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Recognize and Avoid Conflicts of Interest

Fair and objective decisions build trust with our associates, customers, and third parties. When making business decisions, we put Walmart’s interests before personal interests. A conflict of interest occurs when personal interests interfere with, or may appear to interfere with, our work at Walmart. While we can’t list every circumstance, it’s important to know and avoid the common situations that could create a conflict or the perception of a conflict. Outside employment, financial investments, gifts and entertainment, and personal relationships are areas where conflicts can arise.

 

If you realize an activity or situation could influence or appear to influence your ability to make objective business decisions, let your manager, People Lead, or Ethics & Compliance know. They can help you take steps to avoid or resolve a conflict.

Outside Employment and Business Interests

  • Do not work for a competitor while you are a management associate or a salaried associate. Hourly associates should discuss with their managers to determine if a conflict exists before accepting employment with a competitor.
  • Do not use your Walmart role to promote your side business. Your side business cannot interfere with your work at Walmart or use Walmart resources, including your associate discount card. It cannot supply products to Walmart, supply products to any current or potential Walmart supplier with whom you have a business relationship or influence, compete with Walmart, or reflect negatively on Walmart.
  • While working for Walmart, you may identify a business or investment opportunity that Walmart may have an interest in pursuing. Do not take opportunities for yourself that you discover through your position or the use of Walmart property or information.
Think about it

Ask these questions when you’re unsure about whether a situation may lead to a conflict or the perception of a conflict:

 

1. Could this influence my objectivity or judgment in decisions?

2. Could this appear to others to be a conflict?

 

If the answer is “yes” to either of these questions, or if you aren’t sure of the answer, reach out to your manager, People Lead, or Ethics & Compliance for advice.

Financial Investments

  • Do not invest in a Walmart supplier if you can influence Walmart’s relationship with that supplier.
  • Do not have a substantial interest (for example, stock ownership) in a competitor. Consult the Global Conflicts of Interest Policy for specific restrictions.

 

Gifts and Entertainment

  • Decline gifts and entertainment from a supplier if you work with or could work with that supplier in your Walmart role. Accepting any benefit from suppliers that we work with can cause a conflict and drive up the cost of doing business.
  • Explain our policy on gifts and entertainment to new suppliers. Customs may differ in the countries where we work, but our policy on gifts and entertainment applies everywhere we do business.
  • Decline gifts and entertainment from any government official. 
  • We often sample or test merchandise to help us better understand a product or business we may want to purchase. This is not a conflict so long as we reasonably limit sampling. Follow your local policy regarding sampling and testing products.

Associate Relationships

Family

 

Do not supervise or be directly involved in the hiring of a family member. Do not influence the conditions of employment (for example, pay, work hours, or job responsibilities) or performance rating of any family member. In certain rare circumstances, the company allows family members to work in the same reporting chain if there is enough separation. It is unlikely in a store, club, or distribution center that there would be enough levels of separation. If you learn that a family member is being considered for employment or is hired into your reporting chain, you should disclose this to your manager, People Lead, or Ethics & Compliance.

 

  • A family member is any relative (spouse, child, parent, sibling, grandparent, or grandchild) by birth, adoption, marriage, domestic partnership, or civil union as well as any member of your immediate household, regardless of whether you are related.

 

Romantic

 

Do not have a romantic relationship with another associate if the associate is in your chain of command or you have influence over the associate’s conditions of employment or performance rating. If an associate with whom you already have a romantic relationship comes under your supervision due to a change in organizational structure, you should immediately disclose the relationship to your manager, People Lead, or Ethics & Compliance.

 

  • A romantic partner is someone you are dating or with whom you have a sexual relationship.
Can friendships cause a conflict of interest?

Yes, if the depth of your close personal friendship impacts your ability to make objective decisions. A close personal friendship is not simply participating in some of the same community activities. Attending the same house of worship, having children on the same sports team, or

being in the same neighborhood association would not by itself make you close personal friends. It can be difficult to determine on your own whether a close personal friendship could impact your objectivity.

 

Talk with your manager, People Lead, or Ethics & Compliance about how to best manage the business situation if a close personal friend is involved.

Supplier Relationships

 

  • If a close personal friend, family member, or romantic partner works for a supplier over which you have influence, disclose it to your manager, People Lead, or Ethics & Compliance to get advice on managing the potential conflict.
  • Before participating in the selection of a supplier which employs your family member, close personal friend, or romantic partner, disclose the relationship to your manager, People Lead, or Ethics & Compliance to get advice on how to manage the potential conflict.
What if?

I work in Financial Services, and I received a birthday gift from a friend who is also a toy supplier. Can I keep the gift?

Yes. In your job, you have no influence over Walmart’s business relationship with this supplier. If you were in a role where you have influence over Walmart’s relationship with the supplier, talk to your manager, People lead, or Ethics & Compliance to get advice on how to handle the situation.

 

I live in a neighborhood with multiple Walmart merchandise suppliers. I work in Merchandising. My neighborhood has numerous block parties where the whole street is invited. Is it a conflict for me to attend?

No, it is not a conflict for you to attend. You can participate in normal neighborhood social functions but be mindful of how others may perceive your social interactions with suppliers over which you have influence.


 Related Policies
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