Statement of Ethics Statement of Ethics

Table of contents
Using the Statement of Ethics The 3 Basic Beliefs and Guiding Principles Introduction
Who is Covered What Law Applies Associate Responsibilities Additional Responsibilities for Management Associates Discipline for Violations 4 5 6 6 6 6 7 7 8 8 8 8 9

Leading with Integrity in Our Marketplace
Fair Competition Intentional Dishonesty Financial Integrity Insider Trading Restrictive Trade Practices

19 19 19 20 20 21

Leading with Integrity in Our Communities 22
Anti-Corruption Anti-Money Laundering Authority to Work Environmental Responsibility Health & Safety Protecting Personal & Business Information Government Contracts & Inquiries Political Involvement International Trade Media Statements 22 23 24 25 25 26 28 28 28 29 30 30 32 33

Raising Concerns & Speaking Up
Ethics Opinions Waivers What happens How to Raise a Concern

Leading with Integrity in Our Workplace

10 Alcohol & Drug Abuse 10 Harassment 11 Inappropriate Conduct 11 Non-Retaliation 12 Non-Discrimination 12 Wage and Hour 13 Conflict of Interest (COI) 14 COI – Financial Investments 14 COI – Personal Relationships with Suppliers 15 COI – Gifts & Entertainment 16 COI – Personal Relationships with Other Associates 17 Walmart Assets 18

Final Disclaimer Global Ethics Contact Information Ethics Committee Contact Information Index

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A message from our Chief Executive Officer
Mike Duke, CEO
Dear friends, Walmart started out with a single discount store in Northwest Arkansas and in less than 50 years grew to become the world’s largest retailer, with thousands of stores and clubs and millions of associates. Our culture of ethics and integrity has been a constant throughout that transformation. From the beginning, it has defined who we are as a company, and how we as associates treat each other, our suppliers and our customers. The values that set us apart from others -- respect for the individual, service to our customers and striving for excellence -- rest on the foundation of personal integrity and responsibility. Associates in all areas and levels of our business are responsible for understanding and complying with our Statement of Ethics. I encourage you to be a champion for integrity by engaging fellow associates in conversation and setting an example through your words and actions. We also expect and need you to speak up if you have concerns about any inappropriate behavior you observe. It’s important for us to know about issues upfront so we can work to resolve them immediately. We recognize the responsibility that comes with that requirement. And we know that the decision to speak up can be a difficult one. Silence can condone questionable behavior -- and the actions or inactions of just one associate who makes a poor choice can impact our entire company. That’s why we’re committed to sharing the responsibility with you. We encourage you to use the resources available to you such as the Open Door process and the Global Ethics Helpline. The Global Ethics Helpline is a tool that is available for you to raise your concerns confidentially and anonymously, without fear of consequences. A strong commitment to ethics and integrity isn’t just the right way to do business. It’s how we earn the trust and respect that is critical to our success, and our ability to help more people live better. Our customers trust us to be their advocate. Our suppliers trust us to be an equitable partner. And as Walmart associates, we trust each other to uphold the highest standards of conduct every day. I am confident that our commitment to ethics and integrity will continue to guide us well as we continue on our journey together.

Mike Duke

President and CEO Walmart

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Using the Statement of Ethics
This Statement of Ethics is going to introduce you to the types of attitudes and conduct that create an honest, fair, and legal workplace. You’re going to learn how to recognize situations that might come up on your job that could be a violation of our company ethics. Plus, you’ll learn what to do if you have any questions or concerns about what is correct and ethical conduct. Our 3 Basic Beliefs and Guiding Principles at the beginning of this Statement of Ethics will give you a general idea of correct company ethics. But, remember no guide or manual can give you a complete set of rules. So, in the end, we all must trust our own good judgment of right and wrong.

How the Statement of Ethics is organized
• Inside the front cover is a letter from Mike Duke, our president and CEO of Walmart. He points out how important it is for all of us to follow our Statement of Ethics, and how important it is to report anything we feel might be a violation of those ethics. • On the next page are our Guiding Principles. These are a good starting point as a set of guidelines for ethical behavior. • The Introduction section explains that it’s your responsibility to comply with our Statement of Ethics and to report what you feel might be any violation of policy or law. • The section Raising Concerns & Speaking Up tells you how to request an opinion before you take action and how to report what you think might be a violation of ethics, including a way to make a report in private and without giving your name. • This guide gives you an overview of many policies. Some commonly asked questions are included to help explain each policy better. There are also examples of how this Statement of Ethics and other Walmart policies apply in all countries.

Global policies and local laws
Each business organization Walmart operates is expected to have a complete set of policies providing guidance to associates for whatever country they are working in. Walmart also publishes several “global policies,” which are designed to give associates a set of rules that are the same for all locations. This Statement of Ethics is an example of a global policy. If any part of this Statement of Ethics goes against local policies or laws, then the local policy or law must always be followed. It’s our responsibility to know all of the local laws and policies that might affect our area of business. If you’re not sure about any local laws or policies, please talk to your manager, the Walmart in-country Legal Department, or the Global Ethics Office. Some local laws, practices, or even local customs could be more relaxed than our Statement of Ethics. If you find yourself in this kind of situation, you should always rely on our Statement of Ethics.

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Our 3 Basic Beliefs
Since Sam Walton founded Walmart, it has always been a values-based, ethically led company. The values that guide our decisions and our leadership are the 3 Basic Beliefs:

1 2 3

Respect for the individual
Guiding principles
These principles are meant to help our associates make the right decisions, and to act with integrity. • Always act with integrity. • Lead with integrity, and expect others to work with integrity. • Follow the law at all times. • Be honest and fair. • Reveal and report all information truthfully, without manipulation or misrepresentation. • Work, actions, and relationships outside of your position with the company should be free of any conflicts of interest (discussed later in this guide). • Respect and encourage diversity, and never discriminate against anyone. • Ask your manager or the Global Ethics Office for help if you have questions about this Statement of Ethics, or if you face an ethical problem. • Promptly report suspected violations of the Statement of Ethics. • Cooperate with and maintain the private nature of any investigation of a possible ethics violation. • When involved in an ethics investigation, you should reveal and report all information truthfully. You should present all the facts you are aware of without personal opinion, bias, or judgment.

Service to our customers

Striving for excellence

Vision statement
The vision of the Global Ethics Office is to promote ownership of Walmart’s ethical culture to all stakeholders globally.

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Introduction

A people that values its privileges above its principles soon loses both.
Dwight D. Eisenhower, 34th President of the United States

Who’s covered by the Statement of Ethics?
Associates and Directors
This Statement of Ethics applies to all associates worldwide, and all members of the board of directors of Wal-Mart Stores, Inc. It also applies to the associates and directors of all Walmart–controlled subsidiaries.

What law applies
Walmart conducts business in many countries around the world. Our associates are citizens of many countries and, as a result, our operations are subject to many different laws, customs, and cultures. The number of laws and regulations around the world that affect Walmart increase and become more complex each year. When it’s possible, this Statement of Ethics will be modified to conform to changes in laws and customs. In some instances, the laws of two or more countries will conflict. When you encounter a conflict, contact the Global Ethics Office or your in-country Ethics Committee to understand how to resolve the conflict.

