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Ethics and Complaince

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Identify processes that wal-mart uses to comply with SEC regulations-Kunika.
The Securities and Exchange Commission (SEC) will not allow Wal-Mart to exclude from consideration an NLPC-sponsored shareholder proposal asking for a report on the company’s lobbying priorities. The subject matter of meetings, conversations, discussions or other communications with Investment Community Members will be limited to explanations or clarifications of publicly available information concerning Wal-Mart, will not discriminate among recipients of information disclosed by Wal-Mart or its representatives based on a recipient’s prior research, opinions, recommendations, earnings estimates or conclusions relating to Wal-Mart. In addition, Wal-Mart will not restrict, deny or threaten to deny information or access to Wal-Mart representatives in an attempt to influence the research, recommendations or actions of any Investment Community Members. Wal-Mart will not review and provide comments on any securities analyst’s or research organization’s report on Wal-Mart or any other company before the report or rating analysis is published. Wal-Mart may review and provide comments (written or oral) to factual information that Investment Community Members provide Wal-Mart to confirm for factual accuracy of information regarding Wal-Mart. They will not hire or otherwise engage any securities analyst or research organization to produce any public research reports concerning Wal-Mart or compensate any Investment Community Member in any manner for producing any such report. Wal-Mart will not adopt any particular report regarding Wal-Mart prepared by any Investment Community Member. Wal-Mart typically will not confirm or deny rumors or market speculation concerning Wal-Mart so long as it is clear that Wal-Mart is not the source of the rumor or market speculation. No attempts in regards to Communications with Investment Community Members should be made to respond to these inquiries except through an Authorized Spokesperson. Authorized Spokespersons must adhere to approved language and not make any unauthorized disclosure of material nonpublic information about the Company. Any planned disclosure of material nonpublic information must be made only at such time and in such manner as to allow for simultaneous public disclosure in accordance with Regulation FD. If Wal-Mart or any “person acting on behalf of Wal-Mart” (as defined in Regulation FD) inadvertently discloses any material nonpublic information to any Investment Community Member, such disclosure must be immediately reported to the Legal Department so that appropriate action may be taken to comply with Regulation FD. Wal-Mart will publish all of its sales releases, earnings releases, earnings scripts, financial webcasts and presentations to Investment Community Members on its web site and will archive such documents on Wal-Mart web site for at least one year. The Annual Meeting for the Investment Community, all or a portion of which will be made available via a live webcast. Wal-Mart will furnish to the SEC and will make each quarterly earnings press release prior to conducting any telephone calls or other communications with the Investment Community to discuss Wal-Mart sales, earnings or other matters disclosed in those press releases. Any Additional Communication will be widely available to the Investment Community through press release, telephonic means, webcast, SEC filing or any combination of the these media. Wal-Mart will publish on its website (http://www.walmartstores.com/) the dates of its quarterly press releases and pre-recorded, listen-only conference calls to discuss quarterly sales and earnings and information about how shareholders and other interested persons can obtain access to those releases and communications. A widely circulated wire service will be used to make all of its press releases relating to matters of concern to the Investment Community. Wal-Mart will publish in advance the dates and information about accessing any of the communications and meetings described above as soon as practicable after that information becomes available to Wal-Mart. Where practicable, Wal-Mart intends to release all press releases and make all telephone calls available prior to the start of trading on the New York Stock Exchange on the dates and in the manner described above.

Reference:
WAL-MART STORES, INC. (NYSE: WMT)
http://media.corporate-ir.net/media_files/IROL/11/112761/Final%20Investment_Community_Communications_Policy_July%202012.pdf.

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