Untitled

Table of
Contents
A Message from Our CEO
4
Our Values and Our Code
6
How to Use Our Code
8
Why We Have a Code
9
Who is Covered by Our Code
9
When to Speak Up 10
How to Speak Up 10
Speak Without Fear of Retaliation 11
Integrity Builds Trust 12
Trust Begins with You 14
Make Ethical Decisions 15
Recognize and Avoid Conflicts of Interest 16
Build Trust with Our Associates 20
Create a Safe Place to Work and Shop 21
Respect Each Other 22
Work the Right Way 24
Build Trust with Our Customers 26
Sell Safe Food and Products 27
Protect the Environment 28
Deliver Quality Healthcare 29
Build Trust in Our Business 30
Compete Fairly 31
Never Engage in Bribery 32
Keep Accurate Records 34
Follow International Trade Rules 35
Prevent Money Laundering and Consumer Fraud 36
Use Data and Technology Respectfully and Ethically 38
Source Responsibly 39
Protect Our Property 40
Don’t Misuse Inside Information 41
Resources 42
2
3
We set out almost six decades ago to be a company that would
save people time and money and help them live better. We
had no way of knowing in those early days what an enormous
opportunity we would have to use the scale of our business to
make a difference. As the world around us continues to change—
at a faster rate today than when we started out—we reaffirm our
commitment to not just adapt and grow, but to lead.
We remind ourselves each day that our work isn’t just about
what we achieve but how we achieve it. The way we conduct
our business is as important as the products we sell and the
services we provide. That means complying with the laws of
the communities where we do business. But that is not enough.
Associates who work at Walmart are expected to operate based
on our values. Our expectation is you will put fairness, equity,
justice, and integrity at the heart of everything you do. By
working this way, each one of us will play an active part in shaping
our culture, building trust, and making it possible for us to reach
our purpose and potential as a company.
Our Code of Conduct reflects what’s important to us. It applies
to all of us—to me, to our Board members and officers, and to
every Walmart associate. We also expect our business partners
to embrace our values and meet these high standards. Associates
and partners who do not share these values do not belong at
Walmart.
Please read our Code. Refer to it often. Let it guide you to make
honest, fair decisions and comply with the laws and policies that
apply to our conduct. At its heart is a simple guideline: do the
right thing and speak up whenever you have a concern or see
something wrong.
Thank you for doing your part.
A Message
from Our CEO
Doug McMillon
President and CEO
Walmart Inc.
4 5
Our Values
The trust of our customers, communities, associates, and business partners is our competitive advantage.
It’s important to think about our behaviors and make sure that we are creating a culture that inspires trust.
Sam Walton founded a values-driven company that today is grounded in four core values: respect, service,
excellence, and integrity. These values are timeless. When our behaviors are aligned to those four values,
we’ll build trust, create the right environment for our teams, and generate success.
Acting consistently with our purpose and our values demands that a culture of integrity guides all our
decisions. We are dedicated to doing business the right way. Our Code reflects who we are as a company
and shows how we bring our culture of integrity to life in our work every day. Integrity builds trust. That’s
why our associates, customers, investors, suppliers, and business partners choose Walmart—they know we
are a business they can trust.
Our Values and
Our Code
Respect for the Individual
We treat people with dignity, lead by example, and listen to each other.
We seek and embrace differences in people, ideas, and experiences.
Service to the Customer
We put our customers first, anticipate their wants and needs,
and exceed their expectations.
Strive for Excellence
We are a high-performance team and expect the best from ourselves.
We own our work and results.
Act with Integrity
We are honest, fair, and objective. We speak up about concerns and
comply with all laws and our policies.
“…There’s no substitute for hard work, integrity, and a dedication to
leaving this world a little better place than when we came into it.”
– Sam Walton, Founder, Walmart Inc.
6 7
Build trust with
our associates
Build trust with
our customers
Build trust in
our business
How to Use
Our Code
Why We Have a Code
Walmart is a retail company—as well as a logistics, healthcare, manufacturing, real estate, and
technology company. We are constantly changing. We make many decisions every day, and the right
thing to do isn’t always clear. Our Code can help us make decisions that earn and build trust. It tells us
about the behaviors we expect of each other and where to get more information or support. Our Code
focuses on behaviors that:
Our Code reinforces that Walmart is committed to complying with the laws and regulations in all locations
where we operate. Because we are a U.S. company operating globally, our associates around the world
often are subject to additional legal requirements, including some U.S. laws. When local laws or common
practices are not as strict, our Code still applies. If you believe our Code conflicts with local law, contact
our Legal department for guidance on what to do.
Who is Covered by Our Code
Our Code applies to all associates of Walmart and its subsidiaries. It also applies to Walmart’s and its
subsidiaries’ board members when they are acting in their capacity as our directors. Our Code is translated
into multiple languages so that our associates can easily understand it. Walmart may modify the content
of our Code of Conduct as we change and face new issues. We expect our suppliers, vendors, service
providers, and other business partners to act with integrity and honor our values. Specific requirements
for these third parties are included in the Standards for Suppliers and/or in our contracts with them.
Associates who violate our Code may be subject to discipline, up to and including termination.
In rare cases, it might be appropriate to waive a part of our Code. To request a waiver, contact Ethics &
Compliance in advance of the activity for which you want the waiver. When executive officers or directors
seek waivers, only Walmart’s Board of Directors (or a committee of the Board) may grant them, and they
will be publicly disclosed when required by law.