Third Parties
Walmart expects its suppliers, consultants, law firms, public relations firms, contractors, and other service providers to act ethically and in a manner consistent with this Statement of Ethics. If you hire a service provider, you should take reasonable steps to make sure the service provider is aware of our Statement of Ethics, has a reputation for integrity, and acts in a responsible manner consistent with our standards.

Associate responsibilities
The following basic obligations apply to all associates: • Follow the law at all times. If you see any associate violating the law, or if you’re asked to do something you believe may violate the law, discuss it immediately with your manager, in-country Ethics Committee, or the Global Ethics Office. • Read and understand the Guiding Principles and use those principles in your job every day. • Learn the policies that apply to your job. No one expects you to memorize every policy, but it’s good to have a basic understanding of issues covered by each policy.

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• Ask for help from your manager, the Global Ethics Office, or other Walmart resources when you have questions about the application of this Statement of Ethics or other policies. • Immediately raise any concern you, or others, may have about possible requests or acts that may be a violation of this Statement of Ethics or any Walmart policy. • It’s important to understand how to raise ethics concerns. You can raise them with a manager, or by contacting the Global Ethics Office directly. Ways to raise concerns are described in more detail later in this guide. If you raise an ethics concern through a manager and the issue is not resolved, raise it through a different manager or the Global Ethics Office directly. • Cooperate with and maintain the privacy of any Walmart investigation into violations of this Statement of Ethics, or any other Walmart policy.

• Ensure open communication by encouraging associates in your department or division to ask questions concerning our Statement of Ethics. • Never cover up or ignore any ethical conduct problem. Address the matter in a timely manner and seek guidance if necessary. • Appreciate associates who raise issues. • Never retaliate against anyone for raising an ethics issue, assisting in an investigation, or participating in any proceeding relating to an alleged violation of any applicable government regulations, laws or rules, or an alleged fraud against shareholders. • Encourage self-reporting of business conduct violations. If an associate voluntarily reports that they were involved in an ethics violation, such self-reporting may be considered when determining the appropriate disciplinary action to be taken.

Additional responsibilities for management
As a management associate, you’re responsible for creating an environment that encourages compliance with Walmart Statement of Ethics. Supervision of responsible business practices is as important as supervision of performance. You should do the following to make sure our company maintains the highest ethics: • When an ethics issue comes to your attention, contact the Global Ethics Office for assistance. • Meet with your direct reports as a group periodically to review the Guiding Principles and this Statement of Ethics. • Where there is a conflict between our ethics and business objectives, our ethics must always come first. • Lead by example, and encourage your associates to act with integrity in all dealings to avoid even the appearance of a violation of our business standards. • If an ethics issue arises with one of your associates, make sure other associates in your area are not making the same mistake.

Discipline for violations
Appropriate disciplinary action, up to and including termination, may be taken against any associate whose conduct violates this Statement of Ethics or applicable laws and regulations, including the Guiding Principles.

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Raising concerns and speaking up

Ethics opinions
In the normal course of business, you might have a situation where you’re not quite sure if there is a violation of ethics, or whether the situation is within the standards described in this Statement of Ethics. When you have any ethics question, you are encouraged to use the Open Door process or contact the Global Ethics Office for a verbal or written opinion before you take any action.

Don’t compromise your reputation. It’s a precious commodity. Don’t compromise your integrity ... have a good name.
Sam Walton

Waivers and what happens when an ethics concern is raised
Waivers
Any associate (other than executive officers) can request from the Global Ethics Office a waiver of the applicability of this Statement of Ethics. Ethics waiver requests must be submitted in writing to the Global Ethics Office by the associate, and must contain in detail all of the relevant facts and circumstances supporting the requested waiver. The Global Ethics Office will respond in writing to the associate. For members of the board of directors and executive officers, requests for waivers of the Statement of Ethics will only be considered by the Audit Committee or by the full board of directors, as the board of directors determines. Members of the board of directors and the chief executive officer must submit their own waiver requests in writing. Written requests must set forth the relevant facts and circumstances supporting the waiver. After receipt and review of the request, the Audit Committee or the board of directors will respond in writing to the requester. Any waivers of this Statement of Ethics granted in favor of members of the board of directors or executive officers will be promptly disclosed to shareholders. All waiver requests must be approved in advance of the conduct for which approval is sought.

Raising concerns and speaking up
All of us should constantly work to maintain a working environment that encourages associates to raise concerns about possible violations of our Statement of Ethics. Often we hear stories of other companies where employees were aware of problems, but did not feel comfortable coming forward. No one should feel that way at Walmart. Please report possible ethics problems immediately so they can be resolved before more serious consequences develop.

What happens when an ethics concern is raised
Walmart takes all reported concerns seriously. We will confidentially investigate allegations to determine if any law, policy, or the Statement of Ethics has been violated. If you

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report a violation, the Global Ethics Office will make every effort to keep your identity private. We will also work to make sure any data relating to the investigation is kept secure. To assist in privacy, it’s important that you do not discuss your concern with others. If you’ve raised a concern with management, they will follow up with you in a reasonable amount of time and provide an update on the issue. Specific information regarding investigations is private information, but you will be told the status of the investigation — whether it’s active or closed.

Q&A
If an associate reports a Statement of Ethics violation to the Global Ethics Helpline, is that associate exempt from disciplinary actions for unrelated misconduct? Not necessarily. The report made by the associate, and the associate’s own misconduct are two separate issues that should be dealt with independent of each other. We are all expected to perform our duties with integrity, respect, and are accountable for our own actions when conducting business for Walmart.

How to raise a business conduct concern
Walmart provides a variety of resources you can turn to when you need to raise a question or concern. Depending on the nature of the concern, it may be easiest to talk to the person responsible directly about your concerns, providing them an opportunity to clarify their conduct. If you don’t feel comfortable handling the situation yourself, or if you believe the misconduct involves a legal issue, you should consult one of the following resources:

• Call your local Ethics Committee

U.S.A., Puerto Rico and Canada = 1-800-WM-ETHIC [1-800-963-8442] Canada (French) = 1-800-805-9121 (Specific phone numbers for all countries are listed in the back of this tool.)

• Use the Open Door Communications process

The Open Door Communications process is the most direct way to voice any concern to a manager. If you believe your immediate manager is involved in the problem, discuss the issue with the next level of management who is not involved, or use one of the other resources described below.

• Contact the Global Ethics Office by mail, e-mail, or on the Internet Mail Wal-Mart Stores, Inc. Attn: Global Ethics Office 702 SW 8th Street Bentonville, AR 72716-0860 E-mail ethics@wal-mart.com Internet walmartethics.com

• Call the Global Ethics Office

Walmart has a Global Ethics Helpline, which is available to associates around the world 24 hours a day, seven days a week, and is equipped to handle most local languages. The Helpline is staffed by an organization not affiliated with Walmart, and to the extent possible (and in conformity with local regulations), callers may not have to give their name. In all cases, associate privacy will be respected to the fullest extent possible under the law. The operator will relay the information to the Global Ethics Office, and will provide the associate with a case number and callback date if desired. Global Ethics Office phone numbers are located in the back of this tool.

