection laws and regulations, including the following:
- Research and assess legal conditions of sale to understand how they apply to the products you sell and ensure compliance with same.
- Ensure all content on product labels and on eCommerce website listings is clear, accurate, and not misleading to customers.
- Make only truthful and substantiated claims on product labels and on eCommerce website listings, and provide us with substantiation when requested.
- Include any appropriate disclaimers, disclosures, warranties, registrations, and instructions for products.
- Follow all requirements for creation, set-up, and display of merchandise for both in-store and online.
For U.S. Suppliers
Please see our Prohibited Items Policy. This page identifies some types of products that cannot be listed on Walmart’s Marketplace. Products that are not included in this policy must still comply with all applicable laws.
For reference, the updated Standards for Suppliers includes the following…
Label and Market Products Accurately
Earning and maintaining customer trust requires being accurate and transparent about the products we sell. Walmart cannot do it alone—suppliers play a key role in helping our customers make informed decisions.
- Provide Walmart with timely and accurate information about the products you provide to Walmart and our customers. We rely on this information to make business, legal, and compliance decisions, among other purposes.
- Provide only genuine products that are what they claim to be.
- Comply with relevant labeling laws and regulations and be honest with Walmart’s customers. Make sure all product labels and descriptions are clear, accurate, truthful, and not misleading. Include all appropriate disclaimers, disclosures, and warranties, and support any claims you make with adequate substantiation.
- Where appropriate, products must contain instructions adequate to use or consume the product safely.
Environmental Health & Safety
Walmart requires any merchandise that is or may contain a chemical, aerosol, pesticide or battery item to be submitted to UL WERCSmart, a third-party company, for review and assessment prior to an item number being created.
As part of the UL WERCSmart review and assessment, suppliers are required to submit formulation information. These assessments ensure Walmart has the necessary information to store, transport, dispose and otherwise manage products in accordance with applicable federal, state and local laws and regulations. This information also allows Walmart to support environmental sustainability and product stewardship initiatives.
Suppliers must provide accurate information regarding the above outlined merchandise, as may be deemed necessary by Walmart, to properly store, transport, handle, or dispose of merchandise. Accurate item information must be maintained within WERCS for at least three years after the last date of shipment and the assessment must not be archived. Walmart may assess additional charges based on the additional costs of storing, transporting, handling, and/or disposing of such merchandise.
To get started, (1) go to the WERCS website at www.supplierwercs.com, (2) set up a company account using the first 6 digits of your host vendor number, (3) create an assessment for the merchandise, (4) attach all applicable UPCs, (5) pay and complete the process. The WERCS assessment must be completed prior to item creation or the process will be halted, resulting in delays in item creation. To ensure the item(s) complete the WERCS assessment process as quickly as possible, please ensure all fees associated with the supplier are paid as soon as possible and Walmart is listed as a “Retailer".
Review Chemical definitions and Environmental Health and Safety Compliance policies here.
For U.S. Suppliers
At Walmart Inc., our commitment to our customers and members is unparalleled. We strive relentlessly to provide safe, affordable, quality foods in our retail operations. As part of our commitment to continuous improvement, we go further than many U.S. and Puerto Rico retailers in requiring that harmonized, leading-edge food safety standards be adopted throughout the entire food production chain.
When our customers and members shop in our stores and clubs, we know they expect great prices. But an often unspoken expectation is that they want the products they purchase in our stores and clubs to be safe - and when it comes to food, this is critically important.
Walmart Inc. strives to ensure the products we provide can be trusted. To maintain this trust, we work with suppliers to ensure integrity is part of their process beginning with product design. We also expect suppliers to monitor information, including customer complaints, and act quickly should product need to be removed from our shelves to keep our customers and members safe.
Recalls | Withdrawals
If for any reason a situation arises where you need to remove product from Walmart Stores, Sam’s Clubs, Distribution Centers, or Fulfillment Centers:
Complaint Management Expectations
While it is an expectation that all suppliers have a complaint management program in place, below are the expectations we hold for our Private Branded and Direct Import suppliers.
