Associates and Directors – This Statement of Ethics applies to all associates worldwide, and all members of the board of directors of Walmart Stores, Inc. It also applies to the associates and directors of all Walmart-controlled subsidiaries.

Third Parties – Walmart expects its suppliers, consultants, law firms, public relations firms, contractors, and other service providers to act ethically and in a manner consistent with this Statement of Ethics. If you hire a service provider, you should take reasonable steps to make sure the service provider is aware of our Statement of Ethics, has a reputation for integrity, and acts in a responsible manner consistent with our standards.

Walmart conducts business in many countries around the world. Our associates are citizens of many countries and, as a result, our operations are subject to many different laws, customs, and cultures.

The number of laws and regulations around the world that affect Walmart increase and become more complex each year. When it’s possible, this Statement of Ethics will be modified to conform to changes in laws and customs. In some instances, the laws of two or more countries will conflict. When you encounter a conflict, contact the Global Ethics Office or your in-country Ethics Committee to understand how to resolve the conflict.

• Follow the law at all times. If you see any associate violating the law, or if you’re asked to do something you believe may violate the law, discuss it immediately with your manager, n-country Ethics Committee, or the Global Ethics Office.
  
• Read and understand the Guiding Principles and use those principles in your job every day.
  
• Learn the policies that apply to your job. No one expects you to memorize every policy, but it’s good to have a basic understanding of issues covered by each policy.
  
• Ask for help from your manager, the Global Ethics Office, or other Walmart resources when you have questions about the application of this Statement of Ethics or other policies.
  
• Immediately raise any concern you, or others, may have about possible requests or acts that may be a violation of this Statement of Ethics or any Walmart policy.
  
• It’s important to understand how to raise ethics concerns. You can raise them with a manager, or by contacting the Global Ethics Office directly. Ways to raise concerns are described in more detail later in this guide. If you raise an ethics concern through a manager and the issue is not resolved, raise it through a different manager or the Global Ethics Office directly.
  
• Cooperate with and maintain the privacy of any Walmart investigation into violations of this Statement of Ethics, or any other Walmart policy.
  

Appropriate disciplinary action, up to and including termination, may be taken against any associate whose conduct violates this Statement of Ethics or applicable laws and regulations, including the Guiding Principles.

As a management associate, you’re responsible for creating an environment that encourages compliance with Walmart’s Statement of Ethics. Supervision of responsible business practices is as important as supervision of performance. You should do the following to make sure our company maintains the highest ethics:

• When an ethics issue comes to your attention, contact the Global Ethics Office for assistance.
  
  
• Meet with your direct reports as a group periodically to review the Guiding Principles and this Statement of Ethics.
  
  
• Where there is a conflict between our ethics and business objectives, our ethics must always come first.
  
  
• Lead by example, and encourage your associates to act with integrity in all dealings to avoid even the appearance of a violation of our business standards.
  
  
• If an ethics issue arises with one of your associates, make sure other associates in your area are not making the same mistake.
  
  
• Ensure open communication by encouraging associates in your department or division to ask questions concerning our Statement of Ethics.
  
  
• Never cover up or ignore any ethical conduct problem. Address the matter in a timely manner and seek guidance if necessary.
  
  
• Appreciate associates who raise issues.
  
  
• Never retaliate against anyone for raising an ethics issue, assisting in an investigation, or participating in any proceeding relating to an alleged violation of any applicable government regulations, laws or rules, or an alleged fraud against shareholders.
  
  
• Encourage self-reporting of business conduct violations. If an associate voluntarily reports that they were involved in an ethics violation, such self-reporting may be considered when determining the appropriate disciplinary action to be taken.