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Leading with integrity in our workplace

You can overcome almost anything, but you cannot overcome a lack of integrity.
Lee Scott

Q&A
I was asked to take a drug test before accepting a promotion into management. Is this standard? Where permitted by law, job applicants may be drug screened as part of the post-offer hiring process, or prior to accepting a promotion into management. Any applicant who tests positive for illegal drug use will not be hired or promoted, and may be terminated. In addition, Walmart may require you to submit to drug testing following certain on-the-job injuries or if there’s a reasonable basis to suspect you’re under the influence of drugs (also only where permitted by law). Is there somewhere I can go for help if I have a drug or alcohol problem? Walmart operations in some countries provide Helplinecounseling services. Please contact your Human Resources manager or local substance-abuse counseling center for help. I’m attending a Walmart–sponsored group/supplier meeting. Alcohol will be served. May I have alcohol while there? With executive vice president approval, Walmart– sponsored events may provide alcohol. Associates of legal age may consume alcohol at these events as long as they do not allow it to impair their judgment.

Leading with integrity in our workplace Alcohol & drug abuse
Walmart is committed to a safe and healthy workplace for everyone. The use of alcohol and illegal drugs can create serious safety risks in our workplace. The possession, solicitation, or use of illegal drugs, or being under the influence of such drugs on company time, while on company property, or at any Walmart– sponsored event, is prohibited and will not be tolerated. In some instances, associates may consume alcoholic beverages at company-sponsored events when appropriate monitoring is in place, off Walmart property, and with the appropriate level of approval (your in-country president, your division’s executive vice president, or your in-country Ethics Committee). Walmart will take common business practices into consideration in countries where a moderate consumption of alcohol with a meal is common. All associates should ensure their performance and judgment are unimpaired by alcohol consumption during working hours.

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Harassment
We believe in treating each other with respect, whether it’s a co-worker, supplier, customer, or anyone doing business with us.

Harassment:

Any conduct which inappropriately or unreasonably interferes with work performance, diminishes the dignity of any person, or creates an intimidating, hostile, or otherwise offensive work environment.

Verbal, visual, or physical conduct of a sexual nature is not acceptable in the workplace and may be determined to be sexual harassment. Examples include: • Sexual advances, requests for sexual favors, sexually explicit language, off-color jokes, remarks about a person’s body or sexual activities. • Displaying sexually suggestive pictures or objects, suggestive looks or leering, or suggestive communication in any form. • Inappropriate touching, both welcome and unwelcome.

Q&A
A department manager comments regularly about my body. What should I do? We encourage you to first tell the person to stop. If you’re not comfortable with this, or the activity does not stop, contact your manager through the Open Door process, your Human Resources manager, or the Global Ethics Office immediately. Is my desk calendar with occasional sexual jokes appropriate in the workplace? It could be offensive to someone else in the workplace. If you’re in doubt, remove the item from the workplace. An associate used a word in a meeting that is offensive to me. What should I do? Speak up and tell the person. Some words are universally offensive but some are not. They might not know the word could be seen as offensive to someone. You can also exercise the Open Door process, contact someone in Human Resources, or the Global Ethics Office.

Inappropriate conduct
We believe in maintaining a working environment free of violence or threats of violence. This means inappropriate language, gestures, threats of violence, and physical violence will not be tolerated. This kind of behavior creates hostile working conditions, and violates the first of the 3 Basic Beliefs: respect for the individual.

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Leading with integrity in our workplace

Q&A
I reported an allegation six months ago. Ever since, my manager stopped including me in several meetings. Is this retaliation? Significant changes in how you’re treated can be viewed as retaliation. If your manager treats you differently since you reported an allegation, you should raise your concern to management through the Open Door process or to the Global Ethics Office. One of my associates called the Helpline and made a false claim against me this past year. I think they did it to hurt my career. Can I score them lower on the “Integrity” section of their evaluation since they’re obviously trying to spread lies about me? We should believe that associates who report concerns do so in good faith. Therefore, taking action against an associate for reporting a concern would be viewed as retaliation, and could result in disciplinary action for you as a manager. Retaliation will not be tolerated at Walmart. It prevents an open reporting environment, and encourages a culture of fear. After an associate reported an ethics violation concerning their assistant manager to the Human Resources manager, their assistant manager began tracking all their mistakes. Is this retaliation? Any variations from how the assistant manager previously treated the associate, and variations from how they treat other associates could be perceived as retaliation. Is protection from retaliation only provided if I report my concerns through the Helpline? Retaliation is unacceptable no matter which source you used to raise your concern (through management, Human Resources, or Global Ethics). If you believe you have been retaliated against, please contact one of those sources immediately.

Non-retaliation
Associates who come forward with concerns play an important role in maintaining a healthy, respectful, and productive workplace, as well as protecting our stakeholders. These associates help our company address problems early — before more serious consequences develop. It‘s important for each of us to create a working environment where everyone can raise concerns of ethics issues without fear of retaliation. Retaliation against associates who raise concerns or questions about misconduct in “good faith” will not be tolerated. Good faith means that you have made a genuine attempt to provide honest and accurate information, even if you are later proven to have been mistaken. Walmart reserves the right to discipline anyone who knowingly makes a false accusation or has acted improperly. However, if an associate voluntarily reports that they were involved in a violation, such self-reporting may be considered when determining the appropriate disciplinary action to be taken. Walmart will not terminate, demote, or otherwise discriminate against associates for raising concerns. Also, it is important for co-workers not to isolate associates who have raised concerns — such employees should be treated with respect. Any change in treatment toward an associate who has raised a concern could be seen as informal retaliation. Walmart has established a process to deal with retaliation issues. Associates who believe they have experienced retaliation after raising an ethics concern should bring the issue to the attention of their manager, or to the attention of the Global Ethics Office. The helpline can also be used to discuss a retaliation issue.

Non-discrimination
The first of the three basic beliefs upon which Sam Walton founded our company is “respect for the individual.” Each of us is responsible for creating a culture of trust and respect that promotes a positive work environment. This means treating one another with fairness and courtesy in all of our interactions in the workplace. We are committed to maintaining a diverse workforce and an inclusive work environment. Walmart will not tolerate discrimination in employment, employment-related decisions, or in business dealings on the basis of race, color, ancestry, age, sex, sexual orientation, religion, disability, ethnicity, national origin, veteran status, marital status, pregnancy, or

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Character is power.

Booker T. Washington, American educator (1856-1915)

any other legally protected status. We should provide an environment free of discrimination to our associates, customers, members, and suppliers.

