Standards for Grantees

Message from Leadership

Sam Walton founded a values-driven company. Our business and our philanthropy - through Walmart Giving and the Walmart Foundation - remain grounded in four core values: respect, service, excellence, and integrity.

We hold our grantees to the same high standards we set for ourselves. When our standards are upheld through our grant-making, we build and strengthen trust with each other, our stakeholders, and the local communities we serve.

So, as you read our Standards for Grantees, 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 our communities every day.

Julie Gehrki
Senior Vice President, Walmart
President, Walmart Foundation

Our Culture and Values

Sam Walton founded a values-driven company that today is grounded in four core values: respect, service, excellence, and integrity.

Why We Have Standards

Walmart Foundation and Walmart are constantly changing, but our values are strong and consistent. Our Code of Conduct outlines the values and behaviors we expect of our associates; our Standards for Grantees complement the Code of Conduct by applying Walmart’s values to our relationships with grantees (as our Standards for Suppliers apply to our suppliers).

Who is Covered by Our Standards

These Standards apply to Grantees and their Subgrantees receiving funds or partnering with Walmart Foundation and Walmart Giving.

If you are a grantee or subgrantee, you are expected to uphold these standards in connection with activities funded by or conducted under the grant. Receipt of a grant and/or a signed grant agreement constitutes acceptance of these Standards and serves as the Grantee’s continuing affirmation of compliance during the grant term, while funds are held or used. In this document, we refer to anyone covered by the Standards as a "Grantee."

Our grantees include some of the largest and most well-known non-profits in the world as well as smaller organizations doing great work in a single community. Grantee activities span a wide range of social and environmental causes. Our grantees are often leaders in their respective fields and operate their own robust ethics and compliance programs. Regardless, Walmart and the Walmart Foundation hold each of our grantees to the same high standards. In applying these expectations, Walmart and the Walmart Foundation consider the size, resource, and operational sophistication of each grantee accordingly.

Grantees are responsible for reasonably complying with these Standards throughout their organizations and initiatives. This includes responsibility for the conduct of any subgrantees, suppliers, and agents they use as part of fulfilling their grant agreement with Walmart or Walmart Foundation.

Anyone who violates the Standards may be subject to consequences, up to and including termination of grants and other engagement with Walmart Foundation or Walmart. Walmart Foundation and Walmart reserve the right to audit or inspect grantees at any time and upon reasonable notice to determine whether they are complying with these Standards.

Operate the Right Way

We expect organizations receiving grants from us to do things the right way, not take shortcuts, and treat others with respect.

Comply with the Law and Agreements

Walmart and the Walmart Foundation believe in doing the right thing and are committed to complying with the laws of the places where we operate. We expect our grantees to do the same.

• Conduct your organization’s activities ethically and with integrity. Don’t do anything that would put Walmart or the Walmart Foundation at risk of violating the law, that might harm our reputation, or that could be perceived as misleading, defrauding, or exerting undue influence on Walmart or the Walmart Foundation.
• Understand and comply with all relevant laws. Activities must comply with the laws of both the location where they occur and the country where funds are transferred from.
• Comply with all applicable grant agreements, policies, procedures, and requirements. It is your responsibility to stay up to date on all applicable requirements. In the event these Standards or our policy require more than the law, you must follow these Standards.
• Obtain the licenses, permits, certifications, registrations, and rights necessary to operate and to execute your programs. Maintain these and comply with all conditions of issue. Remediate issues where they exist and bring your operations into compliance if they are not.

Understand and Manage Risk

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

• Understanding and assessing risks relating to your sector, programs, and workforce.
• Researching and staying up to date on the laws, regulations, standards, industry best practices, and knowledge relevant to your work.
• Adopting strong operations, safety, and quality management systems.
• Training your employees, sub-grantees, and partners.
• Knowing your sub-grantees and partners and monitoring their performance.
• As relevant, understanding and complying with policies that require grantees executing certain types of programs to disclose how and where those programs are executed and who is involved.
• Putting procedures in place to monitor your compliance with laws, policies, and these Standards.
• Assigning clear responsibility and accountability for compliance within your organization.