8 9
When to Speak Up
Building trust requires we do the right thing and speak up if we have questions or concerns. If you don’t
know the right thing to do, ask for advice from your manager, your People Lead, or Ethics & Compliance.
Ethics & Compliance can provide you with an opinion on the right action to take. Make your voice heard
and get the answers you need.
If you see, suspect, or are told about activity that violates our Code, compliance policies, the Standards
for Suppliers, or the law, you must report it. Looking the other way or letting someone else take the lead
may seem easier, but unethical or unlawful behavior hurts us all. It erodes trust. Report your concerns and
cooperate fully and honestly in all internal investigations.
How to Speak Up
Most concerns can be reported to your manager, People Lead, Ethics & Compliance, or Legal.
However, if your concern is about one of the following, it must be immediately reported directly to
Global Ethics & Compliance:
• Bribery (including any suspected violation of
our Anti-Corruption Compliance Policy)
• A company officer or direct report to any
company CEO potentially violating our Code
• Falsifying financial records or interfering
with our internal controls on accurate
financial reporting
Global or local policies may indicate additional matters that must be reported directly to Ethics &
Compliance.
All reports to Ethics & Compliance are treated as confidentially as possible. It helps with follow-up if you
identify yourself. If you are not comfortable identifying yourself, you can make anonymous reports to the
Ethics Helpline to the extent allowed by law.
Speak Without Fear of Retaliation
Walmart does not tolerate retaliation for reporting a concern or participating in an investigation. Any
associate who engages in retaliation will be subject to disciplinary action. If you feel that you have been
retaliated against for reporting a concern, contact your People Lead or Ethics & Compliance.
We know it takes courage to come forward and share your concerns. Discouraging associates from
reporting an ethics concern is prohibited and could result in disciplinary action. When we speak out against
things that are wrong, we uphold our values and Code. Reporting an issue in good faith will not get you
in trouble, even if you make an honest mistake. Knowingly reporting false information is contrary to our
values and will be subject to disciplinary action.
We appropriately investigate reports of misconduct. We share information only on a need-to-know basis. If
you are asked to participate in an investigation, give honest and complete answers, and do not discuss the
investigation with other associates.
Talk to your manager, next-level manager, People Lead, Ethics & Compliance, or Legal.
www.walmartethics.com ethics@walmart.com
800-963-8442 (1-800-WM-ETHIC) in the U.S., Canada, and Puerto Rico, or your local phone
number which is listed at the end of our Code. The Ethics Helpline is available 24 hours a day,
7 days a week and is available in most local languages.
Walmart Inc.
Attention: Global Ethics & Compliance, 702 SW 8th Street, Bentonville, AR 72716-0860
Ways to Reach Out
10 11
Trust Begins
With You
Build Trust with Our
Associates
pages 14-19 pages 20-25
Build Trust with Our
Customers
Build Trust in Our
Business
pages 26-29 pages 30-41
12 13
Integrity in Action • Follow the law. Learn about the laws that apply
to your role and our business.
• Know our Code and live our values. Review
our Code and understand how it and our
policies apply to your job. Associates must
complete any required training on our Code
and acknowledge that they have read and
understand it.
• Act in Walmart’s best interest. Never allow
personal interests to impact the business
decisions you make as a Walmart associate.
• Be honest. Be transparent and make decisions
that reflect our values.
• Lead by example. Talk about our Code and
our values with your fellow associates and
team members.
• When in doubt—reach out. If you have
questions or concerns, let your manager,
People Lead, Ethics & Compliance,
or Legal know.
Trust Begins
with You
Make Ethical Decisions
We build trust when we make decisions consistent with our values and take responsibility for our actions.
Being ethical means doing the right thing even when no one’s watching.
Leaders have a duty to promote
integrity and build trust. If you lead
or supervise others, Walmart expects
you to:
1. Set expectations consistent with our
values, handle questions or concerns
properly, and report issues as
required by policy.
2. Listen to associates who seek advice
or raise concerns.
3. Take reports of misconduct seriously
and ensure they are properly handled.
4. Stand firm against harassment,
intimidation, and retaliation.
Role of Managers
• Is it legal? • Is it consistent with our values
and Code?
• Is it in Walmart’s best interest?
If the answer to any of these is “No,” don’t
do it. If you’re not sure of the answer, reach
out to your manager, People Lead, Ethics &
Compliance, or Legal for guidance.
Before You Act,
Ask These Questions
“Don’t compromise
your reputation. It’s a
precious commodity. Don’t
compromise your integrity…
have a good name.”
– Sam Walton, Founder, Walmart Inc.
14 15
Recognize and Avoid Conflicts of Interest
Fair and objective decisions build trust with our associates, customers, and third parties. When making
business decisions, we put Walmart’s interests before personal interests. A conflict of interest occurs
when personal interests interfere with, or may appear to interfere with, our work at Walmart. While
we can’t list every circumstance, it’s important to know and avoid the common situations that could
create a conflict or the perception of a conflict. Outside employment, financial investments, gifts and
entertainment, and personal relationships are areas where conflicts can arise.
If you realize an activity or situation could influence or appear to influence your ability to make objective
business decisions, let your manager, People Lead, or Ethics & Compliance know. They can help you take
steps to avoid or resolve a conflict.
Outside Employment and Business Interests
• Do not work for a competitor while you
are a management associate or a salaried
associate. Hourly associates should discuss
with their managers to determine if a conflict
exists before accepting employment with a
competitor.