Walmart Inc. expects our suppliers to react with haste and launch a thorough investigation anytime a food safety related complaint is received. Food Safety related complaints may include (but are not limited to) issues involving:
Food safety complaints (both human and pet food) should be handled with the upmost priority. Suppliers should acknowledge receipt of any escalated complaint sent to them directly from a Food Safety Manager within 24 hours. We recognize that some complaints may require more time to investigate than others, however, we do expect an investigation report be submitted back to the Food Safety Manager within the requested timeline. If no timeline is provided, this information should be provided no later than two weeks from initial receipt of the complaint. Information expected to be included in the report can be found in the Investigation Expectations section below.
Because you as the supplier are ultimately responsible for any legal or financial outcomes from the complaint or claim, Walmart Inc. asks that you contact the customer/member directly in order to obtain any additional information you may need in order to conduct your investigation. All communications with the customer/member should be handled in English, or the customer’s/member’s preferred language, during reasonable hours for the U.S. and in the form of communication that is most comfortable for the customer/member (email/phone). The supplier can determine if they prefer to handle these communications internally or utilize a third-party customer service agency (which may be preferred by international or Direct Import suppliers.) All communications should be initiated with the customer/member within 48 hours of receiving the complaint. For this reason, we ask all suppliers to have an emergency plan in place to cover issues that may arise during weekends or holidays.
If you need to retrieve the product, packaging, or foreign object for analysis we request that suppliers use a pre-paid shipping container with a tracking number to the customer/member. For international or direct import suppliers, we recommend you partner with a third-party company or lab to send and receive these pre-paid, trackable shipping containers for expedited investigations. If the complaint could result in legal action, suppliers should consider having the pre-paid, trackable shipping container sent directly to a third-party lab for investigation to maintain chain-of-command and to ensure final analysis results are free of bias which will present better in a legal setting.
If at any time during your investigation of an issue you find that there may be a widespread issue which could impact additional customers/members, suppliers should immediately contact the Food Safety Product Removal team to begin a product removal. For more information on product removals, please visit the Recalls | Withdrawals section on this page.
A summary of each area below should be included in the investigation report that is submitted back to your Food Safety Manager upon their request (as applicable).
- Analyzing Similar Complaints: In order to determine if the complaint is an isolated incident or a potential widespread food safety issue, we ask that you analyze other complaints received in the previous 6 months (this timespan can be expanded or contracted based on the shelf-life of the product.) If you have received similar complaints for the implicated item, products that are similar to the implicated item, or products that are made with the same raw materials as the implicated item, we ask that you inform your Food Safety Manager immediately. In an event that you notice a trend, we may need to take additional actions. Data should be normalized for analysis.
- Review of Production Records: If a lot code for the product is available, suppliers are expected to trace the lot back to the product date and review records for any abnormalities. This includes, but is not limited to batch sheets, finished product testing results, foreign object detection equipment records (e.g. for metal detectors, x-ray, optical sorters, etc.) including calibration logs and any detection issues/rejections, notice of unusual occurrences and corrective action logs (NUOCA), deviation logs, cleaning and sanitation logs, and/or any other relevant CCP records.
- Review of Retain Samples: Retain samples should be analyzed to determine if the reported issue can be observed in similar products. Where invasive tests are required, we recommend documenting the tests via testing records and photographs.
- Review of Production Room CCTV: Where relevant and useful, review production day CCTV footage to help determine complaint cause.
- Conducting the Root Cause Analysis: A formal root cause analysis should be conducted for the complaint using all available information. The root cause analysis should consider any additional products or lots that could be affected by the issue. If you do not have a root cause method defined in your SOP, use the questions who, what, when, where, why, and how to narrow in on one key issue.
- Creating & Implementing Corrective and Preventive Actions: Corrective actions should be identified/implemented and preventive actions taken that are designed to mitigate or prevent the risk of the same issue occurring. A formal timebound corrective action report should be submitted to your Food Safety Manager for review and approval. Depending on the situation, it may be acceptable to implement both short-term and long-term corrective actions. For critical food safety issues identified, immediate corrective actions are to be completed within 24 hours, or prior to further production.
- Confirmation of Resolution with Customer/Member: Unless the customer/member has explicitly indicated they do not wish to be contacted, or no contact information is provided, suppliers should contact the customer/member to obtain additional information as well as to resolve the issue. Please always treat the customer/member with respect, show empathy regarding their recent food safety complaint issue, and keep a detailed record of these communications.
