GRI: 102-16; 102-17; 205-2
UN SDG: 5
G | Last Updated: June 23, 2022
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.
Relevance to Our Business & Society
Ethics and compliance are essential components of sustainable business success and growth. Businesses that set high standards, ground their decision-making in foundational values, swiftly address shortcomings and act transparently not only mitigate risk—they make better business decisions and cultivate trust. Ethics and compliance are integral to a well-functioning society and the economy, as unethical business practices add to the total cost of doing business, reduce GDP, distort markets and contribute to an erosion of trust in institutions.
We believe that trust is one of Walmart’s competitive advantage: associates, customers, investors, suppliers and business partners will choose Walmart because they know we are a business they can trust. With more than 10,500 stores 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.
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 ethics and compliance program foundations, including having the right program structure, developing standards and controls to maintain compliance, training associates on compliance and controls and monitoring for and responding to issues.
- Building trust with our associates and customers, including by not tolerating discrimination or harassment, promoting health and safety, selling safer food and products and delivering quality health care services.
- Building trust with our business, including by competing fairly, combating bribery and corruption, using data and technology respectfully and ethically and sourcing responsibly.
Key Strategies & Progress
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.
- Respecting the Individual means actively listening to understand one another. Be visible, responsive, available, and open to feedback. Demonstrate servant leadership by leading by example, being humble, and teaching and trusting others to do their jobs. We see and celebrate differences. Everyone belongs at Walmart. Make diversity, equity, and inclusion a personal priority for yourself.
- Serving the Customer means putting our customers first by anticipating their wants and needs and exceeding their expectations. We need to be frontline-focused, supporting and empowering associates to serve customers and members every day—in stores, clubs and online. Be a true believer in our everyday low-price business model to deliver value, lower our costs and differentiate our approach.
- Striving for Excellence requires holding ourselves and others accountable to a high standard of performance. We drive growth which is accelerated by taking intelligent risks and embracing change. Be curious. Adapt, learn and apply new information. Accelerate our digital transformation. Manage the short term while strategically investing to build for the long term.
- Acting with Integrity means being honest by keeping our promises, telling the truth and being trustworthy. Be fair and do the right thing—whether you’re a store manager, merchant, or technologist. Be courageous, speak up and ask for help when you need it. Be open and transparent with each other.
Walmart’s Code of Conduct, published in February 2021, replaced the former Statement of Ethics as our internal policy and external statement of our values, principles and expected behaviors. The Code applies to all associates of Walmart and its subsidiaries and to Walmart’s and its subsidiaries’ board members when they are acting in their capacity as directors.
In addition to covering expectations on topics including ethical decision-making, conflicts of interest, use of inside information, protection of Walmart’s property and other foundational ethics and compliance issues, the Code of Conduct makes clear when and how to speak up, our no-retaliation policy, consequences for failing to abide by the Code and examples of how to put integrity in action.
To complement and supplement the Code, Walmart released new versions of 20 ethics and compliance policies in 2020 and 2021, covering topics ranging from financial services compliance to discrimination and harassment prevention and trade compliance.
Walmart also re-released its Standards for Suppliers in early 2021. The revised Standards include foundational expectations of suppliers on topics not previously covered, including food and product safety, consumer protection, trade and sanctions compliance, conflicts of interest and fair competition. The scope of the Standards was also expanded to cover suppliers of goods Walmart purchases for its own use (in addition to suppliers of goods we intend to resell, which were previously covered) and examples of good practice in action.
The Code makes clear that every Walmart associate—at every level of the company—is responsible for upholding our standards and complying with all relevant laws and regulations; we also expect our suppliers, vendors, service providers and other business partners to act with integrity and honor our values.
