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.
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.