Ethics & Compliance

Walmart strives to make trust a competitive advantage. Integrity builds trust in our business, and modeling the highest standards of ethics and compliance helps us create and maintain a culture of integrity.

Ethics and compliance are essential components of good governance and a foundation for the success and growth of a sustainable business. Businesses that set high standards in these areas ground their decision-making in a strong foundation, swiftly identify and address shortcomings, and act transparently not only to mitigate risk but also to make better business decisions and cultivate trust. Ethics and compliance are integral to a well-functioning society and economy, as unethical business practices can add to the total cost of doing business, reduce GDP, distort markets, and contribute to an erosion of trust in institutions.

Trust is one of Walmart’s competitive advantages: associates, customers, investors, suppliers, and business partners choose Walmart because they know we are a business they can trust. With more than 10,500 stores and clubs worldwide and tens of thousands of suppliers, our actions can have a positive impact and influence far beyond the walls of our stores, clubs, and offices. And with more than 2.1 million associates globally, Walmart's integrity depends upon ethical and compliant behavior and decision-making throughout our organization.

At every level of our company, we work to create a culture that inspires trust among our associates, with our customers, and in the communities we serve. We do this by:

• Setting foundations for our ethics and compliance program. This includes maintaining a strong corporate culture of compliance; having an effective program structure; proactive, empowered leadership; developing policies, procedures, and controls to maintain compliance; training associates and third parties to keep compliance top-of-mind; maintaining open and confidential reporting channels; and monitoring and responding to issues.
• Building trust with our associates and customers. Not tolerating discrimination or harassment, promoting health and safety, and selling safe food and products.
• Building trust with our business. Competing fairly, combating bribery and corruption, using data and technology respectfully and ethically, and sourcing responsibly.

Setting Ethics & Compliance Program Foundations | Building Trust With Our Associates and Customers, and In Our Business

Setting Ethics & Compliance Program Foundations

Walmart’s core values are at the center of everything we do. Our Code of Conduct helps us make decisions that promote those values by describing the behaviors we expect of each other and reinforcing that we are committed to complying with laws and regulations in all locations where we operate.

Our Values:

• Respecting 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.
• Serving the Customer. We put our customers first, anticipate their wants and needs, and exceed their expectations.
• Striving for Excellence. We are a high-performance team and expect the best from ourselves. We own our work and results.
• Acting with Integrity. We are honest, fair, and objective. We speak up about concerns and comply with all laws and our policies.

Ethics and Compliance Program Foundations

Walmart’s Ethics and Compliance program is risk-based and tailored to address the needs of our global business. We design our program around nine foundations that enable consistency, yet are able to adapt to changes in our business and the external environment.

These foundations are designed to align our programs with the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs framework and Organisation for Economic Co-operation and Development (OECD) Good Practice Guidance.

Corporate Culture

Walmart's Ethics & Compliance program reflects our strong corporate culture of integrity by promoting ethical and compliant behavior and decision-making. Setting the right tone from the top is critical, and management is expected to lead by example. Leaders are evaluated on how they model our values, and they are expected to regularly communicate their commitment through internal and external channels. Our commitment to integrity cascades company-wide through regular messaging, embedding compliance and ethics principles into business operations, integrating ethics into performance evaluations, and recognizing associates who model integrity in action. We assess our culture of integrity regularly through our Associate Engagement Surveys and other feedback channels.

Compliance Leadership & Personnel

Our effectiveness depends on having a robust and adequately resourced team of experienced ethics and compliance leaders with appropriate authority and autonomy within the organization and direct access to Walmart’s Board and executive leadership.

• Our Global Chief Ethics and Compliance Officer (CECO) holds overall responsibility for our Ethics and Compliance program’s structure, implementation and maintenance; this includes the management of and communication with  dedicated subject matter experts and leaders within markets and business units.
• The Audit Committee of Walmart’s Board of Directors plays a critical and active role in overseeing the company’s ethics and compliance program. The CECO, as well as other global governance leaders, provides reports to the Audit Committee at least annually on ethics and compliance matters  and is independently empowered to request additional time with the Audit Committee to discuss ethics and compliance issues. As part of this oversight, the Audit Committee periodically holds private conversations with the CECO for candid discussion of ethics and compliance matters.
• Walmart has a Governance Risk Committee comprised of leaders including our CEO, Chief Legal Officer, and other members of management at the global level. This committee meets at least quarterly to discuss significant or strategic ethics and compliance matters, enterprise-level risk, and current issues in the industry.
• Governance leaders in each Walmart market are charged with designing and executing the compliance program consistent with our program foundation and ensuring the overall program is operating efficiently and effectively. We also maintain ethics and compliance committees in our international retail markets that meet regularly to discuss issues related to ethics, compliance, and other enterprise-level risks.

