Walmart’s global anti-corruption program strives to assist the company to achieve the highest standards of integrity in our business, while also setting a high standard for the global business marketplace. Walmart’s anti-corruption program includes:
- Walmart’s global anti-corruption policy and procedures – Our policy prohibits offering, giving, or receiving anything of value to gain an improper benefit for the company. Our procedures address several anti-corruption risk areas, including third-party due diligence, business expenditures, donations and sponsorships, licenses and permits, acquisition or lease of properties, government inspections, recordkeeping, as well as how to report allegations.
- Dedicated anti-corruption staff – Our team consists of anti-corruption professionals located in our home office and in each of our international markets who report centrally and are led by a dedicated global anti-corruption officer.
- Training and communications – Each year, we provide computer-based, baseline anti-corruption training to more than 100,000 associates and in-person, procedural anti-corruption training to those who are most likely to interact with governmental officials.
- Monitoring and assessment – We conduct an annual risk assessment to identify and evaluate risks and allocate program resources accordingly. Our anti-corruption continuous improvement team regularly assesses and enhances the program’s implementation in our international markets, providing timely feedback and enabling early identification and remediation of issues. In addition, the Global Internal Audit team also performs periodic, independent audits of our program.
- Third-party due diligence – We use a customized electronic system to screen for and conduct due diligence on third-party intermediaries who seek to represent us. Our contracts with third-party intermediaries require them to commit to following our anti-corruption policy. Additionally, to help our key third-party partners understand and apply these anti-corruption standards, we’ve invested heavily in providing them with anti-corruption training.
- Audits of third-party intermediaries – Each year, we proactively audit a sample of our third-party partners based on several factors, including the risks associated with the region where they operate and the type of service that they provide. This process allows us to examine the way that third-parties respond to our anti-corruption program and identify areas where we can continue to improve our training and controls.
Leading on anti-corruption benefits not only Walmart and our associates, but also the communities in which we operate and live.
Supporting our Communities through Giving
Each year our international stores give back to their local communities by donating tens of millions of dollars in goods to a variety of charitable causes. In support of those charitable efforts, Walmart and the Walmart Foundation developed a Global Donation Management System (“GDMS”), a computerized tool that makes it easier for our international stores to donate goods locally. Associates use GDMS to scan products to be donated, and the tool automatically validates whether the donation adheres to the relevant compliance policies, thereby making the process for reviewing and executing donations more accurate and efficient. In the past year, GDMS was used to process donations in over 2,000 stores internationally, representing a value of over USD 60 million in donated goods.