While fostering and maintaining our culture of integrity is every associate’s job, we have over 1,000 Ethics & Compliance and other Global Governance associates around the world who are dedicated to:
- Cultivating a culture of integrity
- Establishing proper standards and controls
- Creating awareness of and advising on ethics and compliance issues
- Developing and implementing relevant and accessible training materials
- Continuous risk spotting and assessment, including using data
- Conducting independent investigations into ethics and compliance violations
- Monitoring ethics and compliance issues and, where appropriate, reporting to regulatory authorities
- Remediating ethics and compliance gaps and violations
Ethics and Compliance Program Foundations
We design our ethics and compliance programs around foundational principles that help keep us consistent and responsive as our business and the external environment change:
- Leadership: Our leaders at the highest levels of our company (global officers) are held accountable for being champions of integrity and maintaining and promoting an ethical business.
- Risk Spotting and Assessment: We engage in continuous risk spotting and assessment, using data and other information to better understand and mitigate the company’s risks.
- Standards and Controls: We use information from business and compliance reviews for the continual development and refinement of our policies, procedures and controls to help ensure everyday actions are performed in a manner consistent with expectations.
- Training and Awareness: We make our associates aware of and advise them on our standards and controls and provide relevant and accessible training for our associates to help them implement and use our standards and controls.
- Monitoring and Response: We monitor ethics and compliance performance; we incorporate lessons learned from independent investigations of possible violations; and we remediate gaps if we find them.
These foundational principles 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.
Walmart’s governance programs are designed with specific risk areas in mind, which reflect the complexity of our global business and dedication to doing business the right way. Some of these risk areas are:
- Consumer Protection
- Data and Technology Use
- Environmental Compliance
- Financial Services Compliance
- Food Safety
- Health and Safety
- Healthcare Compliance
- Labor and Employment Compliance
- Licenses and Permits
- Product Safety
- Responsible Sourcing
- Trade Compliance
Leadership & Tone from the Top
We expect our leaders to model Walmart’s culture of integrity and values with their daily actions and to regularly communicate their commitment through various channels, both internally and externally.
Compliance is the responsibility of everyone in the company. Many different parts of the company play a part in supporting Walmart’s compliance with laws and regulations. Walmart's global governance organization has more than 1,000 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 ethics and compliance efforts.
Governance leaders in each market are charged with designing and executing the compliance program consistent with our program foundations and ensuring the overall program is operating efficiently and effectively.
The Global Chief Ethics and Compliance Officer, as well as other global governance leaders, makes regular reports on ethics and compliance matters to the Audit Committee of Walmart’s Board of Directors. The Audit Committee plays a critical and active role in overseeing the company’s ethics and compliance program.
Risk and Ethics & Compliance Committees
We have a governance risk committee comprising members of management at the global level. In addition, we have an ethics and compliance committee in each of our international retail markets. These committees meet regularly to discuss issues related to ethics, compliance and other enterprise-level risks, with meetings structured to lead to follow-up and accountability for action items.
Integrity Index survey
As part of Walmart’s Associate Engagement Survey (AES), we ask questions related to integrity to establish an integrity score. The Integrity Index score helps us better understand the strength of our culture of integrity, while identifying opportunities to provide additional guidance and leadership.
For 2021, the Integrity Index measured the favorability of associate responses in six areas:
- I am comfortable expressing my concerns without fear of retaliation.
- Do you feel pressure to violate the organization’s ethics or the law to achieve business results?
- I know how to report unethical behavior.
- My direct supervisor acts ethically and honestly.
- My direct supervisor has communicated to me expectations around working the right way and complying with laws and company policy.
- My company responds to issues or concerns raised by associates.
Each manager with at least five direct reports responding to the Survey receives an Integrity Index score. Market-level Integrity Index scores are reviewed by the market Chief Ethics and Compliance Officer and relevant business leadership. As needed, they work to develop action plans to address areas for improvement.
Standards & Controls
We periodically review the guidance we have published to help our associates make the right decisions. For example, in 2021 Walmart launched a new Code of Conduct that focuses on acting with integrity to build trust in each other and with our customers, members and stakeholders. We also launched 20 new and updated global ethics and compliance policies in 2020-2021 that reflect our commitment to doing business the right way, defining target audiences, and informing associates of expected behaviors (including speaking up when something is not right).
