Global Anti-Corruption Policy
Updated: June 29, 2012
Wal-Mart Stores, Inc. 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. 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. This policy prohibits corrupt payments in all circumstances, whether in dealings with government officials or individuals in the private sector.
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.
Accordingly, Walmart prohibits anyone acting on behalf of the Company, directly or indirectly, from making or receiving improper payments.
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.
A 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.
The use of Walmart funds or assets for any illegal, improper, or unethical purpose is strictly prohibited.
Compliance 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. 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.
Any 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.
Global Implementation of Anti-Corruption Policy
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. As part of the program, Walmart shall adopt operating procedures specifically targeted to the corruption risks that exist for all of its operations, worldwide. Management in each affected area shall be responsible for ensuring that adequate resources are devoted to maintaining effective compliance programs. A senior executive at Wal-Mart Stores, Inc., shall be given overall responsibility for the Program, and shall report regularly to the Audit Committee of the Board of Directors of Wal-Mart Stores, Inc., which shall exercise reasonable oversight as to the implementation and effectiveness of the Program.
The procedures and governance used to implement this policy, shall include, at a minimum:
- Effective controls on the disbursement of funds and other assets to ensure that disbursements are not made for improper purposes;
- Measures to ensure that books and records accurately reflect the disposition of assets;
- Clearly articulated standards of behavior as included in Walmart's Statement of Ethics, which shall be well publicized to all of Walmart's operations, worldwide;
- Clearly defined roles, responsibilities, and reporting lines for day-to-day management and implementation of the compliance procedures;
- Effective training of executives, associates and, where appropriate, third parties regarding relevant anti-corruption standards and procedures;
- Testing by Internal Audit or a third party for compliance with the anti-corruption procedures, including review of expenditures for operations that interact with government officials;
- Corruption risk assessments conducted annually;
- Conducting due diligence of third parties engaged to interact with government officials on behalf of the Company;
- Effectively publicized means to report or seek guidance on actual or potential anti-corruption issues, as well as procedures for responding to such reports or requests;
- Regular review and, if necessary, revisions or updates to this policy and to the related procedures where appropriate, including in response to legal, regulatory, or industry changes or violations of the Anti-Corruption Policy;
- Appropriate incentives and punishments for associates, executives and third parties for adherence to or violations of, respectively, the relevant policy and related procedures.
Every associate or third party who has information that this policy or related procedures may have been violated, or believes he or she is being asked to pay a bribe or receive a bribe, or otherwise act in contravention of this policy shall immediately report the event, as provided by Walmart's Statement of Ethics. Reports shall be made, and may be made anonymously to any officer (Vice President or above) of the Company, Global Ethics, the International Global Ethics Helpline, or the International Anti-Corruption Compliance Manager/Director. Reports may also be made to the Local Ethics Helpline, the legal department, the Compliance and Ethics Office or the Market Anti-Corruption Compliance Manager/Director. If anyone receives a report through the Open Door process he or she shall promptly forward the report to one of the contacts stated in this paragraph. Anyone who receives a report through any of the channels stated in this paragraph shall immediately report to the Global Ethics Helpline.
Contact information for making reports through the International or Local Helplines are below:
Walmart's International Global Ethics Helpline: 800-WM-ETHIC (800-963-8442)
Web: www.walmartethics.com or
Specific country contact information can also be found on www.walmartethics.com
Anyone who reports a suspected violation of this policy will not be subject to disciplinary action or retaliation for the act of making the report. However, anyone who reports a suspected violation may be subject to disciplinary action to the extent he or she violated any Walmart policy or procedure.
Multi-Year Accessibility Plan for Walmart Canada
Accessibility for Ontarians with Disabilities Act (AODA)
This 2014-2021 accessibility plan outlines the commitments and actions that Walmart Canada (Walmart) will put in place to improve opportunities for people with disabilities.
Statement of Commitment
Walmart is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements, especially as they relate to the Accessibility for Ontarians with Disabilities Act (AODA).
