Standards for Suppliers

Since Sam Walton founded Walmart in 1962, our values have remained the cornerstone of our business — a key pillar of those is acting with integrity. That means it’s not enough to deliver everyday low prices and everyday low costs if we do it at the expense of who we are as a company. Our business practices have to reflect our business principles.

We hold our suppliers to the same high standards we set for ourselves. Because when we make sure those standards are upheld throughout the entire supply chain, we do more than deliver products and services — we build and strengthen trust with each other, our customers, and the local communities we serve.

So, as you read our Standards for Suppliers, we’d ask that you do so with the goal of ensuring you thoroughly understand the compliance aspects. Beyond that, however, we hope that you will embrace the spirit in which these Standards were developed and model the values that stand behind them.

Thank you for all you do for Walmart and for our customers every day.

Doug McMillon
President & CEO
Walmart Inc.

Walmart is dedicated to doing business the right way. Sam Walton founded a values-driven company that today is grounded in four core values: respect, service, excellence, and integrity.

These values guide how we work and make decisions, and they help us build trust with our customers. Suppliers play an important role in helping us achieve this mission.

Walmart is constantly changing, but our values are strong and consistent. Our Code of Conduct outlines the values and behaviors we expect of our associates; these Standards complement the Code of Conduct by applying Walmart’s values to our relationships with suppliers.

The Standards apply to suppliers of Walmart Inc. and suppliers of Walmart — controlled subsidiaries globally. Suppliers include anyone that provides products to Walmart, including goods for resale and for Walmart’s own use. A signed supplier agreement, acceptance of a purchase order, and/or provision of merchandise to Walmart constitutes acceptance of these Standards and serves as the Supplier’s continuing affirmation of compliance. In addition, Walmart may enter into contracts with certain other parties that require those parties to comply with these Standards. In this document, we refer to anyone covered by the Standards as a “supplier.”

Our suppliers include some of the largest and most well-known companies in the world as well as smaller companies providing product to a single store. They span the wide range of products we buy and sell. Our suppliers are often leaders in their respective fields and operate their own robust ethics and compliance programs. Nevertheless, Walmart has strong values, and we hold each of our suppliers to the same high standards.

Suppliers are responsible for compliance with these Standards throughout their business and throughout the process of providing products to Walmart. This includes responsibility for the conduct of any suppliers, subcontractors, and agents they use as part of their Walmart business (including, for example, factories, processing facilities, and raw material, component, ingredient providers and labor recruitment agents). More details on supplier transparency are included in our Supplier Traceability requirements.

Anyone who violates the Standards may be subject to consequences, up to and including termination of business with Walmart. Walmart reserves the right to audit or inspect suppliers at any time to determine whether they are complying with these Standards.

If you don’t know the right thing to do, ask for help. While Walmart cannot provide you with legal advice, we can help you understand our expectations.

If you see or hear about something suspicious, report it right away. This includes any potential violation of these Standards and instances where a Walmart associate might be acting contrary to our values. Looking the other way or letting someone else take the lead may seem easier, but unethical or unlawful behavior affects us all and erodes trust. Instructions on how and where to report are provided below.

Most questions about how to meet Walmart’s expectations and concerns should be brought to your primary Walmart business partner, who will reach out to Walmart Ethics & Compliance as necessary.

The following issues should be reported as specified below to get to the right teams quickly:

• The following should be immediately reported to Walmart Ethics & Compliance when related to a supplier’s business with Walmart:
  • Bribery
  • Forced labor, prison labor, trafficked labor, child labor, and underage labor
  • Violence against or harassment of workers
  • Sanctions violations
  • Producing products in a facility not approved for Walmart production
  • Government investigations or enforcement activities

• Conditions posing an imminent risk to the health and safety of workers and incidents involving loss of life, significant disruption to operations, significant injury, and significant loss of property should be reported to the appropriate governmental authority in accordance with local requirements. These should also be reported to Walmart Ethics & Compliance.

• Information that Walmart’s confidential information might have been breached or compromised should be reported to the Walmart Emergency Operations Center at 479-277-1001 and to Walmart Ethics & Compliance.

When in doubt, report issues to Walmart Ethics & Compliance. You can make anonymous reports to the Ethics & Compliance Helpline to the extent allowed by law.

Report accurately and to the best of your knowledge, providing as many details as you can. Our reporting process does not work when someone reports false information — misreporting or failing to report violates the Standards and can result in consequences.

