As the leading retailer, grocer, and private employer,1 Walmart wields significant influence over the U.S. labor market and economy.2 Company policies and practices disproportionately impact BIPOC and female workers, as Walmart employs more Black people and women than any other U.S. company.3 In November 2024, Walmart rolled back its diversity initiatives, cutting racial equity training and eliminating supplier diversity programs.4 The decision was criticized by the NAACP5, the National Urban League6 and Walmart associates.7 Shareholders worry the move clashes with the Company?s stated commitment to fostering inclusion and opportunity for all and disregards evidence that DEI initiatives boost motivation and reduce attrition.8 Moreover, racial inequity poses macroeconomic risks that jeopardize long-term returns across asset classes by generating industry and economy-wide negative externalities and impeding inclusive and broad-based economic growth. A recent Citigroup study found racism and discrimination have cost the U.S. GDP $16 trillion since 2000 and addressing racial discrimination against African Americans could boost the U.S. economy by $5 trillion over ?ve years.9 Several aspects of Walmart's business suggest a racial equity audit would help mitigate reputational, regulatory, legal, macroeconomic, and human capital risk. The Company reports that people of color comprise 51% of its domestic workforce but make up only 30% of U.S. Of?cers10 and 18% of its Board of Directors.11 Walmart has also faced negative media attention over claims of racial pro?ling12, discriminatory hiring13 and promotion practices14, as well as poor working conditions15 and low wages.16 Political spending and lobbying may also have adverse racial impacts. In 2024, Walmart donated $7.5 million, including $3.5 million toward the passage of California's Proposition 36, a tough-on-crime initiative reclassifying petty misdemeanors as felonies.17 The California Secretary of State said the measure would increase the State prison and County jail population,18 a known cause of race-related economic inequality.19 Given its worker demographics and scale, we request Walmart assess its behavior through a racial equity lens to obtain a complete picture of how it contributes to, and could help dismantle, social and economic inequality. A racial equity audit would help Walmart identify, remedy and avoid adverse impacts on nonwhite stakeholders, communities of color, and long-term diversified shareholders. Failure to effectively address inequities in its operations exposes stakeholders, including employees, to unacceptable abuses and exposes Walmart to risks that may ultimately affect shareholder long-term value. 1