Audits, Certifications, & Regulatory Requirements
Walmart Inc. requires all operations/facilities producing food or beverage products for human or pet consumption to obtain a food safety assessment on an annual basis as well as comply with all regulatory requirements applicable to their operations, facilities, and products.
Commodity Specific Requirements
Walmart Inc. requires suppliers of specific commodities to go above and beyond audit and regulatory requirements to ensure the safety of their products. These suppliers must comply with all initiative requirements prior to providing their products to our stores and clubs.
Bulk Deli Meats to be Sliced in a Store/Club | Private Branded Pre-Packaged Sliced Deli Meats Requirements
These requirements are applicable to suppliers who provide bulk deli meat products intended to be sliced within our store or club, regardless of brand. They also are applicable to pre-packaged sliced deli meat sold under a Walmart or Sam’s Club Private Label.
Listeria monocytogenes is a recognized human pathogen commonly associated with ready-to-eat food items including deli meats. As part of our continuous improvement efforts to provide safe and affordable food to our customers and members, Walmart Inc. requires all suppliers of bulk deli meats intended to be sliced in our stores/clubs and Private Branded pre-packaged sliced deli meats to comply with the following requirements.
Please be aware that suppliers will be required to submit challenge studies for review and approval for each item number or formulation of bulk deli meat prior to being allowed to provide the product to our stores and clubs. Challenge studies, Listeria control programs, environmental test results, and final product testing results may be requested for review at any time.
Raw Ground Beef | Raw Ground Bison Requirements
These requirements are applicable to suppliers who provide fresh or frozen products containing raw ground beef or raw ground bison. It should also be noted that these requirements are applicable to product sold raw to our customers/members as well as product that is supplied raw to our stores and clubs which will be cooked prior to being provided to our customers/members.
Based on thorough consultation and consensus with numerous stakeholders from industry, academia, regulatory, and consumer groups, we require all suppliers that provide products containing raw ground beef or raw ground bison implement process control standards to protect against human pathogens such as E. coli O157:H7 and Salmonella Newport. Suppliers of these products must comply with the following requirements.
Please be aware that suppliers will be required to submit scientific validations of their interventions for review and approval prior to being allowed to provide the product to our stores and clubs. It should also be noted that the microorganisms used for the validation must be indicative of enteric pathogens and APC counts will not be accepted. Product testing programs may also be requested for review at any time.
Raw Whole Bird Chicken | Raw Chicken Parts | Raw Ground Turkey Requirements
These requirements are applicable to suppliers who provide the fresh or frozen raw whole bird chicken, raw chicken parts, and raw ground turkey products. It should also be noted that these requirements are applicable to product sold raw to our customers/members as well as product that is supplied raw to our stores and clubs which will be cooked prior to being provided to our customers/members, such as rotisserie chickens.
Poultry products have been involved in multiple high-profile recalls and outbreaks over the past decade. In light of these incidents, we require all poultry suppliers that provide the poultry products outlined above to meet our poultry safety initiative. Suppliers of these products must comply with the following requirements.
Please be aware that suppliers will be required to submit scientific validations of their interventions, for review and approval prior to being allowed to provide the product to our stores and clubs. It should also be noted that the microorganisms used for validations must be indicative of enteric pathogens and APC counts will not be accepted.
Frozen Berries | Frozen Berry Blends Requirements
These requirements are applicable to suppliers who provide frozen berries and/or frozen berry blends.
Frozen berries and frozen berry blends have been increasingly associated with foodborne disease outbreaks over the past couple of years. The most common pathogens identified have been Norovirus, Hepatitis A, and Shegella sonnei. Due to heightened risk and consumer awareness, we require all frozen berry and frozen berry blend suppliers to comply with the following requirements.
To ensure suppliers comply with all food safety requirements, Walmart Inc. may require suppliers to use specific systems to share information with the Food Safety team.
ProSpec | Hive
Private Label suppliers who provide product under a Walmart or Sam’s Club label or who provide components that will be used to create a Walmart or Sam’s Club labeled product are required to use our product life cycle management systems. Walmart Private Label suppliers are required to use the ProSpec system while Sam’s Club Private Label suppliers are required to use the Hive system. While these systems are run by our Private Brand Product Development teams, certain critical Food Safety traceability information is housed within each system, which must be accessible at all times in case of product or ingredient recall and/or outbreak investigation.
