As a representative of Walmart, 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 vendor of Walmart, if you have direct or indirect involvement in our business with that vendor.
• Substantial financial interest in a competitor.
• Receiving personal compensation from a vendor, if you have direct or indirect involvement with our business concerning that vendor.
• Using confidential company information for personal gain.

Ownership of stock in a competitor with a market value in excess of $20,000 must be disclosed in writing to the Global Ethics Office. The Global Ethics Office will decide whether or not a conflict, or potential conflict, exists and how it should be handled.

I’m a Vision Center regional manager. I’ve recently invested $10,000 in an investment fund that may invest some of the money in the optical industry. Would this be a violation?
Since you don’t have direct control over the investment strategy, it’s not a violation.

Someone told me I could not own stock in a vendor. Is this correct?
No. The restriction is you may not have any direct financial interest in a vendor whose business you have direct or indirect influence over within your position at Walmart. There are no restrictions to financial interests in vendors you do not have business influence over.

I recently joined Walmart and I own more than $20,000 of stock in a key competitor. Must I sell this stock?
You should disclose the information to your manager and the Global Ethics Office. The Global Ethics Office will issue you an opinion with any instructions regarding any potential conflicts of interest.