This comment examines whether corporate codes of conduct and more specifically, Wal-Mart’s Code of Conduct, are binding contracts between foreign suppliers and their employees or whether they are voluntary and non-contractual devices. An analysis of U.S. law and the text and implementation of Wal-Mart’s Code of Conduct reveals that the Code should not be interpreted as a contract binding on foreign suppliers and their employees for the breach of contract for denial of minimum and overtime wages, the breach of contract for forced labor, and the breach of contract for denial of the fundamental right to freely associate. The comment goes on to discuss the ramifications of this type of suit and other possibilities for bringing about the successful reform of labor conditions for foreign workers. This comment concludes that the best means for reform is not litigation but legislation. Part II of this comment discusses the historical origins of corporate codes of conduct and the role that they currently play within MNCs. Part III discusses how courts in the United States have interpreted corporate codes of conduct. Part IV analyzes the text and implementation of Wal-Mart’s Code of Conduct and determines whether it should be interpreted as a contract or mere guidelines in light of recent court rulings. Part V analyzes the impact of the lawsuit and discusses the appropriateness of other possible means for reforming foreign working conditions. Part VI draws conclusions with respect to the most effective means of impacting workers’ conditions, such as grassroot efforts.