Overall, Walmart's global governance organization has thousands of associates, including subject matter experts, investigators, compliance and risk assessment professionals, legal counsel, security specialists, and data analysts, among others, dedicated to supporting Walmart’s business teams and promoting and maintaining ethics and compliance efforts in practice. We strive for constant two-way communication and maintain close relationships with core business functions to ensure our program is successful in practice.

Regular Risk Identification & Analysis

We continually review and assess our compliance-related risks. Among the areas that we analyze are:

• Walmart's evolving business activities, including new business ventures and acquisitions, our interactions with third parties, and organizational changes within our company
• Trends in emerging risk areas from external sources, including relevant enforcement authorities and industry groups
• Our own ethics and compliance data and trends emerging from recent investigations

Policies, Procedures, & Controls

We implement formal, written policies to clearly articulate the company’s expectations on how to conduct the organization’s business, what we expect from suppliers and other third parties and how to apply them across our operations. Ethics and compliance expectations are set forth in our Code of Conduct, in topic-specific policies, and in documented procedures and guidance. We design risk-based controls to help ensure business processes are executed in compliance with our expectations.

Risk reviews (including regulatory change monitoring and control testing) help us confirm that our policies and controls cover relevant risks and are effective. These include financial controls to detect and prevent unauthorized transactions. In order to keep ourselves accountable, we periodically review and update the guidance we have published to help our associates and applicable third parties make the right decisions.

Additionally, in many compliance areas, we oversee third-party relationships (for example, suppliers, vendors, and outside counsel) using risk-based controls, including due diligence on higher-risk business partners and audits within our supply chain.

Training & Awareness

Educating associates on our behavioral expectations, key policies and procedures, and controls through timely, effective training is key to maintaining a culture of integrity and promoting overall compliance. Walmart conducts regular ethics and compliance training for all levels of the company, from frontline store associates to senior leaders, and provides periodic ethics and compliance briefings and education for the Board of Directors. We continually seek to improve our method and approach to training to help ensure participants have the right information at the right time and in the right way that aligns to the potential ethics and compliance issues associated with their work. Tailoring training to specific audiences, employing proven educational methodologies, tracking completion, and evaluating participant comprehension all contribute to the effectiveness of our compliance training program. Training is also supplemented by ongoing communication campaigns to keep the concepts top-of-mind.

Example Ethics and Compliance training and awareness activities include:

• Code of Conduct: Walmart associates receive training on our Code of Conduct during onboarding and regularly thereafter. In FY2023, more than 1.4 million associates globally completed Code of Conduct training.
• Food safety: Walmart trained just under 1.2 million associates globally on at least one food safety course in FY2023.
• Anti-corruption: Walmart trains associates globally to recognize the various forms of bribery, to know and understand Walmart’s policies and procedures, how to properly conduct governmental interactions, and how to make international donations. In FY2023, more than 60,900 associates completed this training. The knowledge of certain associates more likely to have anti-corruption touchpoints was reinforced through gamified awareness, with embedded progression, challenges, levels and instant feedback; more than 10,200 associates benefited from this campaign. Certain associates deemed most likely to interact with government officials or work with third party intermediaries (TPIs) who might interact with government officials receive live training, unless they demonstrate knowledge proficiency through role-tailored learning. In FY2023, more than 11,800 associates attended live training or tested out of live training through gamified learning. Based on their Walmart-assessed risk level, third parties directly interacting with government officials on Walmart’s behalf are given detailed training about our Global Anti-Corruption Policy, their obligations under our anti-corruption program, their duty to report suspected program violations, and whom to contact for guidance. More than 1,500 third-party intermediaries completed this training in FY2023.
• Harassment and discrimination prevention: All global officers receive regular discrimination and harassment prevention training. Ethics training also addresses discrimination and harassment prevention, and, beyond our regular Ethics training, Walmart assigns discrimination and harassment prevention and sexual harassment prevention training to all U.S. based associates every two years, unless the associate works in a state that has a specific training frequency requirement. Market training and awareness teams also developed awareness campaigns focused on sexual harassment prevention. The campaigns featured executive leadership messaging and used multiple communication channels and collateral material including market intranet sites, emails, and posters.
• Responsible sourcing: Walmart merchandising and sourcing associates are trained on our Global Responsible Sourcing Compliance Policy, our Standards for Suppliers and our Responsible Sourcing expectations on an ongoing basis. This training introduces new merchants to the Responsible Sourcing program while updating program understanding among experienced merchants. We also provide tools and resources to suppliers through various channels, including our website, to help them understand our expectations and to make improvements in their supply chains.