• Do not use your Walmart role to promote
your side business. Your side business cannot
interfere with your work at Walmart or use
Walmart resources, including your associate
discount card. It cannot supply products to
Walmart, supply products to any current or
potential Walmart supplier with whom you have
a business relationship or influence, compete
with Walmart, or reflect negatively on Walmart.
• While working for Walmart, you may identify
a business or investment opportunity that
Walmart may have an interest in pursuing. Do
not take opportunities for yourself that you
discover through your position or the use of
Walmart property or information.
Financial Investments
• Do not invest in a Walmart supplier if you
can influence Walmart’s relationship
with that supplier.
• Do not have a substantial interest (for example,
stock ownership) in a competitor. Consult
the Global Conflicts of Interest Policy
for specific restrictions.
Gifts and Entertainment
• Decline gifts and entertainment from a supplier
if you work with or could work with that supplier
in your Walmart role. Accepting any benefit from
suppliers that we work with can cause a conflict
and drive up the cost of doing business.
• Explain our policy on gifts and entertainment
to new suppliers. Customs may differ in the
countries where we work, but our policy on
gifts and entertainment applies everywhere
we do business.
• Decline gifts and entertainment from any
government official.
• We often sample or test merchandise to help
us better understand a product or business
we may want to purchase. This is not a conflict
so long as we reasonably limit sampling.
Follow your local policy regarding sampling
and testing products.
Ask these questions when you’re unsure about whether a situation may lead
to a conflict or the perception of a conflict:
1. Could this influence my objectivity or judgment in decisions?
2. Could this appear to others to be a conflict?
If the answer is “yes” to either of these questions, or if you aren’t sure of the answer, reach out to
your manager, People Lead, or Ethics & Compliance for advice.
Think about it
Global Conflicts of Interest Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
16 17
Associate Relationships
Family
Do not supervise or be directly involved in the
hiring of a family member. Do not influence
the conditions of employment (for example,
pay, work hours, or job responsibilities) or
performance rating of any family member. In
certain rare circumstances, the company allows
family members to work in the same reporting
chain if there is enough separation. It is unlikely
in a store, club, or distribution center that there
would be enough levels of separation. If you learn
that a family member is being considered for
employment or is hired into your reporting chain,
you should disclose this to your manager, People
Lead, or Ethics & Compliance.
• A family member is any relative (spouse,
child, parent, sibling, grandparent, or
grandchild) by birth, adoption, marriage,
domestic partnership, or civil union as well as
any member of your immediate household,
regardless of whether you are related.
Romantic
Do not have a romantic relationship with
another associate if the associate is in your
chain of command or you have influence over
the associate’s conditions of employment or
performance rating. If an associate with whom
you already have a romantic relationship comes
under your supervision due to a change in
organizational structure, you should immediately
disclose the relationship to your manager, People
Lead, or Ethics & Compliance.
• A romantic partner is someone you
are dating or with whom you have
a sexual relationship.
Yes, if the depth of your close personal
friendship impacts your ability to make
objective decisions. A close personal
friendship is not simply participating in
some of the same community activities.
Attending the same house of worship,
having children on the same sports team, or
being in the same neighborhood association
would not by itself make you close personal
friends. It can be difficult to determine
on your own whether a close personal
friendship could impact your objectivity.
Talk with your manager, People Lead, or
Ethics & Compliance about how to best
manage the business situation if a close
personal friend is involved.
Can friendships cause
a conflict of interest?
Supplier Relationships
• If a close personal friend, family member,
or romantic partner works for a supplier
over which you have influence, disclose it
to your manager, People Lead, or Ethics &
Compliance to get advice on managing
the potential conflict.
• Before participating in the selection of a
supplier which employs your family member,
close personal friend, or romantic partner,
disclose the relationship to your manager,
People Lead, or Ethics & Compliance to get
advice on how to manage the potential conflict.
I work in Financial Services, and I received a birthday gift from a friend who is also a toy supplier.
Can I keep the gift?
Yes. In your job, you have no influence over Walmart’s business relationship with this supplier.
If you were in a role where you have influence over Walmart’s relationship with the supplier,
talk to your manager, People lead, or Ethics & Compliance to get advice on how to
handle the situation.
I live in a neighborhood with multiple Walmart merchandise suppliers. I work in Merchandising.
My neighborhood has numerous block parties where the whole street is invited. Is it a conflict for
me to attend?
No, it is not a conflict for you to attend. You can participate in normal neighborhood social
functions but be mindful of how others may perceive your social interactions with suppliers
over which you have influence.
What if?
Global Conflicts of Interest Policy
18 19
Build Trust with
Our Associates
Integrity in Action
• Stop a task if conditions are unsafe and report
the concern. Watch for hazards that could
harm you or others.
• Don’t work under the influence. Alcohol and
improper use of drugs can affect your work and
the safety of people around you.
• Protect yourself. Use proper safety gear and
follow all training and procedures. Know what
to do in case of an injury or emergency.
• Be careful operating machinery. Do not
operate machinery or equipment unless you
are trained, have the proper safety gear, and
are following all health and safety procedures.
• Follow safe driving requirements.
Show concern for others on the road. Getting
there safely is more important than getting
there quickly.
• Zero tolerance for violence and threats.
Immediately report concerning behavior to a
salaried manager or your Security Manager/
Asset Protection Manager.
• Follow health and safety laws and our policies.
Know the health and safety procedures that
apply to your role and follow them.
