All of us should constantly work to maintain a working environment that encourages associates to raise concerns about possible violations of our Statement of Ethics. Often we hear stories of other companies where employees were aware of problems, but did not feel comfortable coming forward. No one should feel that way at Walmart. Please report possible ethics problems immediately so they can be resolved before more serious consequences develop.

In the normal course of business, you might have a situation where you’re not quite sure if there is a violation of ethics, or whether the situation is within the standards described in this Statement of Ethics. When you have any ethics question, you are encouraged to use the Open Door process or contact the Global Ethics Office for a verbal or written opinion before you take any action

Any associate (other than executive officers) can request from the Global Ethics Office a waiver of the applicability of this Statement of Ethics. Ethics waiver requests must be submitted in writing to the Global Ethics Office by the associate, and must contain in detail all of the relevant facts and circumstances supporting the requested waiver. The Global Ethics Office will respond in writing to the associate.

For members of the board of directors and executive officers, requests for waivers of the Statement of Ethics will only be considered by the Audit Committee or by the full board of directors, as the board of directors determines. Members of the board of directors and the chief executive officer must submit their own waiver requests in writing. Written requests must set forth the relevant facts and circumstances supporting the waiver. After receipt and review of the request, the Audit Committee or the board of directors will respond in writing to the requester. Any waivers of this Statement of Ethics granted in favor of members of the board of directors or executive officers will be promptly disclosed to shareholders.

All waiver requests must be approved in advance of the conduct for which approval is sought.

Walmart takes all reported concerns seriously. We will confidentially investigate allegations to determine if any law, policy, or the Statement of Ethics has been violated. If you report a violation, the Global Ethics Office will make every effort to keep your identity private. We will also work to make sure any data relating to the investigation is kept secure. To assist in privacy, it is important that you do not discuss your concern with others.

If you’ve raised a concern with management, they will follow up with you in a reasonable amount of time and provide an update on the issue. Specific information regarding investigations is private information, but you will be told the status of the investigation — whether it’s active or closed.

If an associate reports a Statement of Ethics violation to the Global Ethics Helpline, is that associate exempt from disciplinary actions for unrelated misconduct?
Not necessarily. The report made by the associate, and the associate’s own misconduct are two separate issues that should be dealt with independent of each other. We are all expected to perform our duties with integrity, respect, and are accountable for our own actions when conducting business for Walmart.

Walmart provides a variety of resources you can turn to when you need to raise a question or concern. Depending on the nature of the concern, it may be easiest to talk to the person responsible directly about your concerns, providing them an opportunity to clarify their conduct. If you don't feel comfortable handling the situation yourself, or if you believe the misconduct involves a legal issue, you should consult one of the following resources:

• Use the Open Door Communications process.
  The Open Door Communications process is the most direct way to voice any concern to a manager. If you believe your immediate manager is involved in the problem, discuss the issue with the next level of management who is not involved, or use one of the other resources described below.
  
  
• Call the Global Ethics Office.
  Walmart has a Global Ethics Helpline, which is available to associates around the world 24 hours a day, seven days a week, and is equipped to handle most local languages. The Helpline is staffed by an organization not affiliated with Walmart, and to the extent possible (and in conformity with local regulations), callers may not have to give their name. In all cases, associate privacy will be respected to the fullest extent possible under the law. The operator will relay the information to the Global Ethics Office, and will provide the associate with a case number and callback date if desired. Global Ethics Office phone numbers are located in the back of this tool.
  
  
• Call your local Ethics Committee.
  
  U.S.A., Puerto Rico and Canada = 1-800-WM-ETHIC [1-800-963-8442]
  Canada (French) = 1-800-805-9121
  (Specific phone numbers for all countries are listed in the back of this tool.)
  
  
• Contact the Global Ethics Office by Mail, E-Mail or on the Internet.
  
  
  Mail
  Walmart Stores, Inc.
  Attn: Global Ethics Office
  702 SW 8th Street
  Bentonville, AR 72716-0860
  
  E-Mail
  ethics@wal-mart.com
  
  The Internet
  walmartethics.com