Common Questions
Conflict of Interest

Common Questions

One of our suppliers would like to make a donation on behalf of Walmart to a local charity. Is that acceptable?

To protect our fair and objective relationship with suppliers, we do not approve of donations made on our behalf nor should we use our position at Walmart to influence where our suppliers make contributions.

Walmart and one of my suppliers have co-sponsored an organization. They've asked me to present the check. Can I present the check?

As long as Walmart also donated to the charity, then you may be the appropriate person to present the check. When handing the check over to the charity, you would need to be clear in communicating that the check is on behalf of both Walmart and the supplier.

I recently became an independent sales agent for a mail order cosmetics company. Can I encourage my co-workers to purchase their cosmetics through my new business?

Associates should avoid actively and personally promoting a side business at work or soliciting coworkers for new business. This includes trying to sell products or services to co-workers during daily work conversations. Promoting a personal business could be considered a conflict of interest because the associate may be using his or her position for personal gain.

When visiting my supplier, can the supplier provide transportation for me?

In some instances, it may be more cost effective and sustainable for associates to ride with a supplier while conducting business. If it’s necessary to travel with the supplier, you should pay your portion of the travel expenses (e.g. half the taxi fee, half the cost of gas, etc.). If these situations arise, be transparent and let your manager know. You should also avoid extravagance. Even if you pay for half the cost, it is not in line with our value of Every Day Low Costs to be escorted in limousines or similar luxury accommodations.

A former Walmart associate left Walmart less than six months ago and now works for my supplier. Am I allowed to work with the former associate as a supplier to Walmart?

A conflict may exist if, within a year of leaving Walmart, the former associate is calling back on an area he or she formerly worked in or had influence over while at Walmart. For example, a Sam’s Club toy merchandising team member would not be allowed to do business with a former Sam’s Club toy merchandising associate for a period of one year. If the former associate is calling back on an area they have not worked in or had influence over the restriction does not apply. Note: Walmart will not do business with a former officer for one year regardless of the area they worked in or had influence over while at Walmart. Global Ethics may, in partnership with senior business leadership, determine a different time period is reasonably warranted under the circumstances.

I was recently asked to participate in a supplier advisory board on behalf of Walmart. Would it be a conflict to participate?

When participating in supplier advisory boards on behalf of Walmart, be mindful of potential conflicts of interest, your obligation to avoid sharing private and confidential business information, and potential antitrust issues that can arise when you are together with competitors. To avoid the perception of favoritism, the decision to participate in any advisory board must be approved by your Executive Council member.

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