Ethics and Compliance
GRI: 2-23, 2-26, 3-3, 205-2
UN SDG: 5
G
Published: Apr. 24, 2024
At a Glance
- Trust is one of Walmart's competitive advantages; our commitment to upholding ethical standards and compliance establishes a culture of integrity and builds trust with our associates, customers, investors, suppliers, and business partners.
- Walmart's Ethics and Compliance program is based on nine core program foundations designed to keep us consistent and responsive as our business and external environments change.
- We maintain compliance programs for a broad range of subjects including anti-corruption, antitrust, worker health and safety, and prevention of discrimination and harassment.
Walmart strives to make trust a competitive advantage. Modeling the highest standards of ethics and compliance helps us maintain a culture of integrity, and integrity builds trust in our business.
Businesses with high standards in ethics and compliance ground their decisions in those standards, acting swiftly to identify and address issues in order to mitigate risk and cultivate trust.
Trust is one of Walmart’s competitive advantages, which is why 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, 2.1 million associates worldwide, and tens of thousands of suppliers, our actions 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:
- Governing our ethics and compliance functions with strong oversight and empowered leadership.
- Setting foundations for our Ethics and Compliance program that promote a corporate culture of integrity, provide the building blocks for an effective program, and inspire continuous improvement.
- Building trust through robust compliance programs that reflect the size, complexity, and unique aspects of our business.
Governance
Walmart’s Ethics and Compliance team is part of our Global Governance organization, led by our EVP of Global Governance, Chief Legal Officer (CLO), and Corporate Secretary. Our Global Chief Ethics and Compliance Officer (CECO) holds overall responsibility for Walmart’s Ethics and Compliance program’s structure, implementation, and maintenance. Governance leaders in each Walmart market are charged with designing and executing their compliance programs consistent with our program foundations and ensuring the overall program is operating efficiently and effectively.
- 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 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 its oversight, the Audit Committee periodically holds private conversations with the CECO for candid discussion of ethics and compliance matters.
- Walmart’s Governance Risk Committee comprises leaders including our CEO, CLO, and other members of executive 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.
- 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.
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 with the ability to adapt to changes in our business and the external environment.1
Corporate Culture
Setting the right tone from the top on ethics and compliance is critical, and management is expected to lead by example. Our commitment to integrity permeates all levels of the company by integrating compliance and ethics principles into business operations and performance expectations and recognizing associates who demonstrate integrity.
To gauge our culture of integrity and identify opportunities to improve, we conduct regular assessments using our Associate Engagement Survey (AES) and other feedback channels. In 2023, AES 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.
Results from the AES are shared with leadership across our company and, as needed, they work to develop action plans to address areas for improvement.
Compliance Leadership and Personnel
Our effectiveness depends on having an 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. Walmart’s Global CECO oversees the overall Ethics and Compliance program, and our Global Governance organization includes thousands of associates, including subject matter experts, investigators, compliance and risk assessment professionals, legal counsel, security specialists, and data analysts, among others, who support business teams and promote ethics and compliance practices across the company.
Regular Risk Identification and 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, and Controls
We implement formal, written policies to 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. We periodically review and update the guidance we have published to help our associates and applicable third parties make the right decisions.
Training and Awareness
Timely and effective training is essential to how we educate associates on our behavioral expectations, key policies and procedures, and controls. 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. Our training and awareness campaigns help ensure participants have the right information at the right time and in the right way, through methods including tailoring training to specific audiences, employing proven educational methodologies, tracking completion, and evaluating participant comprehension.
Internal Monitoring and Testing
We regularly monitor and test our controls to help ensure that our program is well-designed and operates effectively. Risk analysis, coupled with the monitoring and regular evaluation of key program elements and metrics, allows us to identify potential areas of concern and effectiveness. This serves as the basis for further enhancements and continuous improvement. We utilize internal audit processes and external reviews from expert resources to test and refine our program’s design, execution, and effectiveness.
Confidential Reporting
We maintain reporting channels that allow for anonymous and confidential reporting of concerns from Walmart associates and third parties, including workers in our supply chain. These include:
- Global and local phone numbers that anyone can use to ask questions and report concerns 24/7/365. The helpline is available in 29 languages.
- The WalmartEthics.com website, which is globally accessible and available in 11 languages.
- Contacting ethics@walmart.com
- Postal mail
- An internal employee portal for U.S. associates, myFeedback.
Investigation and Remediation
Prompt fact-finding, root cause, and corrective action planning are central to the effectiveness of our program. When we substantiate a violation of our company’s ethics and compliance expectations, we remediate the underlying issues, including through root cause analysis, appropriate accountability for culpable associates and third parties, and needed adjustments in processes and controls.
