Leading with Integrity

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“The Statement of Ethics reflects our commitment to continue to be a leader in our industry not only in business, but also in ethical choices and behavior.”
Rob Walton
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We believe in fair, free and open markets, and in promoting good government. We do not tolerate, permit, or engage in bribery, corruption, or unethical practices of any kind. Bribery of public officials in the U.S. and abroad is illegal under both U.S. law and the local law of the countries in which we operate. Walmart’s policy goes beyond these legal requirements and prohibits corrupt payments in all circumstances, whether in dealings with public officials or individuals in the private sector.

Specifically, the Global Anti-Corruption Policy prohibits us from paying, promising, offering, or authorizing a payment, directly, indirectly, or through a third party, money or anything of value to a government official or political party for the purpose of influencing an official act or decision in order to obtain or retain business or secure an improper advantage. The term “government official” includes any person acting in an official capacity for or on behalf of a government or governmental agency or department, including a business with government ownership (for example, a national oil company); a public international organization (for example, the U.N. or World Bank); or a political party or candidate for political office. Even when local practices or customs allow behavior that violates our Anti-Corruption Policy, it is not acceptable for us to do so.

Q & A

Local police officers have recently stopped trucks leaving our distribution center and threatened to delay deliveries unless the driver pays $50 U.S. in cash to the officer. My manager said we should carry $50 gift cards with us. Is it permissible?
Walmart policy prohibits even small unofficial payments to government officials to influence government action. This prohibition applies to cash, gifts, or other things of value. Immediately report this matter to the Legal Department or the Global Ethics Office.

A store is seeking a permit from the local Transport Authority. The store usually gives holiday baskets to various local officials. This year, the store manager suggested including a $300 gift card in the basket for the head of the Transport Authority. Is this acceptable?
The policy does not allow the gift because it's something of value and is apparently intended to influence the Transport Authority. The policy does permit certain customary gifts, such as holiday baskets that are of relatively low value and are not intended to influence anyone.