Table of

Contents

2
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

Resources42

3
 A Message
from Our CEO

4
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.

Doug McMillon
President and CEO
Walmart Inc.

5
 Our Values and
Our Code

6
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.

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.

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.

“…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.

7
 How to Use
Our Code

8
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:

Build trust with Build trust with Build trust in

our associates our customers our business

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.

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 • Falsifying financial records or interfering

our Anti-Corruption Compliance Policy) with our internal controls on accurate
• A company officer or direct report to any financial reporting
company CEO potentially violating our Code

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.

Ways to Reach Out

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

10
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.

11
Trust Begins Build Trust with Our
With You Associates

pages 14-19 pages 20-25

Build Trust with Our Build Trust in Our

Customers Business

pages 26-29 pages 30-41

12
13
 Trust Begins
with You

14
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.

Integrity in Action
Before You Act,
• Follow the law. Learn about the laws that apply Ask These Questions
to your role and our business.

• Know our Code and live our values. Review • Is it legal?

our Code and understand how it and our
• Is it consistent with our values
policies apply to your job. Associates must
and Code?
complete any required training on our Code
and acknowledge that they have read and • Is it in Walmart’s best interest?
understand it.
If the answer to any of these is “No,” don’t
• Act in Walmart’s best interest. Never allow do it. If you’re not sure of the answer, reach
personal interests to impact the business out to your manager, People Lead, Ethics &
decisions you make as a Walmart associate. Compliance, or Legal for guidance.
• Be honest. Be transparent and make decisions
that reflect our values.

• Lead by example. Talk about our Code and Role of Managers

our values with your fellow associates and
team members.
Leaders have a duty to promote
• When in doubt—reach out. If you have integrity and build trust. If you lead
questions or concerns, let your manager, or supervise others, Walmart expects
People Lead, Ethics & Compliance, you to:
or Legal know.
1. Set expectations consistent with our
values, handle questions or concerns
properly, and report issues as
required by policy.
“Don’t compromise 2. Listen to associates who seek advice
your reputation. It’s a or raise concerns.

precious commodity. Don’t 3. Take reports of misconduct seriously

and ensure they are properly handled.
compromise your integrity...
have a good name.” 4. Stand firm against harassment,
intimidation, and retaliation.
- Sam Walton, Founder, Walmart Inc.

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 discover through your position or the use of
management associate or a salaried associate. Walmart property or information.

• 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
Global Conflicts of Interest Policy

Think about it

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.

16
Financial Investments
• Do not invest in a Walmart supplier if you • Do not have a substantial interest (for example,
can influence Walmart’s relationship stock ownership) in a competitor. Consult
with that supplier. the Global Conflicts of Interest Policy
for specific restrictions.

Gifts and Entertainment

• Decline gifts and entertainment from a supplier • Decline gifts and entertainment from any
if you work with or could work with that supplier government official.
in your Walmart role. Accepting any benefit from
suppliers that we work with can cause a conflict • We often sample or test merchandise to help
and drive up the cost of doing business. us better understand a product or business
we may want to purchase. This is not a conflict
• Explain our policy on gifts and entertainment so long as we reasonably limit sampling.
to new suppliers. Customs may differ in the Follow your local policy regarding sampling
countries where we work, but our policy on and testing products.
gifts and entertainment applies everywhere
we do business.

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

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
Can friendships cause Do not have a romantic relationship with
a conflict of interest? another associate if the associate is in your
chain of command or you have influence over
Yes, if the depth of your close personal the associate’s conditions of employment or
friendship impacts your ability to make performance rating. If an associate with whom
objective decisions. A close personal you already have a romantic relationship comes
friendship is not simply participating in under your supervision due to a change in
some of the same community activities. organizational structure, you should immediately
Attending the same house of worship, disclose the relationship to your manager, People
having children on the same sports team, or Lead, or Ethics & Compliance.
being in the same neighborhood association
would not by itself make you close personal • A romantic partner is someone you
friends. It can be difficult to determine are dating or with whom you have
on your own whether a close personal a sexual relationship.
friendship could impact your objectivity.

