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

2

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 striving for excellence -- rest on the foundation of personal integrity and responsibility. Associates in all areas and levels of our business are responsible for understanding and complying with our Statement of Ethics. I encourage you to be a champion for integrity by engaging fellow associates in conversation and setting an example through your words and actions. We also expect and need you to speak up if you have concerns about any inappropriate behavior you observe. It’s important for us to know about issues upfront so we can work to resolve them immediately. We recognize the responsibility that comes with that requirement. And we know that the decision to speak up can be a difficult one. Silence can condone questionable behavior -- and the actions or inactions of just one associate who makes a poor choice can impact our entire company. That’s why we’re committed to sharing the responsibility with you. We encourage you to use the resources available to you such as the Open Door process and the Global Ethics Helpline. The Global Ethics Helpline is a tool that is available for you to raise your concerns confidentially and anonymously, without fear of consequences. A strong commitment to ethics and integrity isn’t just the right way to do business. It’s how we earn the trust and respect that is critical to our success, and our ability to help more people live better. Our customers trust us to be their advocate. Our suppliers trust us to be an equitable partner. And as Walmart associates, we trust each other to uphold the highest standards of conduct every day. I am confident that our commitment to ethics and integrity will continue to guide us well as we continue on our journey together.

Mike Duke

President and CEO Walmart

3

Using the Statement of Ethics
This Statement of Ethics is going to introduce you to the types of attitudes and conduct that create an honest, fair, and legal workplace. You’re going to learn how to recognize situations that...
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