Internal Monitoring & Testing

We regularly monitor and test our controls and communicate with our business partners regarding their effectiveness. Internal monitoring and testing procedures, supplemented by periodic audits, help ensure that our program’s components operate effectively and are well designed. Along with risk analysis, monitoring and periodic evaluation of key programmatic elements provide a foundation for enhancements and continuous improvement of our program.

• We utilize our internal audit processes and external reviews, from outside counsel or expert consultants, to test and refine our program design, execution, and effectiveness.
• Compliance teams regularly visit and actively monitor metrics from facilities to determine the facility’s adherence to protocols.
• We track key metrics of our program, such as site audit results and training compliance rates, continually in order to spot potential areas of concern or areas of particular effectiveness.

Confidential Reporting

We maintain reporting channels that allow for anonymous and confidential reporting of concerns from Walmart associates and all third parties, including workers in our supply chain. We ensure associate awareness of appropriate reporting channels, as well as the ability to report anonymously, confidentially, and free from retaliation.

Walmart’s Code of Conduct encourages associates, suppliers, vendors, service providers, business partners, customers, and community members to raise issues, ask questions, and report concerns. Walmart associates are encouraged, and in some instances required, to speak up. Walmart’s Code of Conduct and program policies make clear that Walmart does not tolerate retaliation for reporting a concern in good faith or participating in an investigation, assuring that associates feel empowered to raise concerns and speak out.

Channels available for reporting concerns include:

• Global and local phone numbers that anyone can use to ask questions and report concerns 24 hours a day, seven days a week. The helpline is available in 29 languages.
• The WalmartEthics.com website is available in 11 languages and accessible globally. The website provides a platform where stakeholders can review frequently asked questions, read our Code of Conduct, submit ethics concerns and follow up on previously reported concerns.
• Contacting ethics@walmart.com
• Postal mail
• U.S. associates can raise concerns or ask a question using an internal employee portal, myFeedback.

Investigation & Remediation

Prompt fact-finding, root cause, and corrective action analysis are central to the effectiveness of our ethics and compliance program. When we substantiate a violation of our company’s ethics and compliance expectations, we remediate the underlying issues, including through root cause analysis and appropriate accountability for culpable associates and third parties. While maintaining independent judgment, we involve and communicate with our business partners regarding our findings and needed adjustments in processes and controls.

Contacts made to Ethics through the confidential reporting channels are triaged by subject matter, risk presented to the company, and severity of the allegation. Cases may be referred to business units for follow-up, investigated by our Global Investigations team or another investigative unit, or escalated to our Legal Investigations Team for handling as appropriate.

If a report results in a substantiated violation of our Code of Conduct or our ethics and compliance program policies, associates may face discipline up to and including termination. Other remedial actions taken as a result of violations can include reduction of associates’ annual cash incentive payment, associates being provided training and/or counseling, changing policies or procedures, or implementing additional processes or controls.

Continuous Improvement

Walmart's Global Governance team works continuously to improve and adapt our ethics and compliance program to mitigate new and evolving risks, including partnering with other stakeholders to design and integrate compliance into new business initiatives and acquisitions. Through program reviews, benchmarking, and the incorporation of lessons learned, we assess and adjust our program to ensure continued effectiveness.

Building Trust With Our Associates and Customers, and In Our Business

Building trust in our business, and with our associates and customers, is foundational to creating the culture of ethics, compliance, and integrity that we need in order to win with our customers and other stakeholders. One of the ways that we increase trust is through the design and implementation of compliance programs that are designed with specific risk areas in mind, and which reflect the complexity of our global business and dedication to doing business the right way.

We maintain compliance programs for a broad range of subjects including anti-corruption, antitrust, consumer protection, labor and employment, financial services, healthcare, food and product safety, environmental health & safety, and responsible sourcing. Several of these programs are described in more detail below.

Respecting One Another by Not Tolerating Harassment or Discrimination

We are dedicated to a workplace that is free of harassment and discrimination. We do not tolerate any behavior that 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. These expectations are set out in our Code of Conduct and in our Global Discrimination and Harassment Prevention Policy.