Create a Safe Place to Work and Shop
Making Walmart a safe place to work and shop builds trust with our associates and customers—and it’s
the right thing to do. If you see something that could put someone’s health or safety at risk, report it
immediately and take action to keep yourself and others safe.
The back room is full of boxes and
many of the walkways are blocked. It
doesn’t feel safe, but my department
manager said not to worry about it.
What should I do?
It’s not okay to ignore a safety
hazard even if your manager says
not to worry about it. Talk with
another manager or your People
Lead about your concerns. If you
still have a safety concern following
your discussions, contact Ethics
& Compliance.
What if?
Global Environmental, Health & Safety Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
20 21
Respect Each Other
Living our value of Respect for the Individual starts with valuing diversity and inclusion. We believe having
associates with different backgrounds, styles, experiences, identities, and opinions makes us a better
company. Inclusion is an intentional act—it is investing time and energy to understand, support, and
champion the uniqueness of individuals. Diversity and inclusion promote individual expression, creativity,
innovation, and achievement—and help us better understand and serve our customers.
We are committed to a workplace that is free of harassment and discrimination. We do not tolerate any
behavior that diminishes the dignity of a person, inappropriately or unreasonably interferes with work
performance, or creates an intimidating, hostile, or otherwise offensive work environment based on an
individual’s protected status. We also do not tolerate retaliation against anyone who raises a concern
about harassment or discrimination. Integrity in Action
• Treat others how they want to be treated. Be
fair and respectful to associates, customers,
members, suppliers, and third parties who work
with Walmart. Value others’ differences and
listen to different points of view.
• Hire and promote the right way. Hire, retain,
and promote associates based on qualifications,
demonstrated skills, achievements, and other
merits.
• Prevent harassment. Set the right tone and
expectation for appropriate behavior with
your team members and peers. Verbal, visual,
or physical conduct of a sexual nature is not
acceptable.
• Lead by example. Be inclusive with your
actions and words. Understand how your
actions and comments may be perceived
or misunderstood by others. Set clear
expectations with your team.
• Follow harassment and discrimination laws
and our policies. Know what behaviors are
considered harassment or discrimination and
create a respectful and inclusive workplace.
• Speak up. Never tolerate harassment
or discrimination. Report harassment or
discrimination to your manager, People Lead,
or Ethics & Compliance.
• Race
• Color
• Ancestry
• Ethnicity
• Religion
• Sex
• Pregnancy
• National Origin
• Age
• Disability
• Marital Status
• Veteran Status
• Military Status
• Genetic
Information
• Sexual Orientation
• Gender Identity
or Expression
• Any Other Legally
Protected Status
Walmart does not tolerate discrimination or harassment
based on an individual’s:
• Unwelcome sexual advances or remarks
• Slurs or inappropriate jokes based on a
protected status
• Displaying written or graphic material
that ridicules, insults, or shows hostility
toward a group or individual based on a
protected status
• Distributing pornographic or sexually
suggestive content
• Intimidating acts, such as bullying or
threatening, concerning or based on a
protected status
Examples of harassment:
Global Discrimination & Harassment Prevention Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
Walmart complies with all laws in the countries in which we operate.
“We must work together to
actively shape our culture to be
more inclusive, not just accepting
our differences…but celebrating
them…everyday…in every part of
the company.”
– Doug McMillon,
President and CEO, Walmart Inc.
22 23
Work the Right Way
At Walmart, our associates are the key to our success. We pay people accurately for their work and hours.
We respect human rights and prohibit the use of underage or forced labor anywhere we do business.
We believe that when we take good care of one another, we will take good care of our customers
and communities.
My manager asked me to gather carts on my way out to my car after my shift.
Is this allowed?
No. Tell your manager you have already clocked out and you do not want to violate company
policy by working off the clock. If your manager insists or gives you a hard time, report this to
your next level manager, People Lead, or Ethics & Compliance.
What if?
Integrity in Action
• Verify eligibility. Managers or People Leads
should inspect, verify, and document the
identity and employment authorization of
every new associate, including associates on
global assignment in a country different from
their home country.
• Work only when compensated. Do not
perform work without pay. Know and follow
the procedures related to breaks, days of rest,
and overtime.
• Choose partners carefully. Only work with
suppliers and vendors who have all necessary
internal approvals. Suppliers must uphold our
Standards for Suppliers and their contracts.
• Follow all labor, employment, and
immigration laws and policies. Know the labor
and employment policies and procedures that
are relevant to your role.
Global Labor & Employment Policy
Standards for Suppliers
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
24 25
Build Trust with
Our Customers
Sell Safe Food and Products
We take our responsibility as one of the world’s largest grocers and retailers seriously. Our customers
expect that the food and products they buy from us are safe. To earn their trust, we must source,
transport, prepare, and sell safe and compliant food and merchandise. We have high internal standards,
and we expect the same of our suppliers.
Integrity in Action • Respond quickly to product recalls and removals.
To keep customers safe, execute recall and removal
processes with urgency.
• Report possible food or product hazards. If you
become aware of a safety issue with an item, tell your
manager and contact Ethics & Compliance.
• Deliver end-to-end food safety. We maintain food
safety throughout our supply chain—from supplier or
Walmart processing facility, through transportation
and warehousing, to online distribution or sale in a
store—there are food safety requirements in each
stage. Follow the requirements that apply to you.
• Follow the Food Safety High Five. Know and follow
the Food Safety High Five to keep food safe.