If you report through the helpline, you will receive a case number to access your report. Walmart Ethics & Compliance will follow up on your concern, as appropriate, and an investigator may contact you. If contacted, please cooperate — we need you to give us complete, accurate, and timely responses to questions and document requests. If we ask you to retain records, do so until you are told retention is unnecessary.

If a problem is found, Ethics & Compliance will work with the relevant parties to resolve it.

We expect companies doing business with us to share our values. This means doing things the right way, not taking shortcuts, and treating one another with respect.

Walmart believes in doing the right thing and is committed to complying with the laws of the places where we operate. We expect our suppliers to do the same.

• Conduct your business ethically and with integrity. Don’t do anything that would put Walmart at risk of violating the law, that might harm Walmart’s reputation, or that could be perceived as misleading, defrauding, or exerting undue influence on Walmart.

• Understand and comply with all relevant laws. Even if conduct is legal in the location in which it takes place, it is prohibited if it would create a legal violation in the country into which products are transported or sold.

• Comply with all applicable Walmart contracts, policies, procedures, and requirements. Walmart makes requirements and resources available from time to time, including on its supplier compliance portal. It is your responsibility to stay up to date on all applicable requirements. In the event these Standards or Walmart policy require more than the law, you must follow Walmart’s requirements.

• Obtain the licenses, permits, certifications, registrations, and rights necessary to operate and to provide products to Walmart. Maintain these and comply with all conditions of issue.
  

• Remediate issues where they exist and bring your operations into compliance if they are not.

Effective risk management is key to complying with the law and Walmart’s expectations. As a supplier, you should actively manage risk related to your business with Walmart by:

• Understanding and assessing risks relating to your industry, products, and workforce. Research and stay up to date on the laws, regulations, standards, industry best practices, conditions of sale, and scientific knowledge relevant to your products.

• Adopting strong operations, safety, and quality management systems.

• Training your employees, suppliers, subcontractors, and factories.

• Knowing your suppliers, subcontractors, and factories and monitoring their performance. Walmart has policies that require suppliers producing certain types of products — including private brand products, products bearing brands exclusive to Walmart, and products where Walmart will be the importer of record — to disclose to Walmart how and where those products are made and who is making them. Suppliers are required to understand these policies and comply with them to the extent applicable.

• Putting procedures in place to monitor your compliance with laws, policies, and these Standards.

• Assigning clear responsibility and accountability for compliance within your organization.

We expect suppliers to support Walmart’s compliance with applicable anti-corruption laws and policies. We also expect our 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.
• Immediately report bribery to Walmart, even attempted bribes that were not successful.

Walmart respects the dignity of every individual and values their unique skills. Individuals should be treated fairly and respectfully without regard to their personal appearance, beliefs, culture, affiliations, or any other characteristics. Discrimination, harassment, and unfair treatment diminish the dignity of individuals and have no place in Walmart’s business or in our suppliers’ businesses. Suppliers’ employees and workers in their supply chains must be able to raise concerns about discrimination, harassment, and unfair treatment freely and without fear of retaliation.

• Provide a fair, consistent, and inclusive environment and make all employment decisions based on neutral and objective criteria. In addition to complying with all applicable laws, suppliers must not engage in or tolerate discrimination, harassment, and unfair treatment based on an individual’s race, color, ancestry, ethnicity, religion, sex, pregnancy, national origin, age, disability, marital status, veteran status, military status or obligation to perform military service, sexual orientation, gender identity or expression, or genetic information. If there is a perceived conflict between this expectation and applicable law, let Walmart know.

• Provide a mechanism for workers or other stakeholders to report concerns to management, to you as the supplier, and to third parties. These mechanisms should allow for anonymity and prohibit retaliation by you as the supplier against any germane party, including human rights organizations, for reporting in good faith. Walmart makes its Ethics & Compliance reporting channels available to workers who have concerns about suppliers and facilities that make product for Walmart. Suppliers of Walmart-branded product and product where Walmart will be the importer of record are required to distribute Walmart posters throughout their supply chain to help make workers aware of Walmart’s expectations and the availability of those reporting channels.

• Address reports that your management, employees, or subcontractors have engaged in harassment, threatening behavior, or discrimination.

• Do not engage in physical punishment, including when imposing discipline.

We value our associates and believe that when we take good care of our associates, they will take good care of our customers. The same is true in the supply chain: companies that treat their workers fairly and comply with relevant employment laws and agreements are better suppliers.