Walmart takes a global approach to discrimination and harassment prevention and process enhancements and requires all salaried members of management to report suspected violations of the Global Discrimination and Harassment Prevention Policy to Ethics. All global officers receive regular discrimination and harassment prevention training, and the topic is regularly discussed with senior leadership. In addition, we assign discrimination and harassment prevention and sexual harassment prevention training to all U.S.-based associates every two years unless the associate works in a state that has a specific training frequency requirement. Associates receive messaging from leadership to ensure consistent messaging from the top down, along with other training and awareness activities, so that they are aware of the policy and understand how to report any concerns. New associates are tasked with reading the policy upon hire. Violations of our policy may lead to consequences up to and including termination of employment.

Because of the special and sensitive nature of these cases, investigators looking into these claims receive enhanced training on how to investigate sexual harassment and sexual assault allegations. We do not require U.S. employees to take discrimination or harassment claims to private arbitration.

Creating a Safe Place to Work & Shop

The health and safety of our associates and customers is not just a business need — it’s a societal imperative. Walmart employs more than two million associates, and those associates keep our business running. Hundreds of millions of customers turn to us for essential food, products, and services. They need to feel safe when they’re shopping at our stores and clubs.

Walmart is proud of its long-standing commitment to protecting human health and the environment. As an ethical and responsible corporate citizen, Walmart is dedicated to minimizing our environmental impact and preserving the health and safety of our associates and customers. It is Walmart’s intent to operate in compliance with all Environmental, Health, and Safety (EHS) laws and regulations. Walmart’s Global EHS Policy establishes a standard that is intended to protect human health and the environment while creating a safe workplace.

Walmart employs a team of safety professionals who are responsible for developing and implementing safety initiatives for the different operational formats within the company, including but not limited to, Walmart stores, Sam's Clubs, supply chain facilities, and international facilities. Our safety team focuses on training, promoting a culture of safety compliance, and monitoring safety compliance. Walmart associates in these facilities receive training on numerous health- and safety-related processes according to their job duties, including, but not limited to:

• Accident prevention
• Hazard identification
• Safe use of machinery and equipment
• Use of personal protective equipment
• Emergency response
• Fire prevention

We also contract with an independent third party to conduct risk-based assessments of our U.S. stores and clubs to monitor the execution of specific elements of our EHS program. More than 33,100 visits were conducted in 2022.

To help ensure a safe working environment for associates, we document and analyze associate incident and injury data. The Occupational Safety and Health Administration (OSHA) Recordable Incident Rate (RIR) and Lost Time Incident Rate (LTIR) are calculations that describe the frequency of incidents per 100 full-time employees per year. The RIR is based on all incidents that resulted in medical treatment beyond first aid; the LTIR is a similar calculation, except that it only includes incidents that resulted in at least one lost workday. The significantly lower LTIR compared to the RIR indicates that the majority of our recorded incidents were minor in nature.¹  

Selling Safe Food & Products

Hundreds of millions of customers depend on Walmart for safe, quality food and products. We have compliance programs designed to deliver end-to-end food and product safety, including through hazard detection, facility procedures, monitoring and recalls, and withdrawals. Walmart maintains a Global Food Safety Compliance Program to assist associates and suppliers in meeting food safety expectations, and our Global Food Safety Compliance team develops policies, standards, procedures and controls designed to prevent and remediate practices that do not meet our requirements. We also maintain a risk-based Global Product Safety Compliance Program to assist Walmart associates and suppliers in complying with local product safety laws and requirements and company policies.

Read more: Safer, Healthier Food & Other Products

Sourcing Responsibly

Walmart’s supply chain reaches tens of thousands of suppliers globally. Through our Responsible Sourcing program, we hold our suppliers accountable for the responsible operation of their facilities and for safeguarding the well-being of workers in their facilities and supply chains. Walmart expects that the products we purchase and sell or purchase for our own use are made by suppliers who act ethically, pay people fairly, provide working environments that are clean and safe, and respect the dignity of workers. Our expectations are stated in our Standards for Suppliers; we use a risk-based approach to monitoring suppliers’ facilities for compliance with our Standards and we use insights to align purchasing decisions with our responsible sourcing objectives.

Read more: People in Supply Chains and Human Rights

Using Data & Technology Respectfully & 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 earn and maintain the trust people have in us by respectfully developing and using technology, respecting individuals’ privacy, and protecting their data.

Walmart has developed Digital Trust Commitments aligned with our core values that serve as a foundation for how Walmart will continue to earn and maintain customer trust in an omni-channel, data- and technology-driven world:

• Our use of technology and data will be in SERVICE of people.
• We strive for EXCELLENCE in our technology, making it simple, convenient, and secure.
• We will use data responsibly and transparently and always with INTEGRITY.
• Our data practices and technology will treat people fairly, with dignity and RESPECT.

