Leading with Integrity

  Download PDF
Skip Navigation LinksHome  ·  Integrity In The Workplace  ·  COI - Gifts And Entertainment
“Personal and moral integrity is one of our basic fundamentals and it has to start with each of us.”
Sam Walton
Download the Statement of Ethics
Gifts and Entertainment

Accepting gifts and entertainment can cause a conflict of interest, or the appearance of a conflict between personal interests and professional responsibility. The Walmart culture is to never accept gifts or entertainment from any supplier, potential supplier, government, or any person 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 store or club, 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 not accept or approve of them making donations on behalf of Walmart.


Our policy of declining all gifts and entertainment stems from our value of maintaining Every Day Low Costs. Since such gifts and entertainment increase the cost of doing business, we help our suppliers to 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 where local practices will come into play. The Global Ethics Office 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, in order to establish expectations. Also, be aware of what policies your suppliers or other business partners may have in place about this issue and take them into consideration.


Occasionally, there may be times when returning a gift would be impractical or embarrassing. In those rare instances, accept the gift on behalf of the company, report it to your manager, and give the gift to the in-country Ethics Committee or the Walmart Foundation. If either of those options are not possible, find a fair way to distribute the gift equally among the members of your department. You should immediately tell your manager or the Global Ethics Office about any gift you’ve been offered or received if you feel that gift might be a violation of our company’s policy. If you have any questions about gifts and entertainment, you should seek assistance from your manager, the in-country Ethics Committee, or the Global Ethics Office.


You should always 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 be offering me this gift or gratuity if I wasn’t employed by Walmart?” If the answer is “no” or is unclear, you should not enter into the transaction.



Q & A

Our market electronics team is attending a training session, hosted by a supplier, to understand a new item the supplier is launching. The supplier said we will each get free t-shirts for attending the training. Can we accept the t-shirts?
Since the t-shirts are coming from the supplier and are not related to the product, and understanding of the product, they cannot be accepted. Politely decline the t-shirt and explain our gifts and entertainment policy to the supplier.


I’m attending a business training session sponsored by a professional organization. Following the first day of training, the suppliers sponsoring the event are going to provide snacks and drinks at a reception for all attendees at the session. Can I go and have snacks and a drink?
Yes. Since the reception is open to all attendees, you’re not being singled out as a representative of Walmart.


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?
You should decline the offer. Although you may be paying face value for the tickets, it may not necessarily 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, there could be a gift of prestige in receiving the ability to attend a coveted event, such as the World Cup.