Q&A
In the break room, another associate called me a disrespectful name associated with my nationality. What should I do? Immediately contact your manager through the Open Door process or contact the Global Ethics Office. A customer continues to call me bad names while in my checkout line. What should I do? Contact a member of management or the Asset Protection department in your store. My manager asks me to pick up some carts each evening on my way to my car. What should I do? You should tell your manager you have already clocked out, and it is a violation of company policy for them to ask you to work off the clock. My manager has reduced my hours recently because she says we need to cut expenses. Is this a violation of the Wage and Hour section? If you want to raise concerns about your hours being reduced, you should exercise the Open Door process by contacting your store, market, or Human Resources manager.

Wage and hour
We are committed to complying fully with all applicable laws and regulations dealing with wage-and-hour issues, including off-the-clock work, meal and rest breaks, overtime pay, termination pay, minimum-wage requirements, wages and hours of minors, and other subjects related to wage-andhour practices. As Walmart associates, we must: • Comply fully with all corporate policies and procedures related to wage-and-hour issues; • Comply fully with all applicable federal, state, and local laws and regulations pertaining to wage-and-hour issues; • Report any violations of wage-and-hour laws or policies to management. It is a violation of law and Walmart policy for you to work without compensation or for a supervisor (hourly or salaried) to request that you work without compensation. You should never perform any work for Walmart without compensation.

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Leading with integrity in our workplace

Personal and moral integrity is one of our basic fundamentals and it has to start with each of us.
Sam Walton

Q&A
I’m a Vision Center regional manager. I’ve recently invested $10,000 in an investment fund that may invest some of the money in the optical industry. Would this be a violation? Since you don’t have direct control over the investment strategy, it’s not a violation. Someone told me I could not own stock in a vendor. Is this correct? No. The restriction is you may not have any direct financial interest in a vendor whose business you have direct or indirect influence over within your position at Walmart. There are no restrictions to financial interests in vendors you do not have business influence over. I recently joined Walmart and I own more than $20,000 of stock in a key competitor. Must I sell this stock? You should disclose the information to your manager and the Global Ethics Office. The Global Ethics Office will issue you an opinion with any instructions regarding any potential conflicts of interest.

Conflict of interest
General
We have a responsibility to all our stakeholders to make decisions strictly on the basis of Walmart’s interests, without regard to personal gain. A conflict of interest can arise when our judgment could be influenced, or might appear as being influenced, by the possibility of personal benefit. Even if it’s not intentional, the appearance of a conflict may be just as damaging to your reputation, and Walmart’s reputation, as an actual conflict. We should always be on the lookout for situations that may create a conflict of interest, and do everything we can to avoid them. It’s your responsibility to tell your immediate manager about any situation that you think creates, or could create, a conflict of interest. Managers are encouraged to bring the matter to the attention of the Global Ethics Office. They will determine how to handle the situation. Conflict of interest situations can come up in various ways. The following sections outline some of the possibilities.

Financial investments
As a representative of Walmart, you have a responsibility to make sure your personal financial activities do not conflict with your responsibilities to the company. A financial conflict of interest can arise when your judgment could be influenced, or might appear as being influenced, by the possibility of personal financial gain.

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Examples of conflicting financial investments are: • Financial interest in a vendor of Walmart, if you have direct or indirect involvement in our business with that vendor. • Substantial financial interest in a competitor. • Receiving personal compensation from a vendor, if you have direct or indirect involvement with our business concerning that vendor. • Using confidential company information for personal gain. Ownership of stock in a competitor with a market value in excess of $20,000 must be disclosed in writing to the Global Ethics Office. The Global Ethics Office will decide whether or not a conflict, or potential conflict, exists and how it should be handled.

If you believe you may be perceived as having an inappropriately close relationship with a supplier, or appear to be exerting a business influence on the supplier, inform your manager or the Global Ethics Office.

Q&A
There’s a contracting company I do business with as part of my position with Walmart. They’ve asked me if I know of an engineer they could hire. My son is qualified and would like to work for this company. May I refer my son for the position? No. Even though the contracting company sought your recommendation, it could be interpreted that you are using your position with Walmart to get your son a job. That would be a conflict of interest that could compromise your reputation as a representative of Walmart. My next-door neighbor is one of my suppliers. They invited my family and me to a neighborhood party. Would it be a violation of the Personal Relationships with Suppliers policy if we went to the party? It would be OK to attend as long as the party is open to the entire neighborhood and you’re invited because you’re a neighbor, not because of your position with Walmart. Remember to ask yourself, if another supplier or other associates knew of this situation, would it appear you are giving preferential treatment to your neighbor as a supplier?

Personal relationships with suppliers
Walmart encourages associates not to have social or other relationships with suppliers if the relationship would give the perception that a business influence is being exerted. We believe in basing our relationships with suppliers on efficient, fair and lawful business practices. The selection of suppliers must be made on the basis of objective criteria, including integrity, quality, price, delivery, adherence to schedules, product suitability, maintenance of adequate sources of supply, and Walmart’s purchasing practices and procedures. We must treat our suppliers with respect, fairness, and honesty. We must not take undue advantage of a supplier by using Walmart’s business influence. Also, we should expect our suppliers to follow all applicable legal requirements in their business practices. A conflict of interest may exist if a former associate is calling on Walmart in an area in which the associate worked or had influence over while employed at Walmart. The Global Ethics Office will make the determination as to whether a conflict of interest exists. When a former associate takes a position with, or on behalf of, a supplier, Walmart will not do business with that associate for a period of three (3) years following his or her separation from Walmart if a conflict of interest, as defined above, is determined to exist. In addition to the restriction described in the preceding paragraph, when a former Walmart officer takes a position with, or on behalf of, a supplier, Walmart will not do business with that former officer for one (1) year following his or her separation from Walmart, regardless of the area in which the former officer was involved at Walmart.

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Leading with integrity in our workplace

Q&A
Our market electronics team is attending a training session, hosted by a supplier, to understand a new item the supplier is launching. The supplier said we will each get free t-shirts for attending the training. Can we accept the t-shirts? Since the t-shirts are coming from the supplier and are not related to the product, and understanding of the product, they cannot be accepted. Politely decline the t-shirt and explain our gifts and entertainment policy to the supplier. I’m attending a business training session sponsored by a professional organization. Following the first day of training, the suppliers sponsoring the event are going to provide snacks and drinks at a reception for all attendees at the session. Can I go and have snacks and a drink? Yes. Since the reception is open to all attendees, you’re not being singled out as a representative of Walmart.

