Conflict of Interest

We have a responsibility to all our stakeholders to make decisions strictly on the basis of Walmart’s interests, without regard to personal gain. A conflict of interest can arise when our judgment could be influenced, or might appear as being influenced, by the possibility of personal benefit. Even if it’s not intentional, the appearance of a conflict may be just as damaging to your reputation, and Walmart’s reputation, as an actual conflict. We should always be on the lookout for situations that may create a conflict of interest and do everything we can to avoid them.

It’s your responsibility to tell your manager about any situation you think creates, or could create, a conflict of interest. Managers are encouraged to bring such matters to the attention of Global Ethics for advice. You also may contact Global Ethics with any question you have.

Conflict of interest situations can come up in various ways. The following sections outline some of the possibilities.

Financial Investments

You have a responsibility to make sure your personal financial activities do not conflict with your responsibilities to the company. 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.

Examples of conflicting financial investments are:

  • Financial interest in a supplier of Walmart, if you have direct or indirect involvement in our business with that supplier
  • Receiving personal compensation from a supplier, if you have direct or indirect involvement in our business with that supplier
  • Using confidential company information for personal gain

Additionally, ownership of stock in a competitor with a market value in excess of U.S. $20,000 (or equivalent local currency amount) must be disclosed in writing to Global Ethics. Global Ethics will determine whether or not a conflict or a potential conflict exists and how it should be handled.

Outside Employment

Associates should avoid employment or outside interests that may create, or give the appearance of creating, a conflict of interest. For example, management associates working for a competitor is deemed to be a conflict. Hourly associates should check with their managers before accepting employment with a competitor to determine if a conflict exists. Factors for consideration include similarity of position and job responsibilities. Similarly, associates may not work for a supplier if they have any influence (either direct or indirect) over the supplier’s product or the supplier’s business with Walmart.

Associates may operate and work in a side business as long as it does not create a conflict of interest with their work at Walmart. This means the side business cannot interfere with your responsibilities as a Walmart associate, be similar in nature to your role as an associate, benefit from the use of Walmart assets, supply products to Walmart or reflect negatively on Walmart.

If you have a question about whether outside employment is a potential conflict, contact your manager or Global Ethics.

Former Employment

A conflict of interest may exist if a former associate is calling on Walmart in an area in which the associate worked or had influence while employed at Walmart. If the former associate was a Walmart officer, a conflict may exist regardless of the area in which the officer worked.

When a former associate takes a position with or on behalf of a supplier, Walmart will not do business with that associate for a period of one year following his or her separation if the former associate is dealing with a business area in which he or she worked or had business influence. Walmart will not do business with former officers for a period of one year regardless of the area in which the former officer worked. Global Ethics may, in partnership with senior business leadership, determine a different time period is reasonably warranted under the circumstances. All conflict determinations must be submitted to Global Ethics in advance for a written opinion.

Personal Relationships with Suppliers

Associates should not have social or other relationships with suppliers if the relationship would give the perception a business influence is being exerted. We believe in basing our relationships with suppliers on efficient, fair and lawful business practices. The selection of suppliers must be made on the basis of objective criteria, including integrity, quality, price, delivery, adherence to schedules, product suitability, maintenance of adequate sources of supply and Walmart’s purchasing practices and procedures. 

The selection of suppliers must be made on the basis of objective criteria.

We must treat our suppliers with respect, fairness and honesty. We must not take undue advantage of a supplier by using Walmart’s business influence. Also, we should expect our suppliers to follow all applicable legal requirements in their business practices, as well as our supplier standards.

If you believe you may be perceived as having an inappropriately close relationship with a supplier, or appear to be exerting a business influence on the supplier, inform your manager or contact Global Ethics.

Gifts & Entertainment

Accepting gifts and entertainment can cause a conflict, or the appearance of a conflict, between personal interests and professional responsibility. Walmart’s culture is to never accept gifts or entertainment from any supplier, potential supplier, government agent or other third party the associate has reason to believe may be seeking to influence business decisions or transactions. Associates also may not accept a gift or gratuity from a customer for work performed by the associate in a Walmart facility, except as required by local or national policy.

We may not accept items donated to Walmart by suppliers for the purpose of raising funds for charities or non-profit organizations. Also, we should never ask for, accept or approve of suppliers making donations on behalf of Walmart. Additionally, associates should not provide a list of our suppliers to charitable organizations for the purpose of fundraising.

Our policy on gifts and entertainment stems from our values of complete transparency and objectivity and our principle of maintaining Every Day Low Costs. Since such gifts and entertainment increase the cost of doing business, we help our suppliers give us low costs on products by not expecting the gifts and entertainment they may have to spend on other customers. We recognize, as a global company, we may encounter situations in which local practices will come into play. Global Ethics will review these situations on a case-by-case basis.

When you are establishing a new business relationship, make sure all parties are aware of our policy regarding gifts and entertainment. In some countries where gift giving is a custom or tradition, you should politely explain this policy to your customers and suppliers, especially prior to holiday gift giving periods, to establish expectations.

You always should be aware of how the act of accepting a gift or gratuity might be perceived by the public, by other suppliers or by other associates. When dealing with external businesses, you should ask yourself, “Would this business offer me this gift or gratuity if I wasn’t employed by Walmart?” If the answer is “no” or is unclear, you should not accept it.

Occasionally, there may be times when returning a gift would be impractical or embarrassing. In those rare instances, the gift should be managed in a fair and objective manner that does not benefit you personally, such as donating it to charity. You should immediately tell your manager or Global Ethics about any gift you’ve been offered or received if you feel that gift might be a violation of our policy. If you have any questions about gifts and entertainment, you should seek assistance from your manager or Global Ethics.

Personal Relationships with Other Associates

At Walmart, we want to maintain a work environment in which associates can perform effectively and achieve their full potential. We all are responsible for creating a climate of trust and respect and for promoting a productive work environment.

A conflict of interest exists when you manage someone with whom you have a family, romantic or dating relationship. A family relationship includes the following relatives by birth, adoption, marriage, domestic partnership or civil union: your spouse, children, parents, siblings, grandparents or grandchildren, as well as anyone who currently is a member of your household, whether or not you are related. It also may include other close personal relationships such as godparents. Even if you’re acting properly, your relationship will likely be seen as influencing your judgment. This can damage morale and disrupt workplace productivity. Therefore, you may not directly or indirectly supervise any family members or any associate with whom you have a close personal relationship, date or are romantically involved. This includes situations in which you may be able to influence that associate’s terms and conditions of employment or that associate may be able to influence the terms and conditions of your employment. Walmart strives to eliminate personal relationships that interfere with work performance or which may constitute harassment. You should ask for guidance from your manager or contact Global Ethics whenever an issue comes up regarding a personal relationship.

At Walmart, we want to maintain a work environment in which associates can perform effectively and achieve their full potential.
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