• Provide compensation, benefits, working hours, breaks, rest days, holidays and leave that comply with legal requirements and applicable agreements. Ensure workers understand these terms.

• Do not make illegal or excessive wage deductions, withhold wages, delay wage payments, or pay wages irregularly.

• Comply with all applicable laws, regulations, and agreements relating to the employment of young workers.

• Recognize freedom of association and collective bargaining. Respect the rights of workers to join an employee association or trade union, or refrain from doing so, without interference, in accordance with applicable law and practice.

• Confirm all workers are appropriately authorized to work. This includes verifying worker eligibility to work in the region and in the relevant job prior to employment.

People should not be exploited through employment, and Walmart has prioritized working with stakeholders to combat forced labor and other exploitative practices in global supply chains. We expect our suppliers to take seriously their responsibility to prevent these practices and remediate if substantiated.

• Do not use forced labor. Exclude involuntary labor — including child, underage, forced, coerced, bonded, involuntary prison, exploited, trafficked or indentured labor — from your operations, subcontractors’ operations, and supply chain.

• Be aware of indicators of involuntary labor and actively address them. Have systems in place to monitor for signs of trafficking and exploitation, particularly where your business includes vulnerable populations such as migrants, women, and young people.

• Recruit responsibly. Do not charge workers recruitment or similar fees — even if the collection of such fees is allowed under local law. If such fees are charged, we expect you to repay them. We also expect you to communicate to migrant workers the terms of their employment contract in their native language prior to departure from their home region. Hold your agents and any labor brokers and recruiters used in the recruitment process to the same standards. More details are included in our Responsible Recruitment Expectations.

• Allow workers freedom of movement. Do not keep workers’ personal identity documents or other valuable possessions, do not control workers’ freedom of movement through debts owed to you, brokers, or other third parties, and allow workers to terminate employment on reasonable notice.

Walmart expects suppliers to take responsibility for the safety and wellbeing of the workers who produce products for Walmart.

• Provide a safe, clean, and healthy work environment as appropriate for your industry, geography, and workforce. This includes ensuring facilities are structurally sound, fit for purpose, compliant with electrical and fire safety laws and standards, and well maintained.

• Provide access to clean and sanitary facilities and clean drinking water.

• Implement appropriate procedures and safeguards to prevent accidents and injuries to workers. Establish proper maintenance, monitoring, and inspection routines, worker training and protection, and fire safety measures. Take appropriate steps to protect workers from exposure to harmful chemicals, infectious disease, and other similar risks. Observe restrictions on hazardous work for young workers.

• Where you work alongside Walmart associates or in Walmart facilities, make sure you and your employees do not pose a risk to the safety of our associates and customers.

Walmart is committed to complying with environmental laws and advancing sustainability in retail. We collaborate with suppliers and others to inspire positive change throughout supply chains and to help reduce emissions, eliminate waste, and preserve natural resources. Walmart works with suppliers who share these values and encourages suppliers to develop their own sustainability goals. In addition to complying with all relevant environmental laws and regulations, we expect our suppliers to:

• Consult and comply with sustainability policies applicable to your business with Walmart, including policies regarding product certification and sustainable sourcing.

• Design and operate systems to properly manage potable water, wastewater, storm water, waste, emissions, and recyclable materials.

• Handle, store, transport, and dispose of fuel, chemicals and hazardous waste responsibly.

We have high expectations for the products we buy and sell, and our customers do, too. When people shine a light on Walmart and our supply chain, we want them to like what they see. We can only achieve this by working with suppliers that are as committed as we are.

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.

Our high expectations of suppliers extend throughout the supply chain, including making products the right way, following all trade laws, and ensuring that products are transported safely and securely.

• Ensure that products are not produced — in whole or in part — in violation of the law or in a way that would cause Walmart to violate the law. In particular, suppliers must comply with all applicable trade, sanctions, conflict minerals, permissible harvest, and animal welfare laws and regulations.

• Establish controls to secure the supply chain from being used for improper purposes, including smuggling, terrorism, fraud, and theft. Walmart participates in the Customs Trade Partnership Against Terrorism program in the United States, the Partners in Protection program in Canada, and Authorized Economic Operator and similar programs in many other countries in which we operate. Suppliers providing product where Walmart will be the importer of record are expected to exercise oversight in accordance with the security principles and requirements of these programs and to help Walmart maintain a safe and secure supply chain.