Gifts and entertainment
Accepting gifts and entertainment can cause a conflict of interest, or the appearance of a conflict between personal interests and professional responsibility. The Walmart culture is to never accept gifts or entertainment from any supplier, potential supplier, government, or any person the associate has reason to believe may be seeking to influence business decisions or transactions. Associates also may not accept a gift or gratuity from a customer for work performed by the associate in a store or club, except as required by local or national policy. We may not accept items donated to Walmart by suppliers for the purpose of raising funds for charities or non-profit organizations. Also, we should not accept or approve of them making donations on behalf of Walmart. Our policy of declining all gifts and entertainment stems from our value of maintaining Every Day Low Costs. Since such gifts and entertainment increase the cost of doing business, we help our suppliers to give us low costs on products by not expecting the gifts and entertainment they may have to spend on other customers. We recognize, as a global company, we may encounter situations where local practices will come into play. The Global Ethics Office will review these situations on a case-by-case basis. When you are establishing a new business relationship, make sure all parties are aware of our policy regarding gifts and entertainment. In some countries where gift giving is a custom or tradition, you should politely explain this policy to your customers and suppliers, especially prior to holiday gift-giving periods, in order to establish expectations. Also, be aware of what policies your suppliers or other business partners may have in place about this issue and take them into consideration. Occasionally, there may be times when returning a gift would be impractical or embarrassing. In those rare instances, accept the gift on behalf of the company, report it to your manager, and give the gift to the in-country Ethics Committee or the Walmart Foundation. If either of those options are not possible, find a fair way to distribute the gift equally among the members of your department. You should immediately tell your manager or the Global Ethics Office about any gift you’ve been offered or received if you feel that gift might be a violation of our company’s policy. If you have any questions about gifts and entertainment, you should seek assistance from your manager, the in-country Ethics Committee, or the Global Ethics Office.

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You should always be aware of how the act of accepting a gift or gratuity might be perceived by the public, by other suppliers, or by other associates. When dealing with external businesses, you should ask yourself, “Would this business be offering me this gift or gratuity if I wasn’t employed by Walmart?” If the answer is “no” or is unclear, you should not enter into the transaction.

Q&A
A supplier I work with has offered me two tickets to the World Cup if I pay face value for them. Can I buy the tickets? You should decline the offer. Although you may be paying face value for the tickets, it may not necessarily reflect the market value of the item. Some areas allow you to resell tickets, and you might be able to make a profit if you sold them. Also, there could be a gift of prestige in receiving the ability to attend a coveted event, such as the World Cup. I’m an assistant manager of a store. Recently, I started dating another assistant manager in my store. Is this OK? Since you do not have influence over the other assistant manager’s terms of employment, it would not be a violation. We recommend you tell your store manager about the relationship so they would be cautious not to place either of you in a potential conflict situation, such as a temporary assignment of store management duties.

Personal relationships with other associates
At Walmart, we want to provide a work environment where associates can perform effectively and achieve their full potential. We are all responsible for creating a climate of trust and respect, and for promoting a productive work environment. There is a basic conflict of interest when you manage someone with whom you have a family, romantic, or dating relationship. Even if you’re acting properly, your relationship will likely be seen as influencing your judgment. This can damage morale and disrupt workplace productivity. Therefore, you may not supervise, directly or indirectly, any family members or any associate with whom you date or are romantically involved. This includes situations where you may be able to influence that associate’s terms and conditions of employment, or if that associate can influence the terms and conditions of your employment. Walmart strives to eliminate personal relationships that interfere with work performance or which may constitute harassment. You should ask for guidance and advice from your manager or from the in-country Ethics Committee whenever an issue comes up regarding a personal relationship. Your manager or Human Resources manager can discuss options with you, such as a possible transfer to remove the conflict.

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Leading with integrity in our workplace

The strongest bond of human sympathy outside the family relation should be one uniting working people of all nations and tongues and kindreds.
Abraham Lincoln, former President

Q&A
I have to travel often for my job. Can I use my company laptop to check my bank account online while I am traveling? Yes, as long as it does not interfere with work performance. My manager told me when I travel with my laptop I should carry it on the plane with me. Is this really necessary? Yes. When traveling with a company-issued laptop, you must carry it on the plane with you. It may not be checked with your baggage. This is necessary to protect the laptop and the information contained on it from theft, loss, misuse, or damage.

Walmart assets
We have a responsibility to our shareholders to use Walmart property and assets for Walmart business, and not allow them to be used for any type of personal gain. You’re responsible for maintaining Walmart property under your control and should take reasonable steps to protect it from theft, misuse, loss, damage, or sabotage. Where permitted by law, associates have no expectation of privacy as to the use of Walmart communication tools (such as e-mail or voice mail). Walmart has the right to and does monitor communications tools, including the content and usage of such tools.

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Leading with integrity in our marketplace

Leading with integrity in our marketplace Fair competition
Fair Competition laws protect free enterprise by ensuring vigorous competition and prohibiting activities that restrain trade. Fair competition laws vary from country to country, but they commonly prohibit or regulate business practices that would be expected to cause prices of goods or services to be higher, or availability or choices to be less, than would be the case in a competitive market. For example, in some countries, fair competition laws may prohibit or regulate practices such as price fixing and agreements between competitors not to compete in particular markets or businesses. We are committed to doing our part to preserve free enterprise by requiring all associates to comply with fair competition laws. For specific information on local laws such as these, please consult your country’s Legal Department.

Q&A
An industry trade association has contacted me about participating in a benchmarking study for members of their association. This seems like a good way to obtain information about our competitors. Should we participate? There is nothing wrong with participating in industry benchmarking activities; however, this should not be used as a means to uncover confidential information on competitors. My manager told me to markdown several items to zero but leave them on the shelves to sell because it will, “help our inventory.” Is this ok? Not only is this dishonest, but it could also affect the store’s profitability. If you’re being instructed to do this, contact management through the Open Door process, Human Resources, or the Global Ethics Office.

Intentional dishonesty
Striving for excellence means operating our business with high integrity, and avoiding deceptive, dishonest, or fraudulent activities. Fraudulent actions are not only unethical, but may also be a violation of law. You should manage your particular area of business with as much transparency as possible. You should encourage a work environment that supports the contributions of your associates, and is based on our company’s values and ethics. Acts of fraud or dishonesty are more likely to occur in environments with insufficient controls and unrealistic expectations. In order to maintain excellence in our operations, you should encourage transparency, honesty, and realistic expectations.

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Leading with integrity in our marketplace

Do the right thing. It will gratify some people and astonish the rest.
Mark Twain, author

Q&A
An associate near me says she makes adjustments to our financial information so that our “good months” will help out our “bad months.” Could this be an issue? The practice of incorrectly recording financial data can have serious consequences both personally and as a company. You should report this immediately to the Global Ethics Office or Internal Audit. I have inside information about a product that will be released by another public company. Can I buy that public company’s stock? Any stock sale or purchase based on inside information is considered insider trading. Could I encourage a friend to buy it? Encouraging others to purchase would still be considered insider trading and also commonly referred to or known as “tipping.” The friend would be liable for insider trading, if he or she purchased shares as a “tippee,” and you would be liable for insider trading as a “tipper,” even though you did not buy any shares of the public company’s stock.

Financial integrity
Walmart requires honest and accurate recording and reporting of financial information in order to make responsible business decisions. All financial books, records, and accounts must accurately reflect financial transactions and events. They must conform to generally accepted accounting principles, and to Walmart’s system of internal controls. No Walmart document or record may be falsified for any reason. No undisclosed or unrecorded accounts of Walmart’s funds or assets may be established for any purpose.