In addition to communicating what Walmart stands for, these Digital Trust Commitments serve as foundational principles for product and development teams so they can infuse Walmart’s values into the digital architecture and infrastructure of our operations.

These principles are reflected in our digital citizenship programs and initiatives, including privacy; the use of emerging technologies and data; data, records, and information management; and information security and cybersecurity.

Read more: Digital Citizenship: Ethical Use of Data & Responsible Use of Technology

Combating Bribery & Corruption

Walmart’s stance on bribery and corruption is firm: we compete fairly and honestly everywhere we do business around the world. Our Code of Conduct and Global Anti-Corruption Policy prohibit bribery in any form: 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 is strictly prohibited. The Policy applies to our associates and to TPIs acting on Walmart’s behalf; our Standards for Suppliers require the same of Walmart’s product suppliers.

Walmart dedicates significant resources to our anti-corruption program, including:

• Leadership. Assigning a Global Anti-Corruption Officer to supplement dedicated Anti-Corruption teams in every Walmart market and leveraging our market Anti-Corruption Compliance teams to identify market-specific risks.
• Risk assessment. Formalizing and enhancing the annual anti-corruption risk assessments in all markets.
• Detection and mitigation: Dedicating teams to monitor across all of the Company’s markets and conducting Anti-Corruption program audits, including the review of third parties who interact with the government on the Company’s behalf.
• Program evaluation. Conducting global in-market reviews to assure the program’s global efficiency and effectiveness; incorporating regulators’ guidelines and internationally recognized best practices to establish effective anti-corruption internal controls and monitoring.
• Training. Tailoring anti-corruption training and awareness program to address key audience risks (see Training section above).
• Comprehensive coverage. Designing system enhancements to globally manage corruption risks associated with TPIs, licenses and permits, and donations, as well as implementing our anti-corruption compliance program at acquired entities.

Competing Fairly

Walmart is committed to free and fair competition as this helps enable lower prices, maximize consumer choices, and promote innovation. Walmart’s core mission — to provide everyday low prices so that customers can save money and live better — is aligned with the spirit of competition laws.

Our Global Antitrust and Competition Law Policy applies across all of Walmart’s businesses. The Policy requires (among other things) that Walmart (1) compete independently; (2) protect competitively sensitive information; and (3) deal with suppliers and other parties in a manner that does not harm competition or consumers.

Walmart has an Antitrust Center of Expertise (COE) responsible for advising the company with respect to antitrust matters and for the development and maintenance of a Global Antitrust Compliance Program. The Program is led by a team of global and jurisdiction-specific specialists who design robust training, controls, and monitoring to mitigate relevant risks. The COE works in close partnership with teams across Walmart to verify that compliance controls, training, and awareness are embedded throughout the company.

Walmart associates receive training on antitrust topics through our Code of Conduct training. For associates who work in higher-risk business segments, additional tailored antitrust trainings are assigned. Additionally, the COE conducts in-depth, in-person trainings with teams in higher-risk business segments, both in the U.S. and globally, to help make sure the Program is continually informed by relevant reporting and any business concerns.

Challenges

• Walmart operates in 20 countries around the world, each with different customs, cultures, and societal norms. Moreover, laws and regulations differ substantially across the places where Walmart operates and are constantly evolving, creating challenges for implementing comprehensive and global programs. Read more about these factors in our most recent annual report, found on Form 10-K.
• As Walmart's business expands into new areas, including healthcare and financial services, we face new and unique ethics and compliance challenges, adding more complexity to our overall program framework.
• The success of our ethics and compliance programs depends, in part, on the engagement, participation and cooperation of millions of our associates, suppliers, and other business partners.
• Major global events, such as the COVID-19 pandemic, can disrupt our business operations, cause changes in laws and customer behaviors, and necessitate rapid shifts in our approaches to ethics and compliance.

About Our Reporting

• Code of Conduct
• Standards for Suppliers
• Global Anti-Corruption Policy
• Global Forced Labor Prevention Policy
• Privacy Notice
• Walmart Ethics
• Walmart Corporate Governance
• Safer, Healthier Food & Other Products
• People in Supply Chains 
• Digital Citizenship: Ethical Use of Data & Responsible Use of Technology

1. Data represents U.S. numbers. Industry data for Retail charts is based on NAICS 452311 (45291 in 2018) - Warehouse clubs and supercenters. Industry data for Supply Chain charts is based on NAICS 49311 - General warehousing and storage.