Financial Interests
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Conflict of Interest

We should avoid financial conflicts of interests and make business decisions based on objective criteria. A financial conflict of interest can arise when your business judgment could be influenced or might appear as being influenced by the possibility of personal financial gain. That’s why direct ownership of stock ina competitor with a market value in excess of $50,000 or any direct financial investment in a supplier to Walmart over whom you have direct or indirect influence should be disclosed in writing to Global Ethics.

Financial Interests

Someone told me I cannot own stock in a supplier. Is this correct?

Maybe. The restriction is that you may not have any direct financial interest in a supplier whose business you have direct or indirect influence over in your position at Walmart. There are no restrictions against financial interests in suppliers whose business you do not influence.

I recently joined Walmart and I own more than $50,000 of stock in a competitor. Should I sell the stock?

As a Walmart associate, you have a responsibility to make sure your personal financial activities do not conflict with your responsibilities at work. A conflict would exist if you have a substantial financial investment in a competitor. If you own more than $50,000 of stock in a competitor, or more than 1% of your net worth, you should disclose your stock ownership information to your manager and Global Ethics. Global Ethics will review your situation and offer you further direction on how to handle your stock ownership.

I have more than $50,000 invested in a mutual fund that includes other retailers in its portfolio. Do I need to disclose this investment?

A financial conflict of interest can arise when your judgment could be influenced, or might appear as being influenced, by the possibility of personal financial gain. When you are invested in a mutual fund, you don’t have direct control over the fund’s investment strategy; therefore, in this instance, non-disclosure is required.

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Explore our Statement of Ethics
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