Build Trust in Our Business

Recognize and Avoid Conflicts of Interest

Fair and objective decisions build trust with our associates, customers, members, 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.

Conflicts of interest can arise in various ways. Some examples include:

• Influencing the conditions of employment (for example, pay, work hours, job responsibilities, or a performance rating) of any family member or romantic partner.
• Accepting gifts and entertainment from a current or potential business partner if you work with or could work with that business partner in your Walmart role.
• Investing in a business partner when you can influence Walmart’s relationship with that business partner.

It is important to identify and avoid situations that could create a conflict or the perception of one. Know and follow our Global Conflicts of Interest Policy, which provides additional examples and guidelines.

Never Engage in Bribery

We never bribe. 

Bribery involves receiving, paying, authorizing, offering, or promising money or anything of value to improperly influence any act or decision or to gain an improper advantage to obtain or retain business. Bribes can take many forms, including cash, gifts, travel, meals, entertainment, offers of employment, and charitable or political contributions.

For us, it is simple, bribery—of anyone, anywhere, at any level—is not allowed. This applies to all associates and any third party working on our behalf. If you are  asked for or offered a bribe, refuse it and immediately report it to Ethics.

Know and follow anti-corruption laws, our Global Anti-Corruption Policy, and all local anti-corruption compliance and giving procedures.

Compete Fairly

We believe success comes from offering quality products and services at low prices. Effective competition leads to stronger innovation, lower prices, and better quality, while anticompetitive practices harm our customers and members. Build trust by:

• Protecting and not sharing competitively sensitive information – such as pricing, costs, bid submissions, or strategic plans – with competitors, either directly or through a third party, such as a supplier.
• Not reaching agreements with competitors or others that limit competition. For example, do not agree with a competitor on prices, assortment, margins, promotions, or other terms, and never agree to divide up products, customers or members, or markets we serve.
• Stopping conversations if competitively sensitive information or an improper agreement comes up. Make it clear you do not want to participate and report the incident to Ethics or Legal.

Follow all competition laws, local policies, and our Global Antitrust & Competition Law Policy.

Keep Accurate Business Records

Keeping honest and accurate business records builds trust in our business, informs our strategy, and helps operations run efficiently. As a publicly traded company, Walmart has legal obligations to keep our business records clear, accurate, timely, and complete. We all share this responsibility. Build trust by:

• Following all internal processes and controls when creating and maintaining business records. Even if you are not directly responsible for preparing disclosures or financial reports, you are responsible for reporting accurate information in the business records you prepare.
• Properly recording information—including approvals, costs, sales, expense reports, inventory, and time records—in accordance with company procedures.
• Never falsifying, hiding, altering, or disguising any business transaction or account.

Examples of financial records:

• Payroll records
• Invoices
• Expense reports
• Sales or inventory data
• U.S. Securities and Exchange Commission filings

Use Data and Technology Responsibly

We understand the importance of safeguarding data shared with us by customers, members, associates, and business partners. We are expected to use data and technology in ways that respect privacy and protect information. Build trust by:

• Being honest, transparent, and clear about how someone’s information will be used and using it only in those ways.
• Safeguarding 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.
• Only using approved communication methods (such as company-approved email or company-approved messaging apps) to send or receive company information.
• Seeking guidance from Legal and Compliance when we have questions about how to handle data and patient health information, or about which laws and policies apply.

Know and follow all data protection and privacy laws, local policies, and our Global Records and Information Management Policy, Global Tech and Data Compliance Policies, and Global Health and Wellness Compliance Policy.

Protect Our Property

Taking care of Walmart’s property helps us achieve Every Day Low Cost. We use Walmart property, including computers, vehicles, and Walmart funds, to perform our jobs. We are trusted to use Walmart property properly and protect it against loss, theft, misuse, damage, or waste. Build trust by:

• Using Walmart’s computers, phones, and other electronic devices for their intended purposes.
• Obtaining all required approvals before incurring expenses and ensuring Walmart funds are used appropriately.
• Following Walmart policies when handling damaged or price-reduced items and when using your Associate Discount Card.
• Protecting Walmart’s intellectual property. Anything you create as part of your job–such as inventions, ideas, and artwork–is Walmart property and remains so when you leave the company, subject to local law. Know and follow our Intellectual Property Policy.

Protect the Environment

We care about our communities, and we all have a role to play in protecting the environment. Operating our business responsibly and consistent with environmental obligations helps us sustain our resources and care for our planet. Build trust by:

• Following market programs to meet air, water, waste, and other environmental requirements.
• Reducing waste by following market programs to segregate and recycle materials.
• Safely packaging, labeling, and transporting hazardous materials.

Know and follow all environmental laws, local policies, and our Global Environmental, Health & Safety Policy.

Do Not Misuse Inside Information

You may know important information about Walmart or our business partners that has not been made public. This inside information could affect the stock price of Walmart or our business partners. It is illegal to buy or sell shares in Walmart or our business partners based on important or sensitive inside information. Examples of inside information include financial results, pricing or marketing strategy changes, significant lawsuits or contracts, key management changes, or future sales and earnings projections. Trade only on publicly and legally available information. Build trust by:

• Never trading on inside information.
• Only sharing inside information with associates who need it to perform their jobs.
• Never sharing inside information outside of Walmart, even with family members or friends. When discussing inside information, be aware of your surroundings to avoid someone overhearing.
• Contacting Legal if you are unsure whether something qualifies as inside information.

Know and follow all insider trading laws, local policies, and our Insider Trading Policy.