Ethics contacts received through confidential reporting channels are assessed based on subject matter, risk to the company, and severity of the allegation. Depending on the case, it may be investigated by our Global Investigations team or another investigative unit, escalated to our Legal Investigations team for appropriate handling, or referred to business units for further action.
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.
Walmart Code of Conduct and Standards for Suppliers
Walmart’s Code of Conduct is 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, unless otherwise noted, when they are acting in their capacity as directors. The Code is reviewed and updated periodically, with the latest update in 2023.
The Code makes clear that Walmart associates – at every level of the company – are responsible for upholding our standards and complying with all relevant laws and regulations. It covers expectations for topics including ethical decision-making, conflicts of interest, use of inside information, protection of Walmart’s property, and other foundational ethics and compliance topics. It also includes examples of how associates can put integrity into action, instructs them on when and how to speak up if an ethics question or issue arises, underscores our non-retaliation policy, and explains the consequences for failing to abide by the Code.2 To complement and supplement the Code, Walmart maintains, and regularly updates, issue-specific ethics and compliance policies.
Walmart associates receive training on the Code during onboarding and regularly thereafter. All required Code of Conduct courses include an acknowledgment that associates must complete before finishing their training. Our Code of Conduct training was completed by approximately 95% of associates who were assigned in FY2024.3
We also expect our suppliers, vendors, service providers, and other business partners to act with integrity and honor our values. Walmart's Standards for Suppliers set forth our foundational expectations of our suppliers. The Standards apply to all suppliers that sell their products to us for resale or for Walmart’s own use. Suppliers are expected to cascade the requirements outlined in our Standards throughout their supply chains – including raw materials, component or ingredient suppliers, and subcontractors and agents.
Integrity in Action
We know that doing the right thing isn't always easy. Through our annual Integrity in Action Awards, Walmart recognizes associates who demonstrate an exceptional level of integrity and courage and who promote our ethical culture in the workplace.
Effective Compliance Programs
Our compliance programs are foundational elements of how we build trust in our business. They are risk-based programs that reflect the complexity of our global business and our dedication to doing business the right way. Walmart maintains compliance programs for a broad range of subjects. A few of the subject matters covered by the program include anti-corruption, antitrust, consumer protection, financial services, healthcare, food and product safety, environmental health and safety, and responsible sourcing. Several of these programs are described in more detail below.
Prevention of Harassment and Discrimination
Walmart is 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. Violations of our policy may lead to discipline up to and including termination of employment.
Walmart’s annual Code of Conduct training addresses discrimination and harassment prevention. Walmart assigns additional discrimination and harassment prevention and sexual harassment prevention training to U.S. based associates. Across our markets, additional trainings and awareness campaigns include tailored harassment and discrimination prevention training modules, messaging from leadership, and informational emails and posters.
Creating a Safe Place to Work and Shop
The health and safety of our associates and customers are not just business needs – they tie to our core values. As an ethical and responsible corporate citizen, Walmart is dedicated to preserving the health and safety of our associates and customers, including the goal of compliance with all environmental, health, and safety laws and regulations. Walmart’s Global Environmental, Health and Safety Policy (“EHS Policy”) establishes a standard that is intended to ensure we protect human health and the environment while creating a safe workplace. Violations of our EHS Policy may lead to disciplinary action up to and including termination. Additional detail on Walmart’s commitments and expectations for associates can be found in our Environmental, Health, and Safety Statement.
Walmart employs a team of safety professionals who are responsible for developing and implementing safety initiatives for the different operational formats within the company. They focus on training, promoting a culture of safety compliance, and monitoring safety compliance. We also contract with an independent third party to conduct risk-based assessments of our U.S. stores and clubs and to monitor the execution of specific elements of our EHS program. More than 31,500 visits were conducted in 2023.
Training is a key component of our program. In the U.S., new-to-role Walmart store and Sam’s Club associates are required to complete our safety foundations curriculum as well as tailored training that addresses the particular risks within their area. In FY2024, more than 96% of U.S. Walmart store and Sam’s Club associates timely completed their assigned safety training curricula.
Associates can also access microlearning courses on safety topics, which are available on-demand and provide in-the-moment information in an easily digestible format. Managers and hourly supervisors are required to complete specialized training designed to help them support associates within the facility and maintain a strong safety culture.