Insider trading
Inside information is any material non-public information that a reasonable investor is likely to consider important when making an investment decision. Common examples of inside information include: • Projections of future earnings or loss • News of a significant or pending merger, acquisition, or tender offer • News of a significant sale of assets, or the disposition of a subsidiary • Changes in dividend policy, the declaration of a stock split, or the offering of additional securities • Changes in executive management • Significant new products or discoveries • Impending bankruptcy or financial liquidity problems • Significant lawsuits or legal settlements • The gain or loss of a significant supplier or customer • The possible awarding or cancellation of a significant contract to either Walmart or to a supplier

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It is illegal to buy or sell stock or other securities on the basis of material, nonpublic (i.e., inside) information. It is also illegal to communicate (or “tip”) inside information to others so that they can buy or sell stock or other securities. If you are aware of inside information about Walmart or any other company, including our suppliers or business partners, you are prohibited from trading (directly or indirectly) or tipping others to trade in the stock or other securities of that company. These same restrictions apply to any person who lives in your household or who is financially dependent upon you. • Never buy or sell the stock or other securities of any company while you have inside information about that company. • Never recommend that anyone buy or sell the stock or other securities of any company while you have inside information about that company. • Don’t disclose inside information about Walmart to anyone outside of Walmart (including your family members), unless such disclosure has been approved by the Legal Department, and only after the Legal Department has informed you that adequate steps have been taken to prevent misuse of the information. • Disclose inside information to people within Walmart only on a “need-to-know” basis.

Restrictive trade practices
We will not participate in any activity intended to restrain trade, or promote a refusal to conduct business with customers, members, or suppliers, in any country where such a refusal would be in violation of applicable law. If you learn of a refusal to conduct business request, or any related request, report it immediately to the Legal Department. Agents representing Walmart must comply with this policy as well.

Q&A
I was told I should boycott one of my suppliers because they conduct business in a certain country. Should I not do business with that supplier? Although restrictions are sometimes placed on certain countries and individuals, it’s always best to speak to the Legal Department when you’re instructed to boycott a supplier or country.

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Leading with integrity in our communities

There are really only two important points when it comes to ethics. The first is a standard to follow. The second is the will to follow it.
John C. Maxwell, leadership expert

Q&A
Local police officers have recently stopped trucks leaving our distribution center and threatened to delay deliveries unless the driver pays $50 U.S. in cash to the officer. My manager said we should carry $50 gift cards with us. Is it permissible? Walmart policy prohibits even small unofficial payments to government officials to influence government action. This prohibition applies to cash, gifts, or other things of value. Immediately report this matter to the Legal Department or the Global Ethics Office. A store is seeking a permit from the local Transport Authority. The store usually gives holiday baskets to various local officials. This year, the store manager suggested including a $300 gift card in the basket for the head of the Transport Authority. Is this acceptable? The policy does not allow the gift because it’s something of value and is apparently intended to influence the Transport Authority. The policy does permit certain customary gifts, such as holiday baskets that are of relatively low value and are not intended to influence anyone.

Leading with integrity in our communities Anti-corruption
We believe in fair, free and open markets, and in promoting good government. We do not tolerate, permit, or engage in bribery, corruption, or unethical practices of any kind. Bribery of public officials in the U.S. and abroad is illegal under both U.S. law and the local law of the countries in which we operate. Walmart’s policy goes beyond these legal requirements and prohibits corrupt payments in all circumstances, whether in dealings with public officials or individuals in the private sector. Specifically, the Global Anti-Corruption Policy prohibits us from paying, promising, offering, or authorizing a payment, directly, indirectly, or through a third party, money or anything of value to a government official or political party for the purpose of influencing an official act or decision in order to obtain or retain business or secure an improper advantage. The term “government official” includes any person acting in an official capacity for or on behalf of a government or governmental agency or department, including a business with government ownership (for example, a national oil company); a public international organization (for example, the U.N. or World Bank); or a political party or candidate for political office. Even when local practices or customs allow behavior that violates our Anti-Corruption Policy, it is not acceptable for us to do so.

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Anti-money laundering
We’re committed to complying fully with all applicable moneylaundering laws throughout the world. We must comply with all applicable laws prohibiting money laundering. Some countries also have laws related to the reporting of cash or other suspicious transactions that we must obey. Be alert to the following activities: • The types of payments that have become associated with money laundering, such as: multiple money orders, travelers checks, or large amounts of cash. • A customer or other third party who is reluctant to provide complete information, provides false or suspicious information, or is anxious to avoid reporting or recordkeeping requirements. • Unusually favorable payment terms or unusual fund transfers to or from foreign countries unrelated to the transaction. • Structuring a transaction to avoid requirements, such as conducting multiple transactions below the reportable threshold amounts. You must follow our rules concerning acceptable forms of payment. For further guidance on this topic, please consult with your local Legal Department.

Q&A
A customer refuses to provide their address for a $3,000 money transfer to another country. Should I report this as a “suspicious person”? Any customer reluctant to provide requested information should be reported as a “suspicious person” when processing financial transactions. A customer asked me if I could split a $5000 transaction into two transactions of $2500 so they did not have to bother with the paperwork that may otherwise be involved. Should I process the transaction this way? No. If it’s truly the same transaction, it should be processed as one transaction and the proper paperwork should be completely filled out and turned in to the Home Office for reporting to the government. If the customer refuses to comply, contact a member of management to assist you.

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Leading with integrity in our communities

To see what is right and not to do it is want of courage.
Confucius

Q&A
Should I report suspected non-authorized workers if they’re technically employed by a contractor and not Walmart? Yes. We require our contractors to use only work-authorized employees at our facilities. If you suspect there are unauthorized workers at our work sites, please contact the Global Ethics Office. What should I do if an associate arrives ready to begin working and they cannot show evidence of work authorization? Follow your country’s policies regarding employment authorization. This includes verification for new associates as well as visiting associates on an expatriate or transition assignment. For example, under U.S. law an employer must terminate the employment of an employee who is unable to show evidence of work authorization by the third day of work.

Authority to work
We strive to be good corporate citizens. Therefore, we may not hire, recruit, or refer for a fee, anyone not legally authorized to work in the country in which employment is sought. It is our responsibility to inspect, verify, and document the identity and employment authorization of every new associate, including associates who are international expatriates on assignment in a foreign country. We are also responsible for re-verifying the continuing employment eligibility of each associate by requesting further documentation when the initial work authorization has expired. All persons we hire or send to a foreign country on an expatriate or transition assignment must provide proper documentation and verification of their authorization to work in the country where they are to be employed. In complying with immigration laws, it is important to follow our policy against employment discrimination on the basis of national origin or possible citizenship status. We require all employment agencies, contractors and others doing business with us to fully comply with all immigration laws.

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Environmental, health and safety in the workplace
Environmental responsibility
We’re committed to environmental protection and preservation of our natural resources. We’re also responsible for complying with all applicable environmental laws and regulations. This responsibility is one of the core foundations for our environmental sustainability commitment. Our policy is to conduct our business in a socially responsible and ethical manner that protects the environment of our customers, members, associates, and communities.

