Wal-Mart Code of Ethics

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Statement of Ethics Statement of Ethics

Table of contents
Using the Statement of Ethics The 3 Basic Beliefs and Guiding Principles Introduction Who is Covered What Law Applies Associate Responsibilities Additional Responsibilities for Management Associates Discipline for Violations 4 5 6 6 6 6 7 7 8 8 8 8 9

Leading with Integrity in Our Marketplace
Fair Competition Intentional Dishonesty Financial Integrity Insider Trading Restrictive Trade Practices

19 19 19 20 20 21

Leading with Integrity in Our Communities 22
Anti-Corruption Anti-Money Laundering Authority to Work Environmental Responsibility Health & Safety Protecting Personal & Business Information Government Contracts & Inquiries Political Involvement International Trade Media Statements 22 23 24 25 25 26 28 28 28 29 30 30 32 33

Raising Concerns & Speaking Up
Ethics Opinions Waivers What happens How to Raise a Concern

Leading with Integrity in Our Workplace

10 Alcohol & Drug Abuse 10 Harassment 11 Inappropriate Conduct 11 Non-Retaliation 12 Non-Discrimination 12 Wage and Hour 13 Conflict of Interest (COI) 14 COI – Financial Investments 14 COI – Personal Relationships with Suppliers 15 COI – Gifts & Entertainment 16 COI – Personal Relationships with Other Associates 17 Walmart Assets 18

Final Disclaimer Global Ethics Contact Information Ethics Committee Contact Information Index


A message from our Chief Executive Officer
Mike Duke, CEO
Dear friends, Walmart started out with a single discount store in Northwest Arkansas and in less than 50 years grew to become the world’s largest retailer, with thousands of stores and clubs and millions of associates. Our culture of ethics and integrity has been a constant throughout that transformation. From the beginning, it has defined who we are as a company, and how we as associates treat each other, our suppliers and our customers. The values that set us apart from others -- respect for the individual, service to our customers and...
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