Conflict of Interest

At Walmart, we’re dedicated to serving our customers. Serving our customers means upholding our Every Day Low Cost business philosophy and remaining impartial in our business relationships. Associates should not accept gifts or entertainment from their suppliers or potential suppliers because it adds unnecessary costs in our supply chain and could impact an associate’s objectivity.

Gifts & Entertainment

Our market electronics team is attending a training session hosted by a supplier to learn about a new item the supplier is launching. The supplier said we will each get a free t-shirt for attending the training. Can we accept the t-shirts?

Because the t-shirts are coming from the supplier and are not related to the product or gaining an understanding of the product, the team should not accept the t-shirts. Politely decline the t-shirts and explain our standard on gifts and entertainment to the supplier. 

I work in Financial Services, and I received a birthday gift from a close personal friend who happens to be employed by a Walmart toy supplier. Can I accept the gift?

In your role, you have no direct or indirect influence over the business relationship with the supplier, so it would not be a violation to accept the gift from your friend.

In my market, it is a cultural custom for suppliers to offer beverages, such as coffee, tea or soft drinks, and other small snacks during business meetings at their facilities. Can I accept these refreshments?

You may accept customary refreshments such as a coffee, soft drink or small snack. However, you should not accept food and beverages that would be considered a meal.

A supplier I work with has offered me two tickets to the World Cup if I pay face value for them. Can I buy the tickets?

No. Although you may be paying face value for the tickets, it may not reflect the market value of the item. Some areas allow you to resell tickets, and you might be able to make a profit if you sold them. Also, this can be considered a gift of prestige, as having the opportunity to attend a coveted event such as the World Cup is not readily available to everyone.

I have a friend who works for a Walmart supplier. I do not have a business relationship with this supplier, and he wants to give me a Christmas present. Should I accept this gift?

Many associates have friends and neighbors who are suppliers to Walmart with whom they have no business relationship. In these situations, exchanging small customary gifts with friends and neighbors for Christmas, birthdays, baby showers, etc. does not create an appearance of impropriety or conflict with our values of objectivity and Every Day Low Cost (EDLC). Common sense should apply in these instances.

Use good judgment and ask yourself the following questions:

  • Am I being offered the gift because I work for Walmart?
  • Could accepting the gift create an appearance of impropriety?

If the answer to either of these questions is yes or maybe, then you should decline the gift.

One of my suppliers has offered to give me two tickets to an upcoming sporting event. Should I accept the tickets? Should I offer to buy the tickets?

To ensure that you treat all of your suppliers fairly and make objective business decisions, you should not accept free tickets or purchase tickets from your suppliers.

Accepting free tickets from your supplier would be considered a gift. If you buy the tickets at face value, you may not be paying the actual fair market value of the tickets. The difference in the face value and the fair market value would also be considered a gift.

Even if you paid fair market value for the tickets, you have access to the tickets because of your business relationship with your supplier; therefore, it would not be acceptable to buy the tickets from your supplier.

I serve on a supplier advisory board and will be attending an advisory board event. Should I cover the cost of attending the event?

When attending an advisory board event, you should pay for all costs associated with attending the event. Accepting an offer to cover the cost of an event from a supplier over whom you have influence would be deemed a gift.

Objectivity and favoritism concerns can arise when you decline to participate in certain advisory boards and/or expand business with a supplier on which advisory board you participate. To avoid the perception of favoritism, the decision to participate in any advisory board must be approved by your Executive Council member.

Want to know more?
Explore our Statement of Ethics