• Know your suppliers. Only source from suppliers that
follow our food and product safety requirements.
• Follow food and product safety laws and our policies.
Know the food safety and product safety procedures
that are relevant to your role and follow them.
One of my coworkers in the Deli
often fails to wash her hands when
she returns from a break. I talked
to her about how important it is
to wash hands, but she still isn’t
washing them every time. What
should I do?
Washing hands properly every
time is required and is key to
keeping our food safe. Talk to any
member of your management
team about this situation. If your
concerns are not addressed
by your management, contact
Ethics & Compliance.
What if?
Food
Safety
High
Five
Know the
High Five, &
follow them
while working
with food.
• Wash hands when necessary
• Do not work with food if you are ill
• Never touch ready-to-eat food with bare hands5
• Do not store raw foods over
cooked or ready-to-eat foods
• Never prepare ready-to-eat
foods on the same surface or
with the same utensils used
to prepare raw animal proteins
• Keep cold foods
at proper
temperature
• Keep hot foods
at proper
temperature
• Cook foods
thoroughly
• Rapidly chill
foods
• Properly wash, rinse
and sanitize all food
contact utensils and
equipment Cook it
& Chill it
Wash, Rinse, 4
& Sanitize 2
Keep it Cold,
Keep it Hot 1
Be Clean,
Be Healthy
3
Don’t Cross
Contaminate
Global Food Safety Policy, Global Product Safety Compliance Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
26 27
Protect the Environment
We care about our communities, and we all have a role to play in protecting the environment. Designing
our facilities and operating our business responsibly and consistent with environmental obligations helps
us sustain our resources and care for our planet. It’s not only what we do, but how we do it that makes
the difference.
Integrity in Action
• Segregate and recycle. Help reduce waste by
following your market programs to segregate
and recycle materials.
• Correctly handle hazardous items.
Appropriately transport, handle, and dispose
of hazardous items. Follow corporate market
programs to ensure compliance with hazardous
materials and hazardous waste regulations.
• Report environmental hazards or unnecessary
waste to management. If you see an
environmental hazard or a waste of resources,
alert management.
• Follow environmental laws and our policies.
Know and follow the environmental policies and
procedures relevant to your role.
Deliver Quality Healthcare
We are committed to providing healthcare when and where our customers need it. Delivering service and
products the right way strengthens our customers’ trust in us.
Integrity in Action
• Adhere to professional standards. Maintain all professional
licenses and certifications as required for your role. Report
to your manager all issues associated with your ability to
legally perform your job duties. Do not provide professional
services beyond the authority of your licenses and
certifications or if your required credentials lapse or
are revoked.
• Provide quality care. Providing quality patient care in a safe
and responsible manner is our mission. You are expected
to exercise sound professional judgment and work to
understand the healthcare needs of the patients you serve.
• Properly handle and dispense prescription medication.
Follow all laws, regulatory entity rules, and policies for the
safe handling, prescribing, and dispensing of prescription
medication. Report accidental or improper prescribing
or dispensing to your manager, in the established error
reporting systems, or to Ethics & Compliance in a manner
that complies with any applicable local privacy laws.
• Protect patient confidentiality. Prevent the improper use
or disclosure of patient health information. Never look
up patient information that is not needed for your role.
• Bill fairly and accurately for products and services.
Payments received in error must be refunded, and all billing
errors should be investigated and resolved. Billing for
medical services must be accurate and timely, and services
must be medically necessary.
• Follow healthcare laws and our policies. Know the health
and wellness procedures that are relevant to your role and
follow them.
Global Environmental, Health & Safety Policy Global Health & Wellness Compliance Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
28 29
Build Trust in
Our Business
Compete Fairly
We believe success comes from offering quality products and services through free and fair competition.
Anti-competitive practices harm our customers. Fair competition leads to stronger innovation, lower
prices, and better quality.
Integrity in Action
• Compete independently from our competitors.
Don’t share sensitive information with competitors
such as pricing, costs, bid submissions, or strategic
plans. Don’t make agreements with competitors or
others that limit competition. For example, don’t
agree on price, terms of sale, assortment, margins,
promotions, or allocation of products, customers,
or markets.
• Interact with suppliers and other third parties the
right way. Focus on Walmart’s goal to better serve
our customers. We must be careful to not seek out
or pass along confidential information about our
competitors via our suppliers. We also must not
share confidential information about our suppliers
with other suppliers. If confidential information
or an improper agreement comes up, stop the
conversation. Make it clear you don’t want to
participate and report the incident.
• Conduct market research properly.
Never encourage anyone to improperly give
you confidential information.
• Be honest and accurate. Always be truthful
in pricing, marketing, and advertising.
• Sell products the right way. Know which
products have sales restrictions (for example,
alcohol and tobacco), and follow the restrictions.
• Seek guidance. If you are ever unsure
whether a conversation or agreement is okay,
ask Legal for advice.
• Follow competition and consumer protection
laws and our policies. Know the antitrust and
consumer protection policies and procedures
that apply to your role and follow them.
• Report suspected violations. Any suspected
violations of Walmart’s Antitrust and
Competition Law Policy must be reported to
Ethics & Compliance or Legal.
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
Global Antitrust & Competition Law Policy
Global Consumer Protection Policy
30 31
Integrity in Action
• Do not offer or accept bribes. Laws in some
countries make a distinction between bribing
a government official and bribing a nongovernment official. We don’t rely on those
distinctions. For us, it is simple, bribery—of
anyone, at any organization, at any
level—is wrong.