• Formulate and label products in a way that allows them to be transported, stored, and sold without compromising the products or the supply chain.

• Where the supplier is responsible for delivering product to Walmart, ensure containers and conveyances used are safe, sound, clean, and appropriate for the safe and secure delivery of product to Walmart.

• Take steps to prevent illegal transshipment or the mislabeling of products to mask a product’s country of origin.

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.

Walmart can’t achieve its objectives without strong supplier relationships. Honesty, transparency, and collaboration are key to building and maintaining a strong relationship.

We ask our associates to avoid situations where they might put personal interests or the interests of a third party ahead of Walmart’s. Relationships with Walmart suppliers are a key area in which conflicts can arise, so we need your help.

• Avoid forming personal relationships with Walmart associates that would compromise or appear to compromise the independence, integrity, impartiality, or judgment of Walmart associates. Where such relationships exist, they must be disclosed to Walmart. Whether a personal relationship is appropriate depends on the circumstances. Reach out to your primary Walmart business contact to discuss any potential issues.

• Do not offer gifts and entertainment to Walmart associates who might influence your business with Walmart or to any third party that might influence your business with Walmart (for example, audit firms and testing laboratories). Walmart associates and others who could influence Walmart’s business decisions are not permitted to accept gifts or entertainment, so please don’t offer them.

• Do not make donations on behalf of Walmart — Walmart will make its own giving decisions.

• You may provide product samples to Walmart for customary evaluation and testing according to Walmart policies and procedures, but you should ensure you’re providing no more than necessary and avoid the appearance of impropriety.

Walmart is committed to free and fair competition and conducts its business in compliance with antitrust and competition laws. We expect our suppliers to:

• Focus negotiation discussions on Walmart’s costs. Suppliers should not discuss costs to Walmart’s competitors, Walmart’s retail prices, or any other retailer’s non-public information, including price-related information. Walmart independently sets its retail prices and does not attempt to influence (directly or indirectly) our competitors’ terms or prices. This includes the prices of third-party sellers on Walmart’s marketplace.

• Refrain from asking Walmart to limit business with another company or limit sales of private label products.

• Do not offer or provide Walmart non-public, competitively sensitive information (e.g. on forward-looking pricing or strategy) related to Walmart’s competitors or other third parties. Suppliers should remember that they may be Walmart’s competitors where (for example) they sell directly to customers or with Walmart’s private label products.

Our suppliers are leaders in market intelligence and innovation. Putting the customer first means that we sometimes give suppliers access to Walmart’s property and non-public information, including customer information. Suppliers entrusted with this privilege are held to the same standards to which we hold ourselves.

• Do not share Walmart’s confidential information with any third party, including other retailers or suppliers. Confidential information includes any non-public, commercially sensitive, or proprietary information, including wholesale prices or other terms of supply, product plans, private label product designs and formulas, future or non-public retail prices, promotional plans or strategies, market intelligence, production or sales volumes or forecasts, and trade secrets.

• Protect personal information you receive from Walmart or collect on our behalf by implementing safeguards for its proper collection, storage, sharing, use, and destruction. Comply with all applicable privacy and data use laws and policies.
  

• Follow all applicable guidelines regarding the use of Walmart’s property — including Walmart’s intellectual property and funds — and guard against misuse.

• Submit only accurate and justified financial claims to Walmart.

• Do not allow Walmart to serve as a conduit for money laundering, terrorist financing, or fraud. Where relevant, establish and maintain controls designed to prevent such activity.

• Do not speak for Walmart. Where permitted by law, consult with Walmart prior to providing information about the company or its customers to a government or another requestor. If you need to help someone understand Walmart’s position on an issue, contact your primary Walmart business partner for assistance.

Walmart takes steps to ensure we are living up to our high standards and acting in a manner consistent with our values. Sometimes we ask our suppliers for help, and we need your cooperation.

• Cooperate with Walmart investigations related to potential violations of law, regulation, policy, contract, or these Standards. Respond to inquiries and requests for information and be upfront and honest.

• Make your products, facilities, and records available for audits, inspections, and tests. Obtain required audits, inspections, and tests in accordance with Walmart policy. Provide the results to Walmart and collaborate with Walmart to resolve any issues.

• Develop and maintain accurate records. These include financial records, production records, records of dealings with governments and government officials relating to your business with Walmart, and records of goods supplied to Walmart. Keep records sufficient to demonstrate your compliance with these Standards and all other Walmart expectations.

*Note: Numbers subject to change