Talk with your manager, People Lead, or Global Conflicts of Interest Policy
Ethics & Compliance about how to best
manage the business situation if a close
personal friend is involved.

18
Supplier Relationships
• If a close personal friend, family member, • Before participating in the selection of a
or romantic partner works for a supplier supplier which employs your family member,
over which you have influence, disclose it close personal friend, or romantic partner,
to your manager, People Lead, or Ethics & disclose the relationship to your manager,
Compliance to get advice on managing People Lead, or Ethics & Compliance to get
the potential conflict. advice on how to manage the potential conflict.

What if?

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.

19
 Build Trust with
Our Associates

20
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.

Integrity in Action
What if?
• Stop a task if conditions are unsafe and report
the concern. Watch for hazards that could
harm you or others. The back room is full of boxes and
• Don’t work under the influence. Alcohol and many of the walkways are blocked. It
improper use of drugs can affect your work and doesn’t feel safe, but my department
the safety of people around you. manager said not to worry about it.
What should I do?
• Protect yourself. Use proper safety gear and
follow all training and procedures. Know what It’s not okay to ignore a safety
to do in case of an injury or emergency. hazard even if your manager says
• Be careful operating machinery. Do not not to worry about it. Talk with
operate machinery or equipment unless you another manager or your People
are trained, have the proper safety gear, and Lead about your concerns. If you
are following all health and safety procedures. still have a safety concern following
your discussions, contact Ethics
• Follow safe driving requirements.
& Compliance.
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.

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.

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.

Global Discrimination & Harassment Prevention Policy

Walmart does not tolerate discrimination or harassment

based on an individual’s:

• Race • Sex • Marital Status • Sexual Orientation

• Color • Pregnancy • Veteran Status • Gender Identity
• Ancestry • National Origin • Military Status or Expression
• Ethnicity • Age • Genetic • Any Other Legally
• Religion • Disability Information Protected Status

Walmart complies with all laws in the countries in which we operate.

22
Integrity in Action
Examples of harassment:
• Treat others how they want to be treated. Be
fair and respectful to associates, customers,
members, suppliers, and third parties who work • Unwelcome sexual advances or remarks
with Walmart. Value others’ differences and • Slurs or inappropriate jokes based on a
listen to different points of view. protected status
• Hire and promote the right way. Hire, retain, • Displaying written or graphic material
and promote associates based on qualifications, that ridicules, insults, or shows hostility
demonstrated skills, achievements, and other toward a group or individual based on a
merits. protected status
• Prevent harassment. Set the right tone and • Distributing pornographic or sexually
expectation for appropriate behavior with suggestive content
your team members and peers. Verbal, visual,
or physical conduct of a sexual nature is not • Intimidating acts, such as bullying or
acceptable. threatening, concerning or based on a
protected status
• 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. “We must work together to
• Follow harassment and discrimination laws actively shape our culture to be
and our policies. Know what behaviors are
more inclusive, not just accepting
considered harassment or discrimination and
create a respectful and inclusive workplace. our differences…but celebrating
• Speak up. Never tolerate harassment them…everyday…in every part of
or discrimination. Report harassment or the company.”
discrimination to your manager, People Lead,
- Doug McMillon,
or Ethics & Compliance.
President and CEO, Walmart Inc.

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

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.

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
 What if?

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.