• Third parties must not pay bribes. Any person
or company working on Walmart’s behalf may
not offer, give, or receive a bribe. If the only
way to make a deal or complete a service for
Walmart is through payment of a bribe, we
expect third party service providers to refuse
and to report it. Bribes are not how we
do business.
• Engage Anti-Corruption Compliance. Get
approval from Anti-Corruption Compliance
and Legal before entering into any agreement
with a government or engaging a third party
intermediary.
• Follow anti-corruption laws and our policy.
Walmart is committed to following all
applicable laws regarding the prevention
of bribery and corruption. Know and follow
your local Anti-Corruption Compliance
Procedures and controls. Follow the Giving
Procedures with respect to in-kind and
monetary donations.
• Immediately report allegations of bribery
or attempted bribery directly to Global
Ethics & Compliance.
Police officers have stopped trucks leaving our distribution center and said they would delay
deliveries unless the driver pays the police $50. My manager said we should carry $50 gift cards
to pay the officers. Is this allowed?
No. We do not allow any improper payments to influence government officials, including
police officers. This rule applies to both cash payments and other items of value, such as gift
cards. Report this immediately to Global Ethics & Compliance.
Our next store scheduled to open is pending the operating license. To expedite the process a
government official requested we hire a company that will “take care of it.” Is this allowed?
No. We do not hire specific third parties at the request of the government. We do not allow any
improper payment or action to influence a government official’s decisions. This rule also applies
to any company acting on our behalf. Report this immediately to Global Ethics & Compliance.
What if?
A bribe is receiving, offering to pay,
paying, promising to pay, or authorizing the
payment of money or anything of value to
improperly influence any act or decision or
to secure any other improper advantage in
order to obtain or retain business.
Bribes are not limited to cash. A bribe
can be gifts, travel, meals, entertainment,
offers of employment, and charitable or
political contributions.
Bribery Red Flags
• Excessive commission payments
• Large discounts
• Vague consulting agreements
without deliverables
• Offers or requests for lavish
entertainment or luxury gifts
What is bribery?
A third party intermediary is anyone acting
on Walmart’s behalf, directly or indirectly,
with a government official or government
entity. These third parties are subject to
Walmart’s strict due diligence, contracting,
and monitoring requirements.
Third Party Intermediaries
Global Anti-Corruption Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
Never Engage in Bribery
We compete fairly and honestly everywhere we do business around the world. We never attempt to gain a
business advantage through bribery, and we do not tolerate bribery or corruption in any form.
32 33
Keep Accurate Records
Keeping honest and accurate financial records builds trust in our brand, informs our strategy, and helps
operations run efficiently. We all share this responsibility.
Integrity in Action
• Never falsify a record or account. As a
publicly traded company, Walmart has certain
legal obligations to keep our records clear,
accurate, timely, and complete. Never hide,
alter, or disguise any business transaction.
• Follow all internal processes and controls
when creating and maintaining records.
Even if you are not directly responsible for
the preparation of disclosures or financial
reports, you are responsible for reporting
accurate information in the business records
you prepare. Properly record information—
including approvals, costs, sales, expense
reports, and time records—in accordance with
company procedures.
• Meet records management requirements.
Follow local records management and records
retention policies.
• Immediately report allegations of falsified
financial records or interference with
our internal controls on accurate financial
reporting directly to Global Ethics
& Compliance.
A coworker told me she smooths out our financial information so “good months” can help our
“bad months.” Is this a problem?
Yes. Altering our accounts in this way is dishonest. This could lead to serious consequences for
the individual and Walmart. Report this immediately to Global Ethics & Compliance.
What if?
“There is no business result worth
more than your personal
integrity or our company’s. We
would rather have a bad financial
result than to take a short cut.”
– Doug McMillon,
President and CEO, Walmart Inc.
• Payroll records
• Invoices
• Expense reports
• Sales or inventory data
• U.S. Securities and Exchange Commission
filings
Examples of
financial records
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
Follow International Trade Rules
Our business involves the movement of products, services, information, and technology around the
world, including across international borders. We are committed to sourcing, importing, and exporting
products and other items the right way. Conducting our international trade activities properly is critical to
earning and maintaining trust in our business, allowing us to move these items as necessary to support our
customers around the world.
Integrity in Action
• Provide accurate information. Take care when
providing classification, valuation, country of
origin, and other applicable regulatory
agency data.
• Follow trade compliance laws and our policies.
If your work in the supply chain involves moving
goods across international borders, know and
follow the laws of countries where you do
business. Understand that multiple countries’
laws may apply. Prior to engaging a third party
to assist in the movement of goods across
international borders, ensure that such third
parties have all necessary internal approvals
(for example, from Walmart Anti-Corruption
Compliance).
• Follow sanctions laws and our policies. Before
sourcing from a country, confirm that doing
so is permitted under applicable law. Many
governments keep a list of countries and
people with whom companies may not do
business. Subject to applicable local laws, don’t
conduct business with companies or people if
Walmart would be barred from doing so.
• Seek guidance. Prior to negotiating
international transactions, reach out to
Ethics & Compliance or Legal to discuss any
trade implications.
Global Trade Compliance Policy
Global Sanctions Policy
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
34 35
Prevent Money Laundering
and Consumer Fraud
Walmart offers financial products and services around the world, including money transfers, money orders,
check cashing, bill pay, gift cards, credit cards, and insurance. Most customers perform transactions
with good intent, but some criminals attempt to use our services for money laundering or to victimize
customers. Preventing money laundering and consumer fraud protects our customers and company and
may stop serious crimes.