Prevent Bribery and Corruption

We expect grantees to support Walmart and the Walmart Foundation’s compliance with applicable anti-corruption laws and policies. We also expect our grantees to uphold these same values in their operations.

• 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. Bribes can take many forms, including cash, gifts, travel, meals, entertainment, offers of employment, and charitable or political contributions. For us, it is simple, bribery—of anyone, anywhere, at any level—is not allowed. This applies to all associates and any third party working on our behalf.
• 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, even if unsuccessful, to your primary contact with Walmart Giving or the Walmart Foundation. If you are uncomfortable doing so, report directly to Walmart Ethics (see contact details below).

Treat People with Respect

Walmart and the Walmart Foundation respect the dignity of every individual and value 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 our work or in our grantees’ operations.

• Grantees’ employees, volunteers, and beneficiaries 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 and program decisions based on neutral and objective criteria.
• In addition to complying with all applicable laws, grantees 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, please talk to your program officer.
• Provide a mechanism for workers, volunteers, or other stakeholders to report concerns to management, to you as the grantee, and to third parties. These mechanisms should allow for anonymity and prohibit retaliation by you as the grantee against any party for reporting in good faith.

Employ and Pay People the Right Way

We value our associates and believe that when we take good care of them, they will take good care of our communities. We believe the same is true for our grantees: organizations that treat their workers fairly and comply with relevant employment laws and agreements are better partners.

• 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.

Do Not Use Involuntary, Trafficked, or Underage Labor

People should not be exploited through employment, and Walmart and the Walmart Foundation have prioritized working with stakeholders to combat forced labor and other exploitative practices globally. Our grantees should 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, sub-grantees' operations or your contractors’ operations.
• 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 work 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.
• 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.

Operate Safe Environments

Walmart and the Walmart Foundation expect grantees to take responsibility for the safety and wellbeing of their workers and the people they serve.

• Provide a safe, clean, and healthy environment as appropriate for your work, geography, and workforce. This includes ensuring facilities and program sites 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. Establish proper maintenance, monitoring, and inspection routines, training and protection, and fire safety measures.
• Take appropriate steps to protect people 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 guests.

Protect the Environment

Walmart and the Walmart Foundation are committed to complying with environmental laws and advancing sustainability. We collaborate with grantees and others to inspire positive change and to help reduce emissions, eliminate waste, and preserve natural resources. We work with grantees who share these values and encourage grantees to develop their own sustainability goals.

• In addition to complying with all relevant environmental laws and regulations, grantees should:
  • 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.

Deliver Exceptional Programs and Products

Ensure Program Integrity and Safety

• Walmart and the Walmart Foundation earn trust by supporting safe, high-quality programs, products, and services. Our grantees should help us maintain trust by providing us and third-party recipients with goods, services, or technology that meet all legal, regulatory, industry, and safety, quality, and technical requirements.
• Implementing appropriate risk management systems and processes to protect against safety hazards. Grantees should have these systems validated and verified where appropriate.
• Monitoring goods, services, and technology you provide for safety and quality and promptly reporting material issues to us. Material issues include failing to meet regulatory requirements or recognized safety standards and defects that increase the risk of unsafe use.
• Participating actively with us and with regulatory authorities in the recall and removal of items.
• On goods and services you provide to us or third-party recipients, monitoring regulatory recall and removal requirements and following required recall and removal processes.

Follow Sanctions Laws

Our high expectations of grantees extend to their subgrantees and contractors, including executing programs the right way, following all sanctions laws, and ensuring that goods are transported safely and securely.