Retail Link®️ is an online hub for the data, documentation, reports, and special applications that suppliers use to manage their business with Walmart. The Product Removal app is located within Retail Link and is used to remove products from stores, clubs, distribution centers, and fulfillment centers. The Walmart Food Safety & Health Compliance Team uses data to execute product withdrawals and recalls through this portal.
Fresh produce suppliers of Private Branded, National Branded, and Unbranded Produce items are required to transfer food safety audit reports and certificates using the Azzule Supply Chain Program (SCP) for all growing and facility operations that are used or will be used to supply Walmart and Sam’s Club. Suppliers must ensure that new audits, re-audits, and certificate extensions are transferred in a timely manner so as to avoid certificate expirations. Questions regarding the Azzule SCP can be directed to firstname.lastname@example.org.
Health & Wellness
All companies that provide prescription products, over-the-counter drugs, vitamins, dietary & nutritional supplements, or personal care or cosmetics containing active pharmaceutical ingredients must meet our Health & Wellness product safety requirements to become a supplier. Please see the guide below for complete requirements for your product type.
For help, please contact us at HWSCSAFETY@wal-mart.com.
Walmart is committed to providing our customers and members with access to safe and affordable merchandise. As a supplier to Walmart, we expect you to deliver products that meet that commitment. We require our suppliers to meet all laws, mandatory standards, applicable voluntary consensus standards, and Walmart-specific requirements for all items offered for sale. We also expect our suppliers to:
- Research and assess laws, regulations, standards, and other requirements to understand how they apply to the products you sell and ensure compliance with same.
- Understand and comply with the laws and regulations at all jurisdictional levels (local, state, and federal). For example, products sold by Walmart must comply with all requirements of California’s Proposition 65.
- Implement appropriate risk management systems to protect against product safety hazards. Suppliers should have these systems independently validated and verified.
- Provide documented verification of the compliance of the products you sell, when requested.
- Submit products for testing, where required.
- Avoid undue influence or any attempt to persuade, pressure, suggest, or instruct anyone to withhold or change safety or regulatory test results.
- Inform Walmart immediately if you become aware that any of your products violate or fail to meet any regulatory standards or Walmart-specific requirements or pose an unreasonable risk of injury.
- Participate actively in the inquiry, investigation, or removal of products identified as not meeting regulatory, legal, or safety requirements.
Additionally, we expect our private brand suppliers to hold their supply chains to the same rigorous standards to which we hold you.
For U.S. Suppliers:
Our U.S. Product Quality and Compliance Manual contains full details on our product safety-related processes and procedures.
For reference, the updated Standards for Suppliers includes the following…
Uphold High Standards for Safety and Quality
Walmart earns customer trust by providing safe, high-quality products our customers love. We expect our suppliers to help us maintain trust by:
- Providing us with products that meet all legal, industry, and Walmart safety, quality, and technical requirements.
- Implementing appropriate risk management systems to protect against food and product safety hazards. Suppliers should have these systems independently validated and verified.
- Monitoring products you produce for safety and quality and promptly reporting material issues to Walmart. Material issues include failing to meet recognized safety standards and defects in product labeling or instructions that increase the risk of unsafe use. In the case of food products, material issues also include product specification deviations and microbiological, chemical or physical hazards that affect the safety of the product.
- Notifying Walmart of voluntary and mandatory product recalls and removals where you identify products as not meeting applicable requirements.
- Participating actively with Walmart and with regulatory authorities in the recall and removal of products.
Suppliers are responsible for disclosing and scheduling audits for all facilities within Walmart’s disclosure and audit scope. If Walmart discovers a supplier producing merchandise in or subcontracting to an unauthorized facility, the supplier may become ineligible to do business with Walmart.
Review the disclosure requirements here.
Suppliers have primary responsibility for monitoring compliance throughout their supply chains and correcting non-compliances, including in facilities producing product for Walmart. Walmart takes a risk-based approach to auditing suppliers’ facilities, which requires suppliers with higher-risk facilities (facilities located in countries with greater potential risks and supplying direct import merchandise to Walmart) to submit audits to Walmart on a more frequent basis. Suppliers required to submit an audit must work with an eligible program, follow the program’s directions to schedule an audit, and send the completed audit report to Walmart.