Integrity in Action
• Know your customer. Financial products and
services sometimes require us to collect
additional customer information. Review and
accurately capture the customer’s information
when applicable.
• Report suspicious behavior. If a transaction or
customer seems suspicious or if the customer
appears to be a potential fraud victim, follow
local procedures for handling the transaction
and reporting the suspicious activity.
• Follow Walmart anti-money laundering and
consumer fraud policies and procedures. These
are designed to protect customers and ensure
that we comply with reporting and other legal
obligations where we operate.
Global Anti-Money Laundering & Financial Services Policy
What if?
It is a particularly busy day, and I have a line of customers waiting. The customer at the front of
the line wants to send a money transfer to an individual she does not know, and I think it might
be a fraud scam. What should I do?
If you suspect money laundering or a fraud scam, follow the appropriate procedures to report
suspicious and fraudulent activity in your country. If legally allowed in your country, do not
complete the transaction and report it. Though this may take additional time and inconvenience
the customers who are waiting, you may be preventing fraud or other criminal activity.
What is money laundering?
Money laundering disguises the proceeds of crime by putting them into the legitimate financial
system. It is connected to various criminal activities, including terrorism, drug dealing, and fraud.
Money Laundering Red Flags
If you observe red flags, follow local procedures for handling the transaction and, where
applicable, reporting the suspicious activity.
• Someone who provides incomplete, false, or suspicious information, refuses to answer
questions, or withholds identification
• Making purchases in a way that avoids requirements, such as making multiple small
transactions below the amount that would have to be reported to the government
• Payments using multiple money orders or large amounts of cash
• Large purchases of prepaid products, such as gift cards
• Buying gift cards for an unknown person, including for a government entity like the tax
department or law enforcement When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
36 37
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
Use Data and Technology
Respectfully and Ethically
When our customers, associates, and business partners share data and information with us, we understand
the importance of keeping it safe and using it—and technology—ethically in ways they expect. We will
maintain and grow the trust people have in us by respectfully using technology, respecting individuals’
privacy, and protecting their data.
Integrity in Action
• Respect the trust that people and the business
place in us. When dealing with technology and
personal or business information, do so in a
way that shows you understand and respect its
importance to the person and our business.
• Be clear about what information is being
collected and why. When we collect
information from individuals, make it clear that
information is being collected, and tell the
person why you need it.
• Tell people how you are using technology and
what you are going to do with the information
you collect. Be honest, transparent, and upfront about how someone’s information will
be used. Only use it in those ways, so we don’t
surprise people with unexpected, unexplained,
or unwanted uses.
• Be thoughtful about how much data you
collect and how long you keep it. We collect
information to improve our customer
shopping experience and to support our
business functions. We must store and protect
everything we collect, so make sure you need
it before you collect it. Follow your local
Records Management Policy for retention and
disposal of collected information.
• Protect the information. Safeguard personal
and business information from unauthorized
access or disclosure. Report any known or
suspected unauthorized access or disclosure
immediately through your local data incident
reporting channel.
• Follow data protection and privacy laws
and our policies. Know our data policies,
procedures, and controls that apply to your
role and follow them when handling data.
• Seek guidance. If you have questions about
how to handle data or which laws and
policies apply to your project, contact Digital
Citizenship, Privacy, or Legal.
What if?
I accidentally sent an email containing customer information to the wrong person. What should I do?
Incidents where customer or personal information is sent to an unauthorized person must be
immediately reported through your local data incident reporting channel.
I want to use external service providers to process personal information. What steps should I take?
Third parties must be assessed, and contracts must be in place. Follow all local procedures for
contracts and due diligence reviews.
Source Responsibly
We respect the rights of the people who make the products we sell. We believe they should have a safe
and healthy working environment, and we prohibit the use of underage or forced labor in our supply chain.
Integrity in Action
• Know our standards. Our Standards
for Suppliers set expectations in
our supply chain. Our associates and
suppliers should know and follow
these standards.
• Select responsible suppliers. Only
work with suppliers who meet our
Responsible Sourcing Compliance
program requirements and who are
committed to producing food and
products that meet legal, industry,
and Walmart standards.
• Hold suppliers accountable.
Suppliers should disclose factories as
required by Walmart, complete and
turn in audits on time, and work with
their facilities to remediate all noncompliances identified during audits.
• Follow our responsible sourcing
policy. Know the responsible sourcing
procedures that apply to your role
and follow them.
• Speak up. If you suspect a supplier or
factory is not meeting our Standards
for Suppliers, contact Ethics &
Compliance.
“We believe in the concept of shared
value where Walmart operates for
the benefit of not just customers,
associates, and shareholders, but
all stakeholders including suppliers,
communities, and society in general.
It’s important for us to do things
ethically and the right way.”
– Doug McMillon,
President and CEO, Walmart Inc.
Global Responsible Sourcing Compliance Policy
Global Forced Labor Prevention Policy
Standards for Suppliers
What if?
On a recent factory visit, I noticed some of the
workers appeared fearful, but the supplier said
everything was fine. What should I do?
If you suspect workers are being mistreated,
report it to Ethics & Compliance. They will look
into the concern and may follow up with the
supplier as needed.