25
 Build Trust with
Our Customers

26
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
What if?
• Respond quickly to product recalls and removals.
To keep customers safe, execute recall and removal
processes with urgency. One of my coworkers in the Deli
• Report possible food or product hazards. If you often fails to wash her hands when
become aware of a safety issue with an item, tell your she returns from a break. I talked
manager and contact Ethics & Compliance. to her about how important it is
• Deliver end-to-end food safety. We maintain food to wash hands, but she still isn’t
safety throughout our supply chain—from supplier or washing them every time. What
Walmart processing facility, through transportation should I do?
and warehousing, to online distribution or sale in a Washing hands properly every
store—there are food safety requirements in each time is required and is key to
stage. Follow the requirements that apply to you. keeping our food safe. Talk to any
• Follow the Food Safety High Five. Know and follow member of your management
the Food Safety High Five to keep food safe. team about this situation. If your
• Know your suppliers. Only source from suppliers that concerns are not addressed
follow our food and product safety requirements. by your management, contact
• Follow food and product safety laws and our policies. Ethics & Compliance.
Know the food safety and product safety procedures
that are relevant to your role and follow them.

Global Food Safety Policy, Global Product Safety Compliance Policy

Food
Safety
1
Be Clean,
Be Healthy
• Wash hands when necessary
• Do not work with food if you are ill
• Never touch ready-to-eat food with bare hands

High
2 3
• Keep cold foods • Do not store raw foods over

Five
at proper cooked or ready-to-eat foods
temperature • Never prepare ready-to-eat
• Keep hot foods foods on the same surface or
Keep it Cold, at proper Don’t Cross with the same utensils used
Know the Keep it Hot temperature Contaminate to prepare raw animal proteins

4 5
High Five, &
follow them • Properly wash, rinse • Cook foods
thoroughly
while working and sanitize all food
contact utensils and • Rapidly chill
with food. Wash, Rinse, equipment Cook it foods
& Sanitize & Chill it

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

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 • Report environmental hazards or unnecessary
following your market programs to segregate waste to management. If you see an
and recycle materials. environmental hazard or a waste of resources,
• Correctly handle hazardous items. alert management.
Appropriately transport, handle, and dispose • Follow environmental laws and our policies.
of hazardous items. Follow corporate market Know and follow the environmental policies and
programs to ensure compliance with hazardous procedures relevant to your role.
materials and hazardous waste regulations.

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.

28
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 Health & Wellness Compliance Policy

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

29
 Build Trust in
Our Business

30
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. • Be honest and accurate. Always be truthful
Don’t share sensitive information with competitors in pricing, marketing, and advertising.
such as pricing, costs, bid submissions, or strategic • Sell products the right way. Know which
plans. Don’t make agreements with competitors or products have sales restrictions (for example,
others that limit competition. For example, don’t alcohol and tobacco), and follow the restrictions.
agree on price, terms of sale, assortment, margins,
promotions, or allocation of products, customers, • Seek guidance. If you are ever unsure
or markets. whether a conversation or agreement is okay,
ask Legal for advice.
• Interact with suppliers and other third parties the
right way. Focus on Walmart’s goal to better serve • Follow competition and consumer protection
our customers. We must be careful to not seek out laws and our policies. Know the antitrust and
or pass along confidential information about our consumer protection policies and procedures
competitors via our suppliers. We also must not that apply to your role and follow them.
share confidential information about our suppliers • Report suspected violations. Any suspected
with other suppliers. If confidential information violations of Walmart’s Antitrust and
or an improper agreement comes up, stop the Competition Law Policy must be reported to
conversation. Make it clear you don’t want to Ethics & Compliance or Legal.
participate and report the incident.
• Conduct market research properly.
Never encourage anyone to improperly give
you confidential information.

Global Antitrust & Competition Law Policy

Global Consumer Protection Policy

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

31
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.

