Ethics & Compliance (2024)

Investigation & Remediation

Prompt fact-finding, root cause, and corrective action analysis are central to the effectiveness of our ethics and compliance program. When we substantiate a violation of our company’s ethics and compliance expectations, we remediate the underlying issues, including through root cause analysis and appropriate accountability for culpable associates and third parties. While maintaining independent judgment, we involve and communicate with our business partners regarding our findings and needed adjustments in processes and controls.

Contacts made to Ethics through the confidential reporting channels are triaged by subject matter, risk presented to the company, and severity of the allegation. Cases may be referred to business units for follow-up, investigated by our Global Investigations team or another investigative unit, or escalated to our Legal Investigations Team for handling as appropriate.

If a report results in a substantiated violation of our Code of Conduct or our ethics and compliance program policies, associates may face discipline up to and including termination. Other remedial actions taken as a result of violations can include reduction of associates’ annual cash incentive payment, associates being provided training and/or counseling, changing policies or procedures, or implementing additional processes or controls.

Continuous Improvement

Walmart's Global Governance team works continuously to improve and adapt our ethics and compliance program to mitigate new and evolving risks, including partnering with other stakeholders to design and integrate compliance into new business initiatives and acquisitions. Through program reviews, benchmarking, and the incorporation of lessons learned, we assess and adjust our program to ensure continued effectiveness.

Building Trust With Our Associates and Customers, and In Our Business

Building trust in our business, and with our associates and customers, is foundational to creating the culture of ethics, compliance, and integrity that we need in order to win with our customers and other stakeholders. One of the ways that we increase trust is through the design and implementation of compliance programs that are designed with specific risk areas in mind, and which reflect the complexity of our global business and dedication to doing business the right way.

We maintain compliance programs for a broad range of subjects including anti-corruption, antitrust, consumer protection, labor and employment, financial services, healthcare, food and product safety, environmental health & safety, and responsible sourcing. Several of these programs are described in more detail below.

Respecting One Another by Not Tolerating Harassment or Discrimination

We are dedicated to a workplace that is free of harassment and discrimination. We do not tolerate any behavior that creates an intimidating, hostile, or otherwise offensive work environment based on an individual’s protected status. We also do not tolerate retaliation against anyone who raises a concern about harassment or discrimination. These expectations are set out in our Code of Conduct and in our Global Discrimination and Harassment Prevention Policy.

Creating a Safe Place to Work & Shop

The health and safety of our associates and customers is not just a business need — it’s a societal imperative. Walmart employs more than two million associates, and those associates keep our business running. Hundreds of millions of customers turn to us for essential food, products, and services. They need to feel safe when they’re shopping at our stores and clubs.

Walmart is proud of its long-standing commitment to protecting human health and the environment. As an ethical and responsible corporate citizen, Walmart is dedicated to minimizing our environmental impact and preserving the health and safety of our associates and customers. It is Walmart’s intent to operate in compliance with all Environmental, Health, and Safety (EHS) laws and regulations. Walmart’s Global EHS Policy establishes a standard that is intended to protect human health and the environment while creating a safe workplace.

Walmart employs a team of safety professionals who are responsible for developing and implementing safety initiatives for the different operational formats within the company, including but not limited to, Walmart stores, Sam's Clubs, supply chain facilities, and international facilities. Our safety team focuses on training, promoting a culture of safety compliance, and monitoring safety compliance. Walmart associates in these facilities receive training on numerous health- and safety-related processes according to their job duties, including, but not limited to:

Accident prevention
Hazard identification
Safe use of machinery and equipment
Use of personal protective equipment
Emergency response
Fire prevention

We also contract with an independent third party to conduct risk-based assessments of our U.S. stores and clubs to monitor the execution of specific elements of our EHS program. More than 33,100 visits were conducted in 2022.

To help ensure a safe working environment for associates, we document and analyze associate incident and injury data. The Occupational Safety and Health Administration (OSHA) Recordable Incident Rate (RIR) and Lost Time Incident Rate (LTIR) are calculations that describe the frequency of incidents per 100 full-time employees per year. The RIR is based on all incidents that resulted in medical treatment beyond first aid; the LTIR is a similar calculation, except that it only includes incidents that resulted in at least one lost workday. The significantly lower LTIR compared to the RIR indicates that the majority of our recorded incidents were minor in nature.¹