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Our AspirationWalmart strives to make trust a competitive advantage.
Integrity builds trust in our business, and modeling the highest standards of ethics and compliance helps us create and maintain a culture of integrity. Relevance to Our Business & SocietyEthics and compliance are essential components of sustainable business success and growth. Businesses that set high standards, ground their decision-making in foundational values, swiftly address shortcomings and act transparently not only mitigate risk—they make better business decisions and cultivate trust. Ethics and compliance are integral to a well-functioning society and the economy, as unethical business practices add to the total cost of doing business, reduce GDP, distort markets and contribute to an erosion of trust in institutions. We believe that trust is one of Walmart’s competitive advantage: associates, customers, investors, suppliers and business partners will choose Walmart because they know we are a business they
can trust. With more than 10,500 stores worldwide and tens of thousands of suppliers, our actions can have a positive impact and influence far beyond the walls of our stores, clubs and offices. Walmart’s ApproachAt every level of our company, we work to create a culture that inspires trust among our associates, with our customers, and in the communities we serve. We do this by:
Key Strategies & ProgressSetting Ethics & Compliance Program Foundations | Building
Trust with Our Associates & Customers | Building Trust in Our Business Setting Ethics & Compliance Program FoundationsWalmart’s core values are at the center of everything we do. Our Code of Conduct helps us make decisions that promote those values by describing the behaviors we expect of each other and reinforcing that we are committed to complying with laws and regulations in all locations where we operate. Our Values:
While fostering and maintaining our culture of integrity is every associate’s job, we have over 1,000 Ethics & Compliance and other Global Governance associates around the world who are dedicated to:
Ethics and Compliance Program FoundationsWe design our ethics and compliance programs around foundational
principles that help keep us consistent and responsive as our business and the external environment change:
These foundational principles are designed to align our programs with the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs framework and Organisation for Economic Co-operation and Development (OECD) Good Practice Guidance. Governance Programs Walmart’s governance programs are designed with specific risk areas in mind, which reflect the complexity of our global business and dedication to doing business the right way. Some of these risk areas are:
Leadership & Tone from the TopWe expect our leaders to model Walmart’s culture of integrity and values with their daily actions and to regularly communicate their commitment through various channels, both internally and externally. Compliance is the responsibility of everyone in the company. Many different parts of the company play a part in supporting Walmart’s compliance with laws and regulations. Walmart's global governance organization has more than 1,000 associates, including subject matter experts, investigators, compliance and risk assessment professionals, legal counsel, security specialists and data analysts, among others, dedicated to supporting Walmart’s ethics and compliance efforts. Governance leaders in each market are charged with designing and executing the compliance program consistent with our program foundations and ensuring the overall program is operating efficiently and effectively. The Global Chief Ethics and Compliance Officer, as well as other global governance leaders, makes regular reports on ethics and compliance matters to the Audit Committee of Walmart’s Board of Directors. The Audit Committee plays a
critical and active role in overseeing the company’s ethics and compliance program. Risk and Ethics & Compliance CommitteesWe have a governance risk committee comprising members of management at the global level. In addition, we have an ethics and compliance committee in each of our international retail markets. These committees meet regularly to discuss issues related to ethics, compliance and other enterprise-level risks, with meetings
structured to lead to follow-up and accountability for action items. Integrity Index surveyAs part of Walmart’s Associate Engagement Survey (AES), we ask questions related to integrity to establish an integrity score. The Integrity Index score helps us better understand the strength of our culture of integrity, while identifying opportunities to provide additional guidance and leadership. For 2021, the Integrity Index measured the
favorability of associate responses in six areas:
Each manager with at least five direct reports responding to the Survey receives an Integrity Index score. Market-level Integrity Index scores are reviewed by the market Chief Ethics and Compliance Officer and relevant business leadership. As needed, they work to develop action plans to address areas for improvement. Standards & ControlsWe periodically review the
guidance we have published to help our associates make the right decisions. For example, in 2021 Walmart launched a new Code of Conduct that focuses on acting with integrity to build trust in each other and with our customers, members and stakeholders. We also launched 20 new and updated global ethics and compliance policies in 2020-2021 that reflect our commitment to doing business the right way, defining target audiences, and informing associates of expected behaviors (including speaking up