Q&A
An associate spilled a liquid chemical cleaner, wiped up the spill with a towel and threw the towel in the trash and the remaining cleaner down the drain. How should this be handled? Once the cleaner was spilled, it became a hazardous waste as well as all materials to clean up the spill. Therefore, the towel must be disposed of as a hazardous waste in the appropriate hazardous waste management bucket. All remaining liquid should be managed as a hazardous waste in the bucket as well. Since this behavior is a violation, report it to a member of management, Human Resources, or the Global Ethics Office. The produce manager always leaves the forklift parked in front of the Emergency Exit. Is this a problem? Walmart faces fines and liabilities for safety hazards such as blocking or locking fire exits. It is crucial the fire exits be accessible during emergencies.

Health and safety
We’re committed to the health and safety of our customers, members, and associates, because we care for one another. Conducting our business in compliance with all health and safety laws is crucial to protecting each other from harm. As an associate of Walmart, always comply with all relevant health and safety laws and policies. By following these, we can create and maintain a safe shopping and working environment for our customers, members, and associates.

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Leading with integrity in our communities

Q&A
An invoice associate is married to a supplier who works with the buyers at the Home Office. I’ve seen her call her husband and tell him the cost of products we’re buying from his competitors. Is this a violation? Yes. Although she does not have influence over the business he works with at Walmart, she has access to confidential information that may be giving her husband’s company an advantage over other suppliers. A co-worker of mine has recently given her resignation. Since then, she’s been e-mailing supplier contact information to her home computer so she can start her own business. Is this a violation? Yes. The supplier information she obtained through her position at Walmart is considered confidential company information. She should not be using it for her personal business. A friend of mine told me he could give me information regarding a competitor’s upcoming advertising strategy. Should I get the information? No. We have no desire, or need to know the trade secrets of other companies.

Protecting personal and business information
In your daily business, you might be exposed to personal and business information about associates, customers, members, suppliers, and our own company. It’s your responsibility to protect this information in accordance with applicable laws, industry best practices, and our corporate beliefs. Information may be physical (on paper) or electronic. You should only collect or store personal or business information needed to perform your jobs. Manage that information securely through its lifecycle. Information is divided into three classes of data: private (high security), confidential (medium security), and unprotected (low security). Examples of ways to protect private or confidential information include: • Accessing the information for business purposes only. • Sharing it with other associates for legitimate business purposes only. • Preventing unauthorized access (for example, locking up private data). • Return all private and confidential information to Walmart along with any other Walmart property upon termination of employment. • If there is no business need, or a hold for legal purposes, for keeping the data, dispose of it by placing it in a shredder or confidential bin; never throw it in the trash. If you believe you have information that needs to be shared outside the company, seek approval from your manager or the Legal Department first. Trade secrets are an example of business data we must protect. In our pursuit of “striving for excellence,” we have invested in the development of systems, processes, products, business procedures, and technology – our trade secrets – that have made us a leader in the retail industry, and give us a competitive edge. All trade secrets are private data and must be kept secure. In addition to protecting our own trade secrets, it’s our policy to respect the trade secrets of others. No associate may reveal the trade secrets of the companies with which we conduct business, or of their former employers.

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Q&A
My manager told all my peers about my medical condition when I called in sick yesterday. Is that a violation of the Privacy policy? It could be. Your peers do not have a business need for knowing your medical condition. Many times the information is shared out of genuine care and concern for you as an important and valued member of the team. Talk to your manager and tell them your concern. If you don’t feel comfortable talking to them, contact your Human Resources manager or the Global Ethics Office. A pharmacy associate told me a certain customer has a rare medical condition. Is she allowed to share this information? No. Personal information about our customers (including medical data) is confidential and should not be shared. I have an anonymous blog that I write on a regular basis. Can I post information I’ve learned based on my job? While posting information online can be a great way to communicate with others, it’s important to consider some of the risks and rewards that are involved. Maintain the confidentiality of business information related to Walmart and its partners, and the personal information of associates and customers. Don’t reveal anything that is not public. Ultimately, you’re responsible for what you post.

Integrity can be described as making your beliefs and your actions line up.
John C. Maxwell, author and leadership expert

Personal information must also be securely managed. If you suspect there may be a breach of customer, member, or associate personal information, notify a member of management, your in-country Ethics Office, or the Global Ethics Office. Specific departments within our company may have special privacy rules or procedures. Read, understand, and stay current on information that applies to your specific business and job function.

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Leading with integrity in our communities

Q&A
We have a representative from the government here to inspect our food products. What should I do? Contact your manager immediately. My team is interested in purchasing products from a government-owned business. What should I do? Contact your in-country Legal Department or the Global Ethics Office for opinions and instructions. I would like to sit on the Education Board for my city. Am I allowed to do this as a manager at Walmart? Yes. Make sure your position with Walmart, and any influence related to it, is kept separate from your newly appointed position on the Education Board. I believe one of our imported items was incorrectly classified on the paperwork. What should I do? Contact your manager and the Legal Department immediately. There are fines and additional tariffs in many countries for misclassifying import information on products. I was told one of my new suppliers appeared on some sort of government list and I shouldn’t do business with them. What should I do? Contact your Legal Department for guidance on how to proceed or correct the issue. Many governments keep a list of countries and people with which businesses may not enter into transactions.

Governmental and political activities
Governmental contracts and inquiries
We should not enter into any contract with any governmental entity involving the sale of products or services without written approval from our Legal Department, and the appropriate level of senior management. We will immediately report all inquiries from governmental entities or investigators to the appropriate level of management. All inquiries from government entities and investigators must be answered accurately and completely.

Political involvement
Participation in the political process outside of work and during non-work time is admirable. You can make lawful contributions to political activities; however, Walmart will not reimburse you for those activities unless required by law. You cannot use your job title or company affiliation in connection with political activities unless that information is required by law or allowed by company policy. Political contributions, direct or indirect, of company funds or use of company property, services, or other assets for political purposes may not be made without the prior approval of the Government Relations Department.

International trade
All countries regulate international trade transactions covering activities such as imports, exports, and financial transactions. For example, all inbound merchandise entering the commerce of a country must clear customs prior to being released and delivered to the recipient. It’s at customs where the merchandise is examined, and compliance with regulations is determined in addition to the payment of duties and taxes where applicable. It’s important to keep the following points in mind: • Make sure that a thorough check of all regulatory requirements has been done before attempting to import and export merchandise. Regulatory requirements apply to both the merchandise and the documentation.

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Try not to become a man of success but rather try to become a man of value.
Albert Einstein, theoretical physicist

• Documentation must be complete and accurate, including description, prices, and the parties to the transaction. • Internal controls must be established to ensure compliance with all regulatory requirements, including any recordkeeping obligations. Some governments may administer a variety of trade restrictions, such as embargoes and sanctions, against a number of countries, including nationals of those countries. Transactions with certain designated individuals and organizations, such as terrorist organizations, narcotics traffickers and weapons proliferators, are also prohibited even though those individuals or organizations may not be associated with any particular country’s embargo. Severe civil and/or criminal penalties may be levied against companies or individuals that violate export controls. Always consult the Legal Department prior to entering into international trade negotiations or transactions.