Walmart assesses the findings in each facility audit report submitted to Walmart against our Standards for Suppliers. Non-compliances and failure to remediate may result in consequences, up to and including termination of the supplier’s business relationship with Walmart and/or a facility’s ability to produce goods for sale at Walmart. Walmart reserves the right to audit or inspect a supplier’s facility at any time.
Review the audit and assessment requirements here.
We expect suppliers to understand potential risks for the geographies and industries in which they operate. To help mitigate risk, Walmart provides tools and resources to suppliers.
Global Sanctions & Conflict Minerals Compliance
To further foreign policy and national security objectives, governments and organizations worldwide have programs that impose restrictions and prohibitions, or “sanctions”, on transactions with certain countries, entities, individuals, and end-uses. All Walmart & Sam’s Club suppliers, along with Walmart Inc., have the responsibility of following these programs.
Suppliers must ensure that they A) know where their product originated (Know Your Product) and B) know who provided the product and components to that product (Know Your Supplier).
A. Suppliers are prohibited from engaging in trade, commerce, or any dealings with sanctioned countries or regions subject to applicable local laws.
B. Suppliers are required to restrain from engaging with individuals or companies listed on government watchlists.
Some violations have serious consequences for non-compliance, including but not limited to, personal, criminal, and reputational liability, even if their action was inadvertent or uninformed.
Please review the Global Sanctions Policy.
If you have any questions, please reach out to your Walmart Merchant/Buyer.
Conflict Minerals Compliance
Security Exchange Commission (SEC) reporting requirements are mandated through the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 to provide detailed information about the source of raw minerals present within their company’s supply chain. These reporting requirements are intended to prevent exploitation and curb violence present in the Democratic Republic of the Congo (DRC) and its adjoining countries. Walmart Inc. expects its product suppliers to actively support Walmart’s conflict minerals compliance efforts by assisting in the following ways.
Suppliers should ensure that they do not source any of the 3TG minerals [Tin, Tantalum, Tungsten, & Gold] from the Democratic Republic of the Congo (DRC) or its adjoining countries to incorporate into its products being sold by or through Walmart Inc.
Suppliers should have mineral sourcing policies that align with the policy under Walmart Inc. and be able to provide evidence of compliance upon request.
Walmart believes its conflict minerals program will help drive necessary transparency in the supply chain and fully complies with the regulations enumerated by the Dodd Frank Act § 1502.
Please review the Global Conflict Minerals Policy here.
Supply Chain Security
Suppliers must satisfy all applicable facets of Walmart’s Supply Chain Security program. Suppliers shall have and execute reasonable processes to provide the safe and secure manufacture and shipment of Merchandise.
Suppliers must comply with Walmart’s Standards for Suppliers, which, among other things, require suppliers to ensure that Merchandise is transported safely and securely. Suppliers providing Merchandise to Walmart, where Walmart is the importer of record, are required to satisfy these expectations through Walmart’s Supply Chain Security (SCS) program. This SCS program generally requires suppliers to disclose applicable facilities, schedule audits of said facilities, and provide the reports of those audits to Walmart.
Suppliers have primary responsibility for monitoring SCS compliance throughout their supply chains and correcting non-compliance, including in facilities producing Merchandise for purchase by Walmart. Walmart’s SCS program takes a risk-based approach to auditing suppliers’ facilities, which requires suppliers with higher-risk facilities (e.g., for facilities located in regions with greater potential supply-chain risks) to submit audits to Walmart on a more frequent basis.
- Suppliers required to submit an audit must choose one of the acceptable options to meet Walmart’s audit requirements and provide information to Walmart when requested.
- Walmart will review the information provided and communicate with suppliers regarding the results.
- Failure to comply with above or remediate identified non-compliances may result in consequences, up to and including termination of the supplier’s business relationship with Walmart and/or a facility’s ability to produce goods for sale at Walmart.
- Walmart reserves the right to audit or inspect a supplier’s facility—or the facilities where goods it is selling are made—at any time.
Walmart is committed to complying with all applicable customs, trade and import/export laws and regulations that govern the movement of products across international borders. Critical to this is providing accurate information to regulatory agencies about the products we import and export. We rely on our suppliers and service providers to provide us true and accurate information. Conducting our international trade activities is critical to earning and maintaining trust in our business, allowing us to move these items as necessary to serve our customers around the world.
Suppliers should reference their supplier agreements for further guidance.