when something is not right). Training & AwarenessEducating associates on expectations and keeping ethics, compliance and integrity top-of-mind through tailored, effective training are essential to maintaining a culture of integrity. Walmart conducts regular ethics and compliance training for all levels of the company, from frontline store associates to the board of directors, and we continually seek to improve our method and approach to training to help ensure our associates have the right information at the right time and in the right way. Training is supplemented by ongoing communication campaigns to keep the concepts top-of-mind. Example Ethics & Compliance training and awareness activities include:
Monitoring & ResponseWalmart monitors adherence to laws, regulations, standards, controls and initiatives throughout our business. In addition to tracking key metrics, we have continuous improvement teams regularly visit and actively monitor facilities to determine the facility’s adherence to protocols. And program design, execution and effectiveness are tested and refined
through our internal audit processes and reviews by external experts. Walmart's Code of Conduct and Reporting ChannelsWalmart’s Code of Conduct encourages associates, suppliers, customers and community members to raise issues, ask questions and report concerns. Speaking up is a requirement for Walmart associates, and we support associates in doing so by stating that reporting an issue in good faith will not get the associate in trouble, even if the associate makes an honest mistake. Walmart’s Code of Conduct and program policies also make clear that Walmart does not tolerate retaliation for reporting a concern or participating in an investigation. Channels available for reporting concerns include:
Reports to Ethics are triaged by subject matter, risk presented to the company and severity of the allegation. Actionable cases may be referred to business units for follow-up or investigated by one of our investigative teams. Violations of our Code of Conduct and ethics and compliance program policies can lead to discipline up to and including termination. Other remedial action 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. Building Trust with Our Associates & CustomersBuilding trust with our associates is foundational to creating the culture of ethics, compliance and integrity that we need to win with our customers and other stakeholders. Respecting One Another by Not Tolerating Harassment or DiscriminationWe 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 Harassment & Discrimination Prevention Policy.
Walmart takes a global approach to discrimination and harassment prevention and process enhancements. 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, 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. We do not require U.S. employees to take sexual harassment claims to private arbitration. Because of the special and sensitive nature of these cases, we have also launched enhanced training
for investigators on how to investigate sexual harassment and sexual assault allegations. Creating a Safe Place to Work & ShopThe health and safety of our associates and customers is not just a business need—it’s a societal imperative. Walmart employs over 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. 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 & 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 based on their roles, including, but not limited to:
We also contract with an independent third-party to conduct risk-based assessments of our U.S. stores and clubs to monitor execution of specific elements of our EHS program. A total of 33,234 visits were conducted in 2021.
Selling Safe Food & ProductsHundreds of millions of customers depend on Walmart for safe, quality food and products. We have programs designed to deliver end-to-end food and product safety, including through hazard detection, facility procedures, monitoring and recalls and withdrawals. In addition to our normal processes and practices, during the COVID-19 pandemic we took special measures to keep our customers safe. Read More: Providing Safer, Healthier Food and Other Products. Building Trust in Our BusinessCompeting FairlyWalmart is committed to free and fair competition as this helps enable lower prices, maximize consumer choices and promote innovation. Walmart’s core mission—to provide everyday low prices so that customers can save money and live better—is well aligned with the spirit of competition laws. Our Global Antitrust and Competition Law Policy applies across all of Walmart’s businesses globally. The Policy requires (among other things) that Walmart (1) compete independently; (2) protect competitively sensitive information; and (3) deal with suppliers and other parties in a manner that does not harm competition or consumers. Walmart has an Antitrust Center of Expertise (“COE”) responsible for advising the company with respect to antitrust matters and for the development and maintenance of a Global Antitrust Compliance Program. The Program is led by a team of global and jurisdiction-specific specialists who design robust training, controls and monitoring to meet and properly mitigate relevant risks. The COE works in
close partnership with teams across the company, including merchandising, pricing, sourcing, sustainability, HR and others to verify that compliance controls are embedded throughout the company. The COE also partners with the ethics team, investigations team and our global audit team to help make sure the compliance program is continually informed by relevant reporting and any business concerns. Combating Bribery & CorruptionWalmart’s stance on bribery and corruption is firm: we compete fairly and honestly everywhere we do business around the world; we never attempt to gain a business advantage through bribery; and we do not tolerate bribery or corruption in any form. Our Code of Conduct and Global Anti-Corruption Policy prohibit bribery in any form: receiving, offering to pay, paying, promising to pay or authorizing the payment of money or anything of value to improperly influence any act or decision or to secure any other improper advantage in order to obtain or retain business is prohibited. The Policy applies to our associates and to TPIs acting on Walmart’s behalf; our Standards for Suppliers require the same of Walmart’s product suppliers. Our Anti-Corruption compliance program is designed to effectively manage our bribery and corruption risks and incorporates regulators’ guidelines and internationally recognized best practices to establish effective anti-corruption internal controls and monitoring. We
