An ethics concern is one that involves alleged behaviors or business practices that are inconsistent with one or more of the sections of the Code of Conduct, such as sexual harassment, insider trading, and theft. If you see, suspect, or are told about an activity that violates our Code, compliance policies, Walmart’s Standards for Suppliers, or the law, you must report it to either your manager, People Lead, Ethics & Compliance, or Legal so that the concern can be reviewed and handled appropriately.
All reports to Ethics & Compliance are treated as confidentially as possible. It helps with follow-up if individuals identify themselves. However, if someone is not comfortable identifying themselves, they can make an anonymous report to the Ethics Helpline to the extent allowed by law.
Certain matters must be immediately reported directly to Ethics & Compliance:
Bribery (including any suspected violation of our Anti-Corruption Policy)
A company officer or direct report to any company CEO potentially violating the Code
Falsifying financial records or interfering with our internal controls on financial reporting
Global or local policies may indicate additional matters that must be reported directly to Ethics & Compliance.
Walmart takes all reported concerns or allegations seriously.
We confidentially review each ethics allegation to determine if any law, policy or the Code of Conduct has been violated and assign for investigation where appropriate. If an investigation is warranted, Global Ethics and Compliance is committed to protecting the integrity of these investigations. This includes protecting individuals who report the concern or allegation, as well as any witnesses, from being harassed, intimidated, or retaliated against. Additionally, we strive to keep evidence from being destroyed, verifying testimony provided, and identifying and addressing root causes.
We may reasonably impose a requirement that witnesses maintain the investigation and their role in the investigation in the strictest confidence. In such cases, individuals must maintain confidentiality and not discuss the investigation with others during the course of the investigation. Global Ethics & Compliance does not generally disclose investigation details, but you will be informed of the status of the investigation.
Fair and objective decisions build trust with our associates, customers, and third parties. When making business decisions, we put Walmart’s interests before personal interests. A conflict of interest occurs when personal interests interfere with, or may appear to interfere with, our work at Walmart. While we can’t list every circumstance, it’s important to know and avoid the common situations that could create a conflict or the perception of a conflict. Outside employment, financial investments, gifts and entertainment, and personal relationships are areas where conflicts can arise.
If you realize an activity or situation could influence or appear to influence your ability to make objective business decisions, let your manager, People Lead, or Ethics & Compliance know. They can help you take steps to avoid or resolve a conflict.
Living our value of Respect for the Individual starts with valuing diversity and inclusion. We believe having associates with different backgrounds, styles, experiences, identities, and opinions makes us a better company. Inclusion is an intentional act—it is investing time and energy to understand, support, and champion the uniqueness of individuals. Diversity and inclusion promote individual expression, creativity, innovation, and achievement—and help us better understand and serve our customers.
Work the Right Way
At Walmart, our associates are the key to our success. We pay people accurately for their work and hours. We respect human rights and prohibit the use of underage or forced labor anywhere we do business. We believe that when we take good care of one another, we will take good care of our customers and communities.
If you have any questions or concerns regarding our ability to work the right way or become aware of actions that violate our Global Labor & Employment Policy and Standards for Suppliers, please notify your manager, People Lead, or Ethics & Compliance.