Integrity in Action
What is bribery?
• Do not offer or accept bribes. Laws in some
countries make a distinction between bribing
a government official and bribing a non- A bribe is receiving, offering to pay,
government official. We don’t rely on those paying, promising to pay, or authorizing the
distinctions. For us, it is simple, bribery—of payment of money or anything of value to
anyone, at any organization, at any improperly influence any act or decision or
level—is wrong. to secure any other improper advantage in
• Third parties must not pay bribes. Any person order to obtain or retain business.
or company working on Walmart’s behalf may Bribes are not limited to cash. A bribe
not offer, give, or receive a bribe. If the only can be gifts, travel, meals, entertainment,
way to make a deal or complete a service for offers of employment, and charitable or
Walmart is through payment of a bribe, we political contributions.
expect third party service providers to refuse
and to report it. Bribes are not how we Bribery Red Flags
do business. • Excessive commission payments
• Engage Anti-Corruption Compliance. Get • Large discounts
approval from Anti-Corruption Compliance
• Vague consulting agreements
and Legal before entering into any agreement
without deliverables
with a government or engaging a third party
intermediary. • Offers or requests for lavish
entertainment or luxury gifts
• 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 Third Party Intermediaries
Procedures and controls. Follow the Giving
Procedures with respect to in-kind and
A third party intermediary is anyone acting
monetary donations.
on Walmart’s behalf, directly or indirectly,
• Immediately report allegations of bribery with a government official or government
or attempted bribery directly to Global entity. These third parties are subject to
Ethics & Compliance. Walmart’s strict due diligence, contracting,
and monitoring requirements.
Global Anti-Corruption Policy

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

32
 What if?

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.

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
Examples of
financial records • Never falsify a record or account. As a
publicly traded company, Walmart has certain
legal obligations to keep our records clear,
• Payroll records accurate, timely, and complete. Never hide,
• Invoices alter, or disguise any business transaction.
• Expense reports • Follow all internal processes and controls
when creating and maintaining records.
• Sales or inventory data
Even if you are not directly responsible for
• U.S. Securities and Exchange Commission the preparation of disclosures or financial
filings 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.
“There is no business result worth
• Meet records management requirements.
more than your personal Follow local records management and records
integrity or our company’s. We retention policies.
would rather have a bad financial • Immediately report allegations of falsified
result than to take a short cut.” financial records or interference with
our internal controls on accurate financial
- Doug McMillon, reporting directly to Global Ethics
President and CEO, Walmart Inc. & Compliance.

What if?

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.

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

34
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 • Follow sanctions laws and our policies. Before
providing classification, valuation, country of sourcing from a country, confirm that doing
origin, and other applicable regulatory so is permitted under applicable law. Many
agency data. governments keep a list of countries and
• Follow trade compliance laws and our policies. people with whom companies may not do
If your work in the supply chain involves moving business. Subject to applicable local laws, don’t
goods across international borders, know and conduct business with companies or people if
follow the laws of countries where you do Walmart would be barred from doing so.
business. Understand that multiple countries’ • Seek guidance. Prior to negotiating
laws may apply. Prior to engaging a third party international transactions, reach out to
to assist in the movement of goods across Ethics & Compliance or Legal to discuss any
international borders, ensure that such third trade implications.
parties have all necessary internal approvals
(for example, from Walmart Anti-Corruption
Compliance).

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.

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 • Follow Walmart anti-money laundering and
services sometimes require us to collect consumer fraud policies and procedures. These
additional customer information. Review and are designed to protect customers and ensure
accurately capture the customer’s information that we comply with reporting and other legal
when applicable. obligations where we operate.
• 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.

Global Anti-Money Laundering & Financial Services Policy

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

36
 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.

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

37
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 business functions. We must store and protect
place in us. When dealing with technology and everything we collect, so make sure you need
personal or business information, do so in a it before you collect it. Follow your local
way that shows you understand and respect its Records Management Policy for retention and
importance to the person and our business. disposal of collected information.
• Be clear about what information is being • Protect the information. Safeguard personal
collected and why. When we collect and business information from unauthorized
information from individuals, make it clear that access or disclosure. Report any known or
information is being collected, and tell the suspected unauthorized access or disclosure
person why you need it. immediately through your local data incident
• Tell people how you are using technology and reporting channel.
what you are going to do with the information • Follow data protection and privacy laws
you collect. Be honest, transparent, and up- and our policies. Know our data policies,
front about how someone’s information will procedures, and controls that apply to your
be used. Only use it in those ways, so we don’t role and follow them when handling data.
surprise people with unexpected, unexplained, • Seek guidance. If you have questions about
or unwanted uses. how to handle data or which laws and
• Be thoughtful about how much data you policies apply to your project, contact Digital
collect and how long you keep it. We collect Citizenship, Privacy, or Legal.
information to improve our customer
shopping experience and to support our

Global Privacy Compliance & Records Policy

Global Policy for Reporting Data Incidents

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.

