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.
Integrity in Action
Do not offer or accept bribes. Laws in some countries make a distinction between bribing a government official and bribing a non-government official. We don’t rely on those distinctions. For us, it is simple, bribery—of anyone, at any organization, at any level—is wrong.
Third parties must not pay bribes. Any person or company working on Walmart’s behalf may not offer, give, or receive a bribe. If the only way to make a deal or complete a service for Walmart is through payment of a bribe, we expect third party service providers to refuse and to report it. Bribes are not how we do business.
Engage Anti-Corruption Compliance. Get approval from Anti-Corruption Compliance and Legal before entering into any agreement with a government or engaging a third party intermediary.
Follow anti-corruption laws and our policy. Walmart is committed to following all applicable laws regarding the prevention of bribery and corruption. Know and follow your local Anti-Corruption Compliance Procedures and controls. Follow the Giving Procedures with respect to in-kind and monetary donations.
Immediately report allegations of bribery or attempted bribery directly to Global Ethics & Compliance.
A bribe is 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.
Bribes are not limited to cash. A bribe can be gifts, travel, meals, entertainment, offers of employment, and charitable or political contributions.
Bribery Red Flags
Excessive commission payments
Vague consulting agreements without deliverables
Offers or requests for lavish entertainment or luxury gifts
A third party intermediary is anyone acting on Walmart’s behalf, directly or indirectly, with a government official or government entity. These third parties are subject to Walmart’s strict due diligence, contracting, and monitoring requirements.
Police officers have stopped trucks leaving our distribution center and said they would delay deliveries unless the driver pays the police $50. My manager said we should carry $50 gift cards to pay the officers. Is this allowed?
No. We do not allow any improper payments to influence government officials, including police officers. This rule applies to both cash payments and other items of value, such as gift cards. Report this immediately to Global Ethics & Compliance.
Our next store scheduled to open is pending the operating license. To expedite the process a government official requested we hire a company that will “take care of it.” Is this allowed?
No. We do not hire specific third parties at the request of the government. We do not allow any improper payment or action to influence a government official’s decisions. This rule also applies to any company acting on our behalf. Report this immediately to Global Ethics & Compliance.