Global Privacy Compliance & Records Policy
Global Policy for Reporting Data Incidents
38 39
Don’t Misuse Inside Information
You may know important information about our business that hasn’t been made public. Inside information
may affect Walmart’s or one of our business partner’s stock price. By only trading on publicly and lawfully
available information, we uphold Walmart’s reputation for honesty and fairness.
Integrity in Action
• Do not trade on inside information. Because Walmart is a publicly traded company in the U.S., we
all must comply with U.S. securities laws, which include prohibitions on insider trading. If you have
certain important or sensitive information about Walmart or our business partners that is not known
to the public, it is illegal to buy or sell shares in Walmart or those other companies. Examples of inside
information include financial results, pricing or marketing strategy changes, significant lawsuits or
contracts, key management changes, and projections of future sales and earnings. If you are unsure
whether something qualifies as inside information, contact Legal for advice.
• Keep it to yourself. Only share inside information with associates who need it to perform their jobs.
• Do not share insider tips. Do not share inside information outside of Walmart, even with family
members or friends. When discussing inside information be aware of your surroundings to avoid
someone overhearing.
Insider Trading Policy
What if?
I know about an amazing new product one of our suppliers is about to launch. The news is not
public. May I advise a friend to buy stock in that company if I don’t disclose why?
No. Even if you don’t give a reason for the recommendation, you are still violating the law if
you make the recommendation based on inside information. If you are unsure whether trading
is allowed, contact Legal.
Protect
Our Property
Taking care of Walmart’s property helps us achieve
Every Day Low Cost. Walmart property—including
computers, merchandise, tools, furniture, vehicles,
and office supplies—is provided so you can do your
job and Walmart can succeed as a business. We
are trusted to use Walmart property properly and
protect it against loss, theft, misuse, damage,
or waste.
Integrity in Action
• Be a good steward. Wise use of our resources
and funds enables Every Day Low Cost.
• Protect Walmart funds. Use funds for their
intended purpose. Obtain all required approvals
before incurring an expense.
• Protect intellectual property. To the extent
allowed by local law, anything you create
as part of your job—including inventions,
discoveries, ideas, artwork, and other process
improvements—is Walmart property and remains
Walmart property when you leave the company.
• Report misuse. If you are aware of Walmart
property being misused, report it to your
manager, People Lead, or Ethics & Compliance.
What if?
A customer returned a damaged item, and I know we can’t sell it. May I take it home?
No. Even if merchandise is damaged or out of date, it’s still Walmart property. Properly
account for and process the item through the established returns process.
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
When in doubt—reach out.
If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.
40 41
Global Ethics Helpline Numbers
Argentina 0800-888-0124
Bahrain 800-06-102
Bangladesh 000800-032-035
Belgium 0800-750-76
Botswana 00269-800-7861-036
Brazil 0-800-761-1943
Cambodia 1800-20-8963
Canada 800-963-8442
Canada (French) 800-805-9121
Chile 800-550707
China 400-120-4020
Colombia 01800-913-7496
Costa Rica 0800-542-5443
Dominican Republic 1-888-751-8878
Ecuador 1-800-000-884
Egypt 0800-000-9471
El Salvador 800-6126
Flipkart (China) 400-120-0384
Flipkart (India) 1800-102-1482 &
800-050-1482
Flipkart (Israel) 1-809-467272
Flipkart (Singapore) 800-492-2426
Flipkart (US/Canada)
1-800-564-4163
France 0800-903277
Germany 0800-188-8917
Ghana 030 708 4830
Guatemala 1 800 8350377
Honduras 800 222 00141
Hong Kong 800-930-587
India 000-800-040-1503
Indonesia 007-803-321-8281
Ireland 1-800-200-356
Israel 1-809-477-259
Italy 800-143-952
Japan 0120-692-344
Jordan 0800-22319
Kenya 0800 221 9008
Lesotho 800 62000
Malawi 0800-026-9000
Malaysia 1-800-817-362
Mexico 800 963 8422
Morocco +212-5204-85021
Mozambique 824001
Myntra (India) 1800-102-1482
Namibia 800000077
Netherlands 0-800-024-9759
New Zealand 0800-424280
Nicaragua (TF) 001-800-220-1967
Nicaragua (Local) 505 2248 2275
Nigeria 0708 060 1109
Pakistan 00800-90-033-041
Panama 800-0413
Peru 0800-78378
Philippines 1-800-1-322-0162
PhonePe (India) 1800-102-1482
Russia 8-800-100-9476
Singapore 800-130-1529
South Africa 0800 203 246
South Korea 003084910122
Spain 900-494776
Sri Lanka 247-2469
Swaziland 8001333
Taiwan 00801-49-1191
Tanzania 0800 78 0006
Thailand 001-800-13-203-9969
Turkey 00-800-113-6848
Uganda 0800 113224
United Kingdom 0800 318 405
United Arab Emirates 8000-3201-39
United States 800-963-8442
Vietnam 120-32-518 & 122-80-160
Zambia 8877
Talk to your manager, next-level manager, People Lead, Ethics & Compliance, or Legal.
www.walmartethics.com ethics@walmart.com
800-963-8442 (1-800-WM-ETHIC) in the U.S., Canada, and Puerto Rico, or your local phone number.
The Ethics Helpline is available 24 hours a day, 7 days a week and is available in most local languages.
Walmart Inc.
Attention: Global Ethics & Compliance, 702 SW 8th Street, Bentonville, AR 72716-0860
Questions or Concerns
*Note: Numbers subject to change