• Ensure that goods or programs are not produced or executed—in whole or in part—in violation of the law or in a way that would cause Walmart or the Walmart Foundation to violate the law.
• Establish controls to secure your supply chain from being used for improper purposes, including smuggling, terrorism, fraud, and theft. Maintain a safe and secure supply chain and ensure safety of your beneficiaries.
• Formulate and label goods in a way that allows them to be transported, stored, and distributed without compromising the items or the supply chain.
• Where the grantee is responsible for delivering goods, ensure containers and conveyances used are safe, sound, clean, and appropriate for safe and secure delivery.

Communicate Honestly

Earning and maintaining trust requires being accurate and transparent about the work we do. We cannot do it alone—grantees play a key role in helping us make informed decisions.

• Provide Walmart and the Walmart Foundation with timely and accurate information about the programs and services you provide. We rely on this information to make business, legal, and compliance decisions, among other purposes.
• Provide only genuine reports and data that are what they claim to be. Comply with relevant laws and regulations and be honest with stakeholders.
• Make sure all descriptions of your work, impact, and programs 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, goods and services must contain instructions adequate to use or consume them safely.

Collaborate with Walmart and the Walmart Foundation

Recognize and Avoid Conflicts of Interest

We ask our associates to avoid situations where they might put personal interests or the interests of a third party ahead of Walmart’s or the Walmart Foundation's. Relationships with grantees 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 us. Whether a personal relationship is appropriate depends on the circumstances. Reach out to your primary Program Officer or the Ethics hotline to discuss any potential issues.

Gifts and Entertainment:

• Do not offer gifts, tickets, and entertainment to Walmart associates who might influence your grant or to any third party that might influence your business with us. Walmart associates and others who could influence business or grant decisions are generally not permitted to accept gifts, tickets, or entertainment.
• Exception: Walmart associates may accept invitations to social activities associated with conferences and events (such as industry conferences, dinners, or salons hosted by NGOs or trade associations) where attendance serves a legitimate business purpose or professional development and is made available to similarly situated attendees free of charge.

• Do not make donations on behalf of Walmart or the Walmart Foundation—Walmart and the Walmart Foundation will make their own giving decisions.
• You may share materials or invite program officers to events in order to evaluate efficacy of your work, but ensure you are providing no more than necessary and avoid the appearance of impropriety.

Deal Fairly and Objectively

Walmart and the Walmart Foundation are committed to fair dealing and conduct our work in compliance with applicable laws. Our grantees should:

• Focus negotiation and proposal development discussions on program costs and impact. Grantees should not discuss confidential costs or information of other organizations. We independently make grant decisions and do not attempt to influence other funders’ terms inappropriately.
• Refrain from asking Walmart or the Walmart Foundation to limit support to another organization.
• Do not offer or provide us with non-public, competitively sensitive information related to other organizations or third parties.

Protect Data and Reputation

We sometimes give grantees access to Walmart’s property and non-public information; and in some cases, grantees have access to beneficiary information. When it comes to protecting privacy and safeguarding information, we expect the following:

• Do not share Walmart or the Walmart Foundation’s confidential information with any third party. Confidential information includes any non-public, sensitive, or proprietary information, including strategy plans, grant terms, and private data.
• Protect personal information you receive from us 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 our property—including intellectual property and funds—and guard against misuse.
• Submit only accurate and justified financial claims and reports. Do not allow Walmart or the Walmart Foundation 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 or the Walmart Foundation. Where permitted by law, consult with us prior to providing information about us to a government or another requestor. If you need to help someone understand our position on an issue, contact your primary Program Officer for assistance.

Cooperate with Walmart and the Walmart Foundation

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

• Cooperate with investigations related to potential violations of law, regulation, policy, grant agreements, or these Standards. Respond to inquiries and requests for information and be upfront and honest.
• Make your programs, facilities, and records available for audits, inspections, and tests. Obtain required audits, inspections, and tests in accordance with our policy. Provide the results to us and collaborate to resolve any issues.
• Develop and maintain accurate records. These include financial records, program records, records of dealings with governments and government officials relating to your grant, and records of goods/services supplied. Keep records sufficient to demonstrate your compliance with these Standards and all other expectations.