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

38
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 What if?
our supply chain. Our associates and
suppliers should know and follow
these standards. On a recent factory visit, I noticed some of the
workers appeared fearful, but the supplier said
• Select responsible suppliers. Only
everything was fine. What should I do?
work with suppliers who meet our
Responsible Sourcing Compliance If you suspect workers are being mistreated,
program requirements and who are report it to Ethics & Compliance. They will look
committed to producing food and into the concern and may follow up with the
products that meet legal, industry, supplier as needed.
and Walmart standards.
• Hold suppliers accountable.
Suppliers should disclose factories as
required by Walmart, complete and “We believe in the concept of shared
turn in audits on time, and work with
their facilities to remediate all non-
value where Walmart operates for
compliances identified during audits. the benefit of not just customers,
• Follow our responsible sourcing associates, and shareholders, but
policy. Know the responsible sourcing all stakeholders including suppliers,
procedures that apply to your role
communities, and society in general.
and follow them.
It’s important for us to do things
• Speak up. If you suspect a supplier or
factory is not meeting our Standards ethically and the right way.”
for Suppliers, contact Ethics & - Doug McMillon,
Compliance. President and CEO, Walmart Inc.

Global Responsible Sourcing Compliance Policy

Global Forced Labor Prevention Policy
Standards for Suppliers

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

39
 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.

40
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.

When in doubt—reach out.

If you have questions or concerns, let your manager, People Lead, or Ethics & Compliance know.

41
Global Ethics Helpline Numbers
Argentina 0800-888-0124 Honduras 800 222 00141 South Africa 0800 203 246
Bangladesh 000800-031016 Hong Kong 800-930-587 Spain 900 876 292
Botswana 00269-800-7861-036 India 000-800-040-1503 Swaziland 8001333
Brazil 0-800-761-1943 Indonesia 007-803-321-8281 Tanzania 0800 78 0006
Cambodia 1800-20-8963 Israel 1-809-477-259 Thailand 001-800-13-203-9969
Canada 800-963-8442 Japan 0120-692-344 Turkey 00-800-113-6848
Canada (French) 800-805-9121 Jordan 0800-22319 Uganda 0800 113224
Chile 800-550707 Kenya 0800 221 9008 United Kingdom 0800 051 8266
China 400-120-4020 Lesotho 800 62000 United Arab Emirates 8000-3201-39
Colombia 01800-913-7496 Malawi 0800-026-9000 United States 800-963-8442
Costa Rica 0800-542-5443 Malaysia 1-800-817-362 Vietnam 120-32-518 & 122-80-160
Dominican Republic 1-888-751-8878 Mexico 800 963 8422 Zambia 8877
Ecuador 1-800-000-884 Morocco +212-5204-85021
Egypt 0800-000-9471 Mozambique 824001
El Salvador 800-6126 Myntra (India) 1800-102-1482
Flipkart (China) 400-120-0384 Namibia 800000077
Flipkart (India) 1800-102-1482 & Netherlands 0-800-024-9759
800-050-1482 Nicaragua (TF) 001-800-220-1967
Flipkart (Israel) 1-809-467272 Nicaragua (Local) 505 2248 2275
Flipkart (Singapore) 800-492-2426 Nigeria 0708 060 1109
Flipkart (US/Canada) Pakistan 00800-90-033-041
1-800-564-4163
Panama 800-0413
France 0800-903277
Peru 0800-78378
Ghana 030 708 4830
PhonePe (India) 1800-102-1482
Guatemala 1 800 8350377
Singapore 800-130-1529
*Note: Numbers subject to change

Questions or Concerns
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