To help ensure a safe working environment for associates, we document and analyze associate incident and injury data. Our most common recordable incident types in the U.S. in FY2023 were4:
- Fall/Slip/Trip
- Material Handling
- Struck by Object
- Strain/Injury
- Cut/Puncture/Scrape
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 only includes incidents that resulted in at least one lost workday. Our significantly lower LTIR compared to RIR indicates that the majority of our recorded incidents were minor in nature.5
Retail RIR
Retail LTIR
Supply Chain RIR
Supply Chain LTIR
Consistent with our Ethics and Compliance program foundations, Walmart aims for continuous improvement in our EHS program, and we use the data from our incident and injury monitoring to develop new targeted trainings, as well as new or enhanced safety policies, procedures, and practices designed to reduce workplace illness and injury.
Walmart Safety on the Road
Walmart operates one of the largest and safest truck fleets in the U.S., with more than 15,000 commercially licensed drivers, more than 13,000 tractors and more than 90,000 trailers. In 2023, Walmart fleet drivers drove more than 1.1 billion safe miles, the equivalent of driving around the Earth 44,000 times.
In 2023, Walmart was recognized by the American Trucking Association for receiving top ranking in two categories for its 2021 performance:
- No. 1 in National Industrial Safety: this award, in the General Commodities Truckload Division, is for companies with more than 1,000 employees and is given for the low number of OSHA-classified driver injuries.
- No. 1 in National Truck Safety: this award, in the General Commodities Truckload/Line-haul Division, is for companies with drivers who cover more than 250 million miles and is based on the low number of accidents for the number of miles driven. Walmart has won the National Truck Safety Award for eight consecutive years and 16 times since 2000.
For Walmart’s private fleet, safety is our top value, and we maintain focus on reducing injuries and preventable collisions.
Combating Bribery and 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 (“A/C 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 to obtain or retain business is strictly prohibited. The A/C Policy applies to our associates and to third-party intermediaries (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:
- Assigning a Global Anti-Corruption Officer to supplement dedicated Anti-Corruption teams in every Walmart market.
- Conducting annual Anti-Corruption Program risk assessments, internal monitoring and testing, and TPI audits.
- Designing system enhancements to globally manage corruption risks, as well as implementing our Anti-Corruption Compliance Program with acquired entities.
- Training associates globally to identify corruption risks in our activities and report suspected violations of our A/C Policy and procedures. Training assignments and cadence are customized based on role, tenure, and knowledge proficiency. Associates who are more likely to encounter corruption risk touchpoints receive targeted anti-corruption training and awareness. Additionally, associates most likely to interact with government officials or work with TPIs receive live training, unless they demonstrate knowledge proficiency.
- Assigning tailored training to TPIs based on their risk level. The tailored training addresses the TPIs’ obligations under our Global Anti-Corruption Policy, their duty to report suspected program violations, and whom to contact for guidance.
Competing Fairly
Walmart is committed to free and fair competition, which helps enable lower prices, maximize consumer choice, and promote innovation.
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’s Antitrust Center of Expertise (COE) is responsible for advising the company with respect to antitrust matters and for the development and implementation of a strong Global Antitrust Compliance Program. The program is led by a team of global and jurisdiction-specific specialists who identify market-based risks and design comprehensive training, as well as potential controls and monitoring to mitigate relevant risks. The COE works in close partnership with teams across Walmart to ensure that compliance controls, training, and awareness are embedded throughout the company and that the program is continually informed by relevant developments and evolving business activities.
Walmart trains associates on antitrust topics through our Code of Conduct training. For associates who work in higher-risk business segments, additional detailed antitrust trainings are assigned. The COE also conducts targeted live trainings with teams in higher-risk business segments, both in the U.S. and globally, e.g., our merchandising, marketplace, and sourcing teams.
Selling Safe 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 specifications, facility procedures, monitoring and recalls, and withdrawals.
Read more: Safer, Healthier Products
Sourcing Responsibly
Walmart’s supply chain consists of thousands of suppliers globally, many of whom have their own individual supply chains. 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.
Read more: People in Supply Chains and Human Rights
- Laws and regulations differ substantially across the 20 countries where Walmart operates, and they are constantly evolving. This dynamic creates challenges for implementing comprehensive and global programs. Read more about these factors in our most recent annual report 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.
1. These foundations are informed by 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.
2. Associates may face discipline up to and including termination for a substantiated violation of our Code of Conduct or our ethics and compliance program policies. Other remedial actions may include reduction of associates’ annual cash incentive payment or additional assigned training or counseling.
3. Completion rate includes active associates as of the end of FY2024.
4. See the Bureau of Labor Statistics website for industry-wide information on the most common occupational injuries and illnesses involving days away from work. https://www.bls.gov/iif/nonfatal-injuries-and-illnesses-tables/case-and-demographic-characteristics-table-r4-2020.htm#iif_cd_r4p.f.3
5. Data represents U.S. numbers. Rates subject to adjustments as claims are conciliated and resolved. 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. Industry data have a one-year lag time and therefore do not appear in this chart for 2023.