invest in people, processes and systems to not only prevent and detect corruption risks, but to assure the program continuously improves to be proactive, risk-based, efficient, effective and sustainable. Walmart has dedicated significant resources to enhance our Anti-Corruption program, including:
Our anti-corruption training program gives life to our Global Anti-Corruption Policy and procedures in our business operations. Walmart trains associates globally to recognize the various forms of bribery, to know and understand Walmart’s policies and procedures, how to properly conduct governmental interactions and how to make international donations. In FY2022, more than 77,400 associates received this training. We also provided anti-corruption training to more than 1,500 of the TPIs acting on our behalf. Using Data & Technology Respectfully & EthicallyWhen our customers, associates and business partners share data and information with us, we understand the importance of keeping it safe and using it—and technology—ethically in ways they expect. We will earn and maintain the trust people have in us by respectfully using technology, respecting individuals’ privacy and protecting their data. Walmart has developed Digital Trust
Commitments aligned with our core values that serve as a foundation for how Walmart will continue to earn and maintain customer trust in an omni-channel, data- and technology-driven world:
In addition to communicating what Walmart stands for, these Digital Trust Commitments serve as guiding principles for product and development teams so they can infuse Walmart’s values into the digital architecture and infrastructure of our operations. Read More: Digital Citizenship: Ethical Use of Data & Responsible Use of Technology. Sourcing ResponsiblyWalmart’s supply chain reaches over 100,000 suppliers globally. Through our Responsible Sourcing program, we establish our expectation that suppliers and their facilities operate responsibly and in a way that protects worker dignity. Our expectations are stated in our Standards for Suppliers, we use a risk-based approach to monitoring our supply chain and we use insights to make purchasing decisions that support our responsible sourcing objectives. Read more: People in Supply Chains. Challenges
About Our Reporting 1. In FY2021 we reported that more than 290,000 associates were trained in at least one food safety course. In FY2022 we reported that more than 980,000 associates globally were trained in at least one food safety course. The FY2022 number is higher due to but not limited to the following changes: FY2022 we offered more food safety training courses; training was disproportionately impacted in FY2021 by the COVID-19 pandemic; FY2022 includes all associates where FY2021 was U.S. based associates only; and in FY2022 we included the count of associates trained who left the company after completing the training. What is the difference between complianceA values orientation uses legal terms, statutes, and contracts that teach employees the rules and penalties for noncompliance. e. Unlike values-based programs, compliance-based programs cannot prevent misconduct. a 20. Which of the following is a common mistake made in implementing an ethics program? a. Setting specific program objectives b.
Which is more comprehensive a code of ethics or code of conduct?A code of ethics is more comprehensive than a code of conduct. Which of the following is an advantage of a values-based ethics program over a compliance-based one? Employees learn to make decisions based on values such as fairness, compassion, respect, and transparency.
What are the benefits of valuesValues-based programs increase employees' awareness of ethics at work, integrity, willingness to deliver information to supervisors, use of reporting mechanisms, and perception that ethical decisions are being made.
What is the difference between values orientation and compliance orientation?d. A values orientation uses legal terms, statutes, and contracts that teach employees the rules and penalties for noncompliance. e. Unlike values-based programs, compliance-based programs cannot prevent misconduct. a. Employees learn to make decisions based on values such as fairness, compassion, respect, and transparency.
Which of the following is true about a compliance orientation quizlet?Which of the following is true about a compliance orientation? A compliance orientation can aid in organizational ethical decision-making.
What is the primary focus of complianceAs explained by Paine (1994), compliance-based ethics programs focus on educating employees on complying with existing laws and regulations, and the use of appropriate procedures to disclose violations of federal laws.
What are the advantages of adherence to ethical guidelines?A strong ethical standard in the workplace helps to create strong working relationships between the staff and management. It reduces employee turnover, improves morale and has a positive effect on productivity.
Which of the following is one of the main reasons employees do not report observed misconduct?One of the main reasons employees do not report observed misconduct is fear of retaliation. Employees who witness illegal or unethical behavior in the workplace believe there are risks that hinder them from taking action.
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