Walmart investors joined the chorus of civil society organizations, worker groups and journalists drawing attention to the company’s treatment of its workers.  Last month, at Walmart’s Annual General Meeting, a suite of shareholder resolutions geared toward improving working conditions for Walmart’s 1.6 million US workers enjoyed significant increases in percentage of the vote won compared to previous years. On matters ranging from racial equity and justice in the company’s treatment of its workers to the critical issue of workplace safety, vote counts rose across the board .

This was particularly true in the case of Oxfam and co-filers' resolution which called on the company to conduct and publish the findings of a human rights impact assessment (HRIA). The proposal secured a notable 26 percent of the independent vote, more than doubling the support of last year's resolution on human rights due diligence.

“Workers’ rights are human rights” says civil rights leader Reverend William J. Barber, who presented Oxfam’s resolution to our fellow shareholders at this year’s AGM. As companies and investors are now increasingly coming to understand, one of the best ways to protect workers’ rights and ensure that companies respect these rights is to conduct HRIAs. By examining the real-life impacts employers’ policies have on workers - whether it be concerns over paying below a living wage or making it nearly impossible to access sick leave - HRIAs allow companies to understand and then address the risks their policies and practices are creating for their own workers (and in turn for investors).

In the case of Walmart, reports have indicated that the company’s labor practices – including the use of invasive worker surveillance technology and imposition of unreasonable working quotas – harm workers’ health, safety and overall well-being in a manner that further perpetuates poverty. Walmart’s outsized market control also empowers it to depress average wages overall, deepening economic inequality and creating a disastrous reality for the American worker at a time when many already struggle to get by.

Why human rights impact assessments?

As the largest private employer in the United States, Walmart’s relationships with workers and high-risk suppliers have the potential to expose it to significant reputational, legal, operational, and ultimately financial risks if it does not adequately identify and assess relevant human rights issues.

HRIAs can help mitigate these risks by enabling Walmart to identify, analyze, and address the root causes of those risks. In the absence of such tools, those risks go unchecked and can lead to reputationally harmful media reports like those alleging child migrant labor in US supply chains and insufficient wages and sick leave and failure to sufficiently accommodate pregnant workers in the company’s own workforce and operations.

HRIAs can also help prepare companies for regulatory changes, like the European Corporate Sustainability Due Diligence Directive and the Uyghur Forced Labor Prevention Act, thereby mitigating potential legal risks. For these reasons, Walmart competitors including Kroger, Jumbo, and Tesco have already committed to conduct HRIAs.

While Oxfam welcomes Walmart’s recent commitment to conduct an HRIA, to date the company has refused to take the steps necessary to ensure that the HRIA will meaningfully reduce risk: publishing the full findings of the study and explaining how the company intends to stop committing or contributing to human rights impacts.

Why is Walmart’s current assessment commitment insufficient?

While we applaud what is undoubtedly a step in the right direction, Walmart’s commitment falls short.

For one, it fails to include any assurance that it will communicate the findings of the assessment to investors (and other stakeholders)– one of the central pillars for a meaningful HRIA and therefore a critical omission. Investors should be afforded the opportunity to understand the risks in Walmart's operations and supply chains and as such, Walmart should disclose those risks and their plan for addressing them. Simply conducting the assessment is not enough, there must be a mechanism for transparency and accountability.

Further, to be effective, the publication of HRIA findings must include the specific disclosure of the actual human rights impacts identified, the company’s degree of responsibility for the same, and a timebound action plan for how the company intends to address any such impacts. While Walmart has announced a commitment to complete HRIAs, it has said only that the company will communicate its “aspirations, focus areas, progress and challenges” – not the findings nor an action plan for addressing them.

Again, Reverend Barber said it best: “We’re talking about human beings, and one of the best ways to protect workers’ rights and ensure that companies respect these rights is for there to be a human rights impact assessment.”

Overall, the results of last month’s shareholder vote reinforce what we know to be true: investors are responding to the emerging evidence of poor working conditions and gender and racial disparities at Walmart facilities with increasing concern for the risks presented by them to the viability of the company’s business model, and as a result, the financial risks they in turn pose to the companies’ investors. And they are now increasingly voting their shares accordingly.