Training & Awareness
Educating associates on expectations and keeping ethics, compliance and integrity top-of-mind through tailored, effective training are essential to maintaining a culture of integrity. Walmart conducts regular ethics and compliance training for all levels of the company, from frontline store associates to the board of directors, and we continually seek to improve our method and approach to training to help ensure our associates have the right information at the right time and in the right way. Training is supplemented by ongoing communication campaigns to keep the concepts top-of-mind.
Example Ethics & Compliance training and awareness activities include:
- Food Safety: Walmart trained more than 980,0001 associates globally on at least one food safety course in FY2022. Walmart associates celebrated the World Health Organization’s Food Safety Day with awareness campaigns that included messages from senior executives, contests, webinar events and posters.
- Anti-Corruption: Walmart trains associates globally to recognize the various forms of bribery, to know and understand Walmart’s policies and procedures, and to properly conduct governmental interactions; in FY2022, more than 77,400 associates received this training. Certain associates deemed most likely to interact with government officials or work with third-parties intermediaries (TPIs) who might interact with government officials receive live training; more than 12,400 associates received this training in FY2022. Pursuant to identified risk ratings, third parties that interact directly with foreign government officials about Walmart business are given detailed training about our policy, their obligations under our anti-corruption program, their duty to report suspected violations and whom to contact for guidance. More than 1,500 TPIs received this training in FY2022.
- Ethics: Walmart associates receive ethics training during onboarding and regularly thereafter. In FY2022, more than 2,000,000 associates globally received Ethics training. An updated global training module and awareness campaigns were launched in 2021 to support the new Code of Conduct.
- Harassment and Discrimination Prevention: All global officers receive regular discrimination and harassment prevention training. Ethics training also addresses discrimination and harassment prevention. Beyond this training, U.S.-based associates are assigned anti-harassment and anti-discrimination refresher training on a recurring basis. Market training and awareness teams also developed awareness campaigns focused on sexual harassment prevention. The campaigns featured executive leadership messaging and utilized 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 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 strengthening understanding of the program among seasoned business partners. In FY2022, we provided training to more than 5,900 participants globally. 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.
Monitoring & Response
Walmart monitors adherence to laws, regulations, standards, controls and initiatives throughout our business. In addition to tracking key metrics, we have continuous improvement teams regularly visit and actively monitor facilities to determine the facility’s adherence to protocols. And program design, execution and effectiveness are tested and refined through our internal audit processes and reviews by external experts.
Walmart's Code of Conduct and Reporting Channels
Walmart’s Code of Conduct encourages associates, suppliers, customers and community members to raise issues, ask questions and report concerns. Speaking up is a requirement for Walmart associates, and we support associates in doing so by stating that reporting an issue in good faith will not get the associate in trouble, even if the associate makes an honest mistake. Walmart’s Code of Conduct and program policies also make clear that Walmart does not tolerate retaliation for reporting a concern or participating in an investigation.
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 firstname.lastname@example.org.
Reports to Ethics are triaged by subject matter, risk presented to the company and severity of the allegation. Actionable cases may be referred to business units for follow-up or investigated by one of our investigative teams.
Violations of our Code of Conduct and ethics and compliance program policies can lead to discipline up to and including termination. Other remedial action 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.
Building Trust with Our Associates & Customers
Building trust with our associates is foundational to creating the culture of ethics, compliance and integrity that we need to win with our customers and other stakeholders.
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 Harassment & Discrimination Prevention Policy.
Walmart takes a global approach to discrimination and harassment prevention and process enhancements. 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, 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. We do not require U.S. employees to take sexual harassment claims to private arbitration. Because of the special and sensitive nature of these cases, we have also launched enhanced training for investigators on how to investigate sexual harassment and sexual assault allegations.
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 over 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.
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 & 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 based on their roles, 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 execution of specific elements of our EHS program. A total of 33,234 visits were conducted in 2021.
As the pandemic emerged and evolved in the U.S., several teams of experts collaborated to review our practices and controls and to assess the impact of updated CDC, OSHA and state and local regulations and guidance. Changes made as a result included modifying store hours, metering and traffic management, mask and social distancing requirements, sanitation, provision of PPE, modified leave policies and benefits, and protocols for testing and reporting of positive tests. Walmart continues to update and create new guidelines, policies and procedures for implementation across stores, clubs and support facilities.
