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Global Ethics & Compliance

Each week, Walmart serves nearly 265 million customers globally, and we employ approximately 2.2 million associates. In an organization of any size, a strong culture of integrity is essential, and at Walmart, our culture—the attitudes and actions that help create an honest, fair and compliant workplace—defines who we are as a company and how we treat each other, our suppliers and our customers. Walmart’s Global Ethics & Compliance program is designed to support our unique and growing business and help maintain our culture of integrity.

Our Program

Our Structure
Our Global Ethics & Compliance program is led by our Global Chief Ethics & Compliance Officer (CECO) who reports to the company’s Executive Vice President of Global Governance and Corporate Secretary. The CECO also provides regular updates to the audit committee of Walmart’s board of directors. The board of directors plays a critical and active role in overseeing the company’s ethics and compliance program. In addition to receiving a regular flow of information about ethics and compliance issues, each year the audit committee and the compensation and management development committee establish goals and metrics relating to ethics and compliance. The board assigns these goals to relevant executives and business units and establishes accountability for achieving adequate progress on the goals.

Our ethics and compliance efforts in our U.S. retail operations, our U.S. eCommerce business, and our International operations are each led by a Senior Vice President, CECO. These CECOs lead dedicated teams of ethics and compliance personnel, accounting for more than 2,000 associates worldwide. Each international market’s Ethics & Compliance program is led by a market CECO with direct reporting lines back to our company’s home office in Bentonville, providing increased transparency, consistency, and accountability. Market CECOs also sit on the leadership team of their local business, enabling a close relationship to and influence in local operations.

Ethics & Compliance Committees
We have ethics and compliance committees comprised of members of management at the global level and in each of our retail markets. Walmart’s most senior executives are members of the company’s Ethics, Compliance, and Risk Committee. That committee meets regularly to discuss current issues related to ethics, compliance, and other enterprise-level risks, with meetings structured to ensure follow-up and accountability for action items. Each of Walmart’s retail markets has its own similar committee consisting of the market’s senior management and its ethics and compliance leaders, including both the market CEO and the market CECO.

Our Program Building Blocks
The six basic building blocks of our global program help keep us consistent and responsive as our business and the external environment change:

  1. Leadership
  2. Risk Assessment
  3. Standards and Controls
  4. Awareness
  5. Training
  6. Monitoring and Response

We regularly evaluate whether we have the right leaders for each aspect of our program:

  • Those leaders conduct an assessment of the company’s risks and measures for managing them
  • The results of that assessment inform the continual development of our standards and controls
  • We make our associates aware of those standards and controls
  • We provide training for our associates on how to implement and use those standards and controls
  • We continually monitor and assess the execution of our program to provide data for making informed decisions

Ethics

Our culture of ethics and integrity—the attitudes and conduct that help create an honest, fair and compliant workplace—defines who we are as a company and how we treat each other, our suppliers and our customers. We summarize our ethical principles in the company’s Statement of Ethics, at WalmartEthics.com. Throughout their careers with the company, our associates are provided this and other resources to help them succeed
and to promote and recognize ethical choices. These resources include:

  • Global helpline - Walmart provides 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 equipped to handle most local languages spoken in each of the retail markets where we operate.
  • WalmartEthics.com - This website is available in 14 languages and accessible globally. It provides a platform where stakeholders can ask questions, read our Statement of Ethics, submit ethical concerns and follow up on previously reported concerns.
  • Global case management system - This is both a repository for ethics cases and a system for managing them.
  • Global case management process - Walmart has an established process for handling ethical concerns that promotes consistency across our global operations.
  • Integrity in action awards - Our global recognition program celebrates associates who model integrity or encourage others to do so. Associates nominate candidates, and Walmart recognizes the award winners at our annual Shareholders meeting. In FY2018, Walmart honored 14 associates representing 13 different countries.

Compliance

Walmart’s program is designed to manage the compliance risks associated with 14 different subject areas, ranging from anticorruption to food safety. These 14 subject areas reflect the complexity of Walmart’s global business. To provide relevant expertise in each subject area, we have designated Global Subject Matter Leaders and Subject Matter Experts for each of the 14 risk areas in each retail market. These Subject Matter Leaders and Subject Matter Experts work together to identify and coordinate common standards and procedures, share best practices, and provide training, monitoring, and support.

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