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Never Engage in Bribery

 

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.  Additionally, any person or company working on Walmart’s behalf may not offer, give, or receive a bribe.

 

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. 

 

Immediately report allegations of bribery or attempted bribery directly to Ethics & Compliance.

Police officers have stopped trucks leaving our distribution center and said they would delay deliveries unless the driver pays the police $50 (USD). My manager said we should carry $50 gift cards to pay the officers. Is this allowed?

No. We do not allow 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 Ethics & Compliance. 

A store is seeking a permit from a local government agency. During the holiday season, the store manager suggests sending a $300 (USD) gift card to the head of the agency. Is this acceptable?

No. Such gifts are prohibited.  We do not provide gifts to influence the actions of government officials.  Providing gift cards, membership cards, and/or cash to government officials is prohibited.  Certain customary gifts, such as holiday cards or other items of low to no monetary value may be given in some circumstances, but they can never be given for the purpose of influencing a government official.  Contact your Anti-Corruption or Ethics team if you need additional guidance.

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.

We have a representative from the government here to inspect our food products. What should I do?

Remain calm. Follow your market’s regulatory contact and notification process. Typically, a member of management will be able to assist the government official. Remember if a regulator requests a bribe (e.g. cash, goods or services) you must decline to provide it and immediately report the matter to Ethics & Compliance.

My team is interested in purchasing products from a government-owned business. What should I do?

Contact your Anti-Corruption Compliance Team or Ethics & Compliance before taking any action or making any commitment on behalf of Walmart.