In addition to this regular structural oversight, Walmart conducted multiple levels of monitoring and auditing of its programs specifically relating to COVID-19 protocols in the U.S.
Walmart’s Global Governance Continuous Improvement Team regularly monitored for compliance with health and safety.
Since the emergence of COVID-19, the Board has received updates from management about COVID-19’s impact to our associates, customers, business, financial condition, and operations.
Additional information regarding how we are responding to COVID-19 is available here.
Selling Safe Food & Products
Hundreds of millions of customers depend on Walmart for safe, quality food and products. We have programs designed to deliver end-to-end food and product safety, including through hazard detection, facility procedures, monitoring and recalls and withdrawals. In addition to our normal processes and practices, during the COVID-19 pandemic we took special measures to keep our customers safe.
Building Trust in Our Business
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 well aligned with the spirit of competition laws.
Our Global Antitrust and Competition Law Policy applies across all of Walmart’s businesses, globally. 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 meet and properly mitigate relevant risks. The COE works in close partnership with teams across the company, including merchandising, pricing, sourcing, sustainability, HR and others, to verify that compliance controls are embedded throughout the company. The COE also partners with the ethics team, investigations team and our global audit team to help make sure the compliance program is continually informed by relevant reporting and any business concerns.
Combating Bribery & Corruption
Walmart’s stance on bribery and corruption is firm: 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. 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 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.
Our Anti-Corruption compliance program is designed to effectively manage our bribery and corruption risks and incorporates regulators’ guidelines and internationally recognized best practices to establish effective anti-corruption internal controls and monitoring. We invest in people, processes and systems to not only prevent and detect corruption risks, but to assure the program continuously improves to be proactive, risk-based, efficient, effective and sustainable. Walmart has dedicated significant resources to enhance our Anti-Corruption program, including:
- Hiring a Global Anti-Corruption Officer to supplement dedicated Anti-Corruption teams in every Walmart market
- Formalizing and enhancing the annual anti-corruption risk assessments in all markets
- Conducting enhanced anti-corruption monitoring across all the company’s markets by dedicated teams, including Anti-Corruption program audits
- Enhancing anti-corruption training and awareness program
- Implementing a centralized learning management system for Global Ethics and Compliance training
- Implementing systems to globally manage corruption risks often associated with TPIs, licenses and permits, and donations.
Our anti-corruption training program gives life to our Global Anti-Corruption Policy and procedures in our business operations. 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 FY2022, more than 77,400 associates received this training. We also provided anti-corruption training to more than 1,500 of the TPIs acting on our behalf.
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 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 guiding 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.
Walmart’s supply chain reaches over 100,000 suppliers globally. Through our Responsible Sourcing program, we establish our expectation that suppliers and their facilities operate responsibly and in a way that protects worker dignity. Our expectations are stated in our Standards for Suppliers, we use a risk-based approach to monitoring our supply chain and we use insights to make purchasing decisions that support our responsible sourcing objectives. Read more: People in Supply Chains.
- Walmart operates in 24 countries around the world, each with different customs, cultures and 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.
- The success of certain of our programs are dependent on the engagement, participation and cooperation 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.
- Code of Conduct
- Standards for Suppliers
- Global Anti-Corruption Policy
- Global Forced Labor Prevention Policy
- Walmart Ethics
- Walmart Corporate Governance
- Walmart COVID-19 Information
- Safer, healthier food & other products
- People in supply chains
- Digital citizenship: Ethical use of data & responsible use of technology
1. In FY2021 we reported that more than 290,000 associates were trained in at least one food safety course. In FY2022 we reported that more than 980,000 associates globally were trained in at least one food safety course. The FY2022 number is higher due to but not limited to the following changes: FY2022 we offered more food safety training courses; training was disproportionately impacted in FY2021 by the COVID-19 pandemic; FY2022 includes all associates where FY2021 was U.S. based associates only; and in FY2022 we included the count of associates trained who left the company after completing the training.