In November 2020, Ethical Consumer viewed Wal-Mart's Sustainability Hub website which contained a section on cotton.

It stated: "By 2025, Walmart U.S. stores will endeavor to source 100% more sustainable cotton for Walmart U.S. stores Private Brand apparel and soft home textile products."

It stated that its approach was to work with Better Cotton Initiative and certifications such as Organic and Fairtrade. It also said it would aim to use more recyled cotton. It provided no specific figures on how much of its cotton would be certified or how much was currently certified.

According to Anti-Slavery international (ASI) website viewed by Ethical Consumer in August 2018, Uzbekistan and Turkmenistan were two of the world’s largest exporters of cotton, and every year their governments forcibly mobilised over one million citizens to grow and harvest cotton. A questionnaire response from ASDA did state that it did not source from Uzbekistan but did not state whether this applied to the whole company group. Due to the high proportion of cotton likely to have come from Uzbekistan and Turkmenistan and the prevalence of forced labour in its production, the company lost half a mark in the Workers Rights category.

The Organic Trade Association website, www.ota.com, stated in July 2018 that cotton covered roughly 2.78% of global arable land, but accounted for 12.34% of all insecticide sales and 3.94% of herbicide sales. Due to the impacts of the widespread use of pesticides in cotton production worldwide the company lost half a mark in the Pollution & Toxics category.

According to the International Service for the Acquisition of Agri-Biotech Applications (ISAAA), a non-profit pro biotech organisation, genetically modified cotton accounted for 80% of cotton grown in 2017. Due to the prevalence of GM cotton in cotton supply chains and the lack of any evidence that the company avoided it, it was assumed that some of the company's cotton products contained some GM material. As a result it lost half a mark under the Controversial Technology category.

Overall the company received Ethical Consumer's worst rating for its cotton sourcing policy.

In November 2020, Ethical Consumer searched the Asda website for a policy on genetically modified ingredients and the use of genetically engineered animal feed. No information was found.
Ethical Consumer noted that the company sold meat and dairy not labelled organic, therefore it was likely to be from animals fed a genetically modified diet. In June 2017 the British government website www.food.gov.uk stated that the EU animal feed industry imported 70% of its maize, soya and rapeseed requirements; that "almost all" of the soya from the major producers Brazil, Argentina, Paraguay and the USA was genetically modified and that "much of" the maize imported from the USA was genetically modified.

The company therefore lost half a mark in the Controversial Technologies category.
www.food.gov.uk/science/novel/gm/gmanimal

In November 2020, Ethical Consumer searched for Wal-Mart's policies page on its website, corporate.walmart.com/policies, for information on whether the company had a policy prohibiting the use of genetically modified (GM) ingredients in its own-label products.

The company's GM policy stated: "Walmart has pledged to deliver on trust and transparency for our customers and the communities we serve. We are committed to selling food and products that meet high standards for safety, quality and affordability. Customers are also more interested than they were in recent decades in understanding where their food comes from, what’s in it and how it’s made. Walmart welcomes this development, and we are working on ways to help them make more informed buying decisions. In that regard, we supported legislation passed by Congress in 2016 that provided a uniform standard for the disclosure of bioengineered (BE) ingredients and foods, often referred to as GMOs. We are actively working with our private brand suppliers to meet the disclosure requirements established though USDA bioengineered labeling regulations.

We believe in providing our customers choices when shopping with Walmart. For our customers who prefer to avoid bioengineered foods, we offer a wide selection of USDA certified organic products. By law, bioengineered ingredients are not allowed in the organic program. In FY2020, we started revamping our produce areas that included making organic offerings easier to find, and better highlighting fresh produce prices to emphasize affordability. "

As the policy implied that Walmart sold genetically modified products, the company lost half a mark under Controversial Technologies.

In April 2018, Ethical Consumer viewed a report on the Oxfam America website, which had been released that month.

Walmart was said to have spent $2,144,415.58 lobbying for tax reforms, compared to $0 lobbying on issues regarding climate change. The report included a statement from the company:
"The tax reform framework released today is an important step in the right direction on tax reform. The framework recognizes the need to advance tax reform options that encourage investment in the United States, make U.S. business more competitive around the world, and help working families. We appreciate the efforts of the Big Six negotiators and look forward to continuing to be a constructive voice in the tax reform dialogue.”

Oxfam was calling for companies to take a more responsible to both taxation and lobbying by: committing to pay a fair share of tax, reporting on tax paid, advocating for a fairer tax system, disclosing all public donations, disclosing positions taken to influence public policy, and ensuring that lobbying and membership of industry bodies that conduct lobbying are in line with their company policies.

Wal-Mart lost a whole mark under Political Activities for lobbying for lower taxes.

In November 2020, Ethical Consumer viewed the entry for Walmart on the Opensecrets.org website, which was published in the USA by the Centre for Responsive Politics. This stated that in the 2020 election cycle individuals affiliated with the company had made $3,892,894 in political donations. $2,016,570 was said to have been donated to Democrats and $1,778,874 to Republicans.

NOTE: OpenSecrets states: “The organization itself did not donate, rather the money came from the organization's PACs, their individual members or employees or owners, and those individuals' immediate family members. Organizations themselves cannot contribute to candidates and party committees. Totals include subsidiaries and affiliates.”

In 2019, it had spent $6,430,000 on lobbying.

The company lost a whole mark under Political Activitives.

