As part of the program, Walmart shall adopt operating procedures specifically targeted to the corruption risks that exist for all of its operations, worldwide. To effectively implement this policy, Walmart shall maintain an effective risk-based Global Anti-Corruption Program (the 'Program') designed to prevent, detect, and remediate bribery and recordkeeping violations. Global Implementation of Anti-Corruption Policy All associates are responsible for ensuring that third parties with whom they interact fully understand and follow the policy and associated procedures in their activities related to Walmart business.Īny associate or third party who violates this policy in connection with Walmart business will be subject to disciplinary measures, up to and including termination in the case of an associate, or termination of business relations in the case of a third party and, where appropriate, referral of the matter to relevant law enforcement authorities. The use of Walmart funds or assets for any illegal, improper, or unethical purpose is strictly prohibited.Ĭompliance with this Global Anti-Corruption Policy (the “Policy”) is required of all associates and third parties that are engaged to interact or may interact with government officials on the Company’s behalf. Improper payments means receiving or paying bribes or giving, offering, or promising to give money or anything else of value to any person, including any Government Official, in order to improperly influence any act or decision of a person, or to otherwise gain an improper benefit for the Company.Ī Government Official may include, but is not limited to, any officer or employee of a foreign government, a public international organization, a member of a political party, a candidate for foreign political office, any foreign government department or agency thereof, or any official or employee of a state-owned business enterprise. It is the policy of Walmart to comply with all relevant Anti-Corruption laws including, but not limited to, the US Foreign Corrupt Practices Act ('FCPA') and the UK Bribery Act.Īccordingly, Walmart prohibits anyone acting on behalf of the Company, directly or indirectly, from making or receiving improper payments. This policy prohibits corrupt payments in all circumstances, whether in dealings with government officials or individuals in the private sector. In all of its operations, Walmart seeks to avoid even the appearance of impropriety with respect to the actions of any of its officers, directors, associates, employees, agents or representatives.

and its subsidiaries and affiliates worldwide (collectively 'Walmart' or the 'Company'), are committed to maintaining the highest possible ethical standards and complying with all applicable laws.

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