Q&A
We’re discussing a joint venture with a local partner who will help us open new markets in a country. The partner is proposing special invoicing and shipping arrangements that he says will save taxes for both of us. I’m not familiar with this technique. How should we approach this? Do not enter into a contract where you don’t understand all terms and conditions. Make sure your Legal Department reviews and approves all terms and conditions of the arrangement before you proceed. I think my new store will be opening on a certain date. Can I call the local media to tell them about the Grand Opening and the activities involved? You should contact the Corporate Affairs Department prior to contacting the media. They will direct you with official information and suggested statements to share with your community.

Media statements
To ensure the accuracy of information that we provide to the public, don’t make any statement (written or verbal) on behalf of Walmart to media, news publications, trade publications, or any other source without prior approval from the in-country or global Corporate Affairs Department (and, concerning statements about financial matters, the Finance Department).

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Final disclaimer
This Statement of Ethics provides an introduction to the responsibilities of all associates, along with an overview of certain important policies. It is an important part of your employment with Walmart. But, it’s not intended to create an express or implied contract of employment in and of itself. The policies of Walmart may be modified at our sole discretion, without notice, at any time consistent with applicable law. Employment with Walmart is on an at-will basis, where permitted by law, meaning associates are free to resign at any time for any or for no reason and Walmart may terminate an associate at any time for any or for no reason. Violations of this Statement of Ethics may result in disciplinary action up to and including termination.

Global Ethics Helpline contact information
International access numbers may change. Refer to walmartethics.com for the most updated access numbers by country if you experience difficulties.

Country
Argentina Bahrain Bangladesh Brazil

Access code
Access code is not necessary 800-000-01 157-0011

Contact phone number
0800-666-1693 800-613-9668 800-613-3713 0800-891-4093 800-613-3859 800-963-8442 1-800-805-9121 1230-020-0130 10-800-711-0571 10-800-110-0549 01-800-912-0095 0-800-011-0932 1-888-719-1292 800-451-5596 800-613-3723 800-6192

Access code is not necessary 1-800-881-001

Cambodia Canada Canada-French Chile

Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary 1-999-119 or 1-800-225-528

China-Telecom China-Chinacom Colombia Costa Rica

Dominican Republic Ecuador Egypt

510-0200 (Cairo) 02-510-0200 (not Cairo) Access code is not necessary

El Salvador

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Country
Guatemala Honduras Hong Kong India

Access code
999-9190 or 138-126 800-0-123

Contact phone number
800-613-3715 800-613-3720 800-90-0620 800-613-3704 001-803-009-7987 800-78-7538 00531-11-5053 800-613-3728 704-973-0299 (collect call) 1-800-80-0011 001-888-280-0603 800-613-3721 0800-028-7246 800-613-3719 0800-52-346 1-800-1-111-0073 800-963-8442 800-110-1517 0800-891-4093 00798-1-1-009-4782 900-99-1041 800-613-3727 00801-10-4058 001-800-11-009-4987 001-704-973-0379 (collect call) 800-613-3754 0800-028-7246 800-963-8442 800-963-8442 800-613-9679

Access code is not necessary 000-117

Indonesia Italy Japan Jordan Kenya

Access code is not necessary Access code is not necessary Access code is not necessary 1-880-000

Access code is not necessary Access code is not necessary Access code is not necessary 1-800-0174

Malaysia Mexico Nicaragua Northern Ireland Pakistan Peru

Access code is not necessary 00-800-01001

Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary Access code is not necessary 02-430-430

Philippines Puerto Rico Singapore South Africa South Korea Spain

Sri Lanka Taiwan Thailand Turkey

Access code is not necessary Access code is not necessary Access code is not necessary 0-800-121

United Arab Emirates United Kingdom U.S.A.

Access code is not necessary Access code is not necessary Access code is not necessary 120-10-288

U.S.A.-Spanish Vietnam

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Ethics Committee contact information
Country
Argentina Brazil

Contact phone number
0800 8880124 0800 703 39 66 1-800-963-8442

Contact e-mail
Eticawm@wal-mart.com Etica@wal-mart.com Ethics @wal-mart.com

Canada China

86-755-21512899 800-963-8422 800-2-9638422 1-801-81-38422 800-22-38422 0120-210-737 5255 5283-0148 1-800-963-8422 1-800-963-8442 0777-970-0137 1-800-963-8442 Ethics@wal-mart.com etica@latam.wal-mart.com etica@latam.wal-mart.com etica@latam.wal-mart.com etica@latam.wal-mart.com hotlaine@seiyu.co.jp cumplir@wal-mart.com etica@latam.wal-mart.com PR Ethics@wal-mart.com

Costa Rica El Salvador Guatemala Honduras Japan

Mexico Nicaragua Puerto Rico United Kingdom U.S.A.

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Index
Accounting or Audit Issues. Accurate Bookkeeping. Alcohol & Drug Abuse. Anti-Corruption. Anonymous Reporting. Antitrust. Associate Responsibilities. Authority to Work. Boycotts. Bribery. Commercial Bribery. Competitive Information. Confidential Information. Conflict of Interest. Contact Information. Copyrights. See Financial Integrity See Financial Integrity 10 22 9 19 6 24 21 22 Illegal Activities. 22 19 26 14 32 See Protecting Private & Business Information Discrimination. Discipline for Violations. Drug Use. Entertainment. Environmental Responsibilities. Equal Employment Opportunity. Export Control. External Communications. Facilitation Payments. Fair Competition. Fair Treatment. Family. Financial Integrity. Fraud. Friends. 12 7 10 16 25 12 28 See Media Statements 22 19 5 17 20 19 17 Management’s Responsibility. Meals, accepting/offering. Media Statements. Money Laundering. Offering Gifts & Entertainment. Online Privacy. Opinions. Outside Employment. 7 See Gifts & Entertainment 29 23 16 27 8 15 Lobbying. Local Laws. See Political Activities 4 Immigration. Importing Laws. Inappropriate Conduct. Inside Information. Insider Trading. Intentional Dishonesty. International Trade. Investigations. Investments in Competitors or Suppliers. 5 24 See International Trade 11 19 20 19 28 7 14 Harassment. Health. Helpline. 11 25 9 Government Officials. Gratuities. Gifts. Government Contracts & Inquiries. Government Customers. 16 28 See Government Contracts & Inquiries 22 16

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Section header here

Index
Payment for Work. Personal Use of Company Resources. Political Activities. Privacy. Proprietary Information. Questions about the Statement of Ethics. Raising Concerns. Reporting Violations. Restrictive Trade Practices. Retaliation. 13 18 28 26 26 Trade Secrets. 9 Violence. 9 9 21 12 Wage & Hour Laws. Waivers. 13 8 11 26 Safety. Sexual Harassment. Suppliers. Suspicious Transactions. 25 11 6 23

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“Personal and moral integrity is one of our basic fundamentals and it has to start with each of us.”
- Sam Walton
Revised September 2008