In December 2019 Ethical Consumer viewed the US Council for International Business Annual Report 2017-18. The report listed Wal-Mart as a member. The USCIB described itself as "founded in 1945 to promote an open world trading system, now among the premier pro-trade, pro-market liberalization organizations ...provides unparalleled access to international policy makers and regulatory authorities." Ethical Consumer noted that free trade lobby groups had been criticised by campaigners for lobbying for business interests at the expense of the environment, human rights and animal welfare. The company therefore lost half a mark under Political Activities.

In December 2019, Ethical Consumer viewed an article on the Reuters website, titled 'Walmart to pay $282 million to settle seven-year global corruption probe' and dated to 20 June 2019. The article stated:

"Walmart Inc said on Thursday it will pay $282 million to settle a seven-year-long investigation into whether its overseas units in Mexico, Brazil, China and India violated the U.S. Foreign Corrupt Practices Act...

""The Justice Department launched an investigation of the retailer after a series of New York Times articles in 2012 described alleged bribes paid by Walmart in Mexico to obtain permits to build stores there.

"The reports spurred a wide-reaching investigation by the department into the behavior of Walmart subsidiaries around the globe, including in Mexico, Brazil, China and India.

"“Walmart profited from rapid international expansion, but in doing so chose not to take necessary steps to avoid corruption,” Assistant Attorney General Brian A. Benczkowski of the Justice Department’s Criminal Division said on Thursday.

"The Justice Department said the failures led Walmart’s subsidiaries in Mexico, India, Brazil and China to hire third-party intermediaries and allowed these middlemen to make improper payments to government officials to obtain store permits and licenses."

The company lost a mark under Anti-Social Finance.

In November 2020, Ethical Consumer viewed the 2020 Proxy Statement for Walmart Inc., which included details of five directors' remuneration. All received well over £1million, with the highest compensated receceiving $22,105,350. Ethical Consumer considered any remuneration over £1million to be excessive. The company therefore lost half a mark under Anti-Social Finance.

In November 2020, the Asda Group accounts were downloaded from Companies House. This stated that the highest paid director received remuneration of £2.6million in 2018. Ethical Consumer considered any payment over £1million to be excessive, and the company therefore lost half a mark under Anti-Social Finance.

In November 2020, Ethical Consumer searched the corporate database D&B Hoovers, along with Walmart Inc's 2020, Annual Report for information on the company's subsidiaries. The company was found to have many subsidiaries registered in countries considered by Ethical Consumer to be tax havens at the time of writing, several of which were high risk company types for tax avoidance, including:

- Fit Holdings (Luxembourg, holding company)
- WM Latin American Holdings (BVI) III Corp. (British Virgin Islands, holding company)

The company's 2020 Annual Report also showed that it was registered in Delaware, also considered to be a tax haven, despite the executive offices being based in Arkansas.

An internet search using the search terms “Walmart tax policy statement country” found no country-by-country financial information or reporting (CBCR), nor clear public tax statement confirming that it was this company’s policy not to engage in tax avoidance activity or to use tax havens for tax avoidance purposes.

Given that Walmart Inc. had two or more high risk subsidiaries in jurisdictions on Ethical Consumer's tax haven list as well as a UHC in a tax haven and no country-by-country financial information, nor adequate policy statement and narrative explanation, the company received Ethical Consumer's worst rating for likely use of tax avoidance strategies and lost a full mark under Tax Conduct.

The Institute on Taxation and Economic Policy (ITEP) published a report in March 2017: The 35 Percent Corporate Tax Myth; Corporate Tax Avoidance by Fortune 500 Companies, 2008 to 2015.

The report documented just how successful many Fortune 500 corporations had been at using loopholes and special breaks over the past eight years, in order to have paid less than the 35% federal income tax on their U.S. profits - with many having paid nothing at all.

ITEP stated: "As lawmakers look to reform the corporate tax code, this report shows that the focus of any overhaul should be on closing loopholes rather than on cutting tax rates."

The report included only corporations which had been consistently profitable every year between 2008 to 2015. By leaving out corporations that had losses in any one year (which means they wouldn’t have paid any tax), the report provides a straightforward picture of average effective tax rates paid by the 258 biggest and most consistently profitable U.S. companies.

The report found that one hundred of the 258 companies (39 percent of them) paid zero or less in federal income taxes in at least one year from 2008 to 2015.

The sectors with the lowest effective corporate tax rates over the eight-year period were Utilities, Gas and Electric (3.1%), Industrial Machinery (11.4%), Telecommunications (11.5%), Oil, Gas, and Pipelines (11.6%), and Internet Services and Retailing (15.6%). Each of these industries paid, as a group, less than half the statutory 35 percent tax rate over this eight-year period.

Wal-Mart Stores was one of the companies in the report. Over the eight year period covered by the report, the company was found to have made US$139,743.0 million profit, on which it paid US$43,480.0m tax. This worked out at a rate of 31.1%.

In light of this story, Wal-Mart lost a whole mark under Anti-Social Finance.

A report published by Citizens for Tax Justice on October 2016 criticized US tax policy on large multinational corporations. Many multinational corporations used accounting tricks to pretend for that a substantial portion of their profits were generated in offshore tax havens, countries with minimal or no taxes where a company’s presence could be as little as a mailbox.
The study examined the use of tax havens by Fortune 500 companies in 2015. It revealed that tax haven use was ubiquitous among America’s largest companies and that a narrow set of companies benefited disproportionately.
Amongst these companies Walmart was named as one of the Top 30 companies with the most money held offshore. The amount held offshore was $26.1 billion. Neither the overall rate of the tax paid on this overseas cash, nor any estimate of the US tax avoided, were disclosed. The company lost a whole mark under Anti-Social Finance in light of this report.