Walmart has implemented a Customers with Disabilities policy that applies to all stores in Canada to ensure that customers with disabilities are treated with respect and dignity in their shopping experience at Walmart. Walmart has implemented a Duty to Accommodate policy that applies to all associates in Canada to ensure that associates do not face barriers to working or continuing to work because of disabilities.
Accessible Emergency Information
Walmart is committed to providing its customers with publicly available emergency information in an accessible way upon request. Emergency procedure information is available to visitors of Walmart’s Home Office. Walmart also provide associates the opportunity to prepare individualized emergency response information plans to assist in the event of an emergency.
Walmart has provided computer-based training to all of its associates on the subject of customers with disabilities and Walmart will ensure that the training remains current at all times. Walmart will provide training to associates on applicable accessibility laws and on human rights legislation as it relates to people with disabilities. Training for current associates will be provided by January 1, 2015 and will be updated and provided on an on-going basis.
Walmart will consider the needs of people with disabilities when procuring or acquiring self-service kiosks. Walmart will identify areas of its business in which kiosks are used and coordinate with its vendors and suppliers to ensure that appropriate accessibility features (technical, structural, access path, etc.) are included in the design of any future purchased kiosks.
Information and Communications
Walmart is committed to meeting the communication needs of people with disabilities. Walmart is currently in the process of updating its websites and content on those sites to conform with Web Content Accessibility Guidelines (WCAG) 2.0, Level A and Level AA by January 1, 2021.
Walmart will take the following steps to ensure existing feedback processes are accessible to people with disabilities upon request by January 1, 2015: assess current forms of company communication, consider accessibility requirements when creating new forms of communication, make appropriate changes and accommodations, ensure customers and associates are aware of how to participate in providing and receiving a response to feedback.
Walmart will take the following steps to make sure all publicly available information is made accessible upon request by January 1, 2016: assess all forms of information provided to the public and determine if there is anything that would make it hard for someone with a disability to read, see, hear or understand and establish processes for ensuring alternate formats are available in a timely manner.
Walmart is committed to fair and accessible employment practices.
Walmart will accommodate people with disabilities during the recruitment, assessment and hiring processes and during employment. Walmart will review current recruitment policies, job descriptions, processes and communications and amend as necessary to reflect required integrated accessibility standards.
Walmart will develop or revise as required individual accommodation plans and return-to-work policies for associates who have been absent due to a disability.
Walmart will review performance management, career development and re-deployment processes and amend as required to ensure the accessibility needs of associates with disabilities are taken into account in connection with these processes.
Walmart will take the opportunity to identify and take any necessary steps to prevent and remove other accessibility barriers impacting employment.
Design of Public Spaces
Walmart will work toward meeting the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces which can include accessible off-street parking, ramps, sidewalks, entrances and service-related elements like service counters, check-out lines, waiting areas and washrooms.
For more information
For more information on this accessibility plan, please contact Customer Service at:
Phone: Call 1-800-328-0402 Option 5 - (7:30 a.m. – 5:30 p.m. EST, Monday – Friday (excluding holidays)
Accessible formats of this document are available free upon request from Customer Service.
Sometimes clothes don’t fit right, an appliance breaks, or you’re just not happy with what you bought. We can help.
If I buy something from Walmart, can I return it?
Yes (with just a few exceptions). We know that sometimes you buy something that doesn’t work out the way you had hoped, and for that reason we did our best to make a return policy that is helpful for you. Our return policy is the same for both online and in store purchases with just a few minor differences:
• Online purchases: the return timeframe begins on the date of your order’s arrival
• In-store purchases: the return timeframe begins on the purchase date. Make sure to bring along your proof of purchase.
Almost anything you buy from Walmart can be returned within 90 days with the exception of a few items below.
There are a few exceptions you should know about, which are listed below:
Within 14 days
Computers, tablets, laptops, monitors, printers, camcorders, digital cameras, portable video players, wearable tech, video game consoles and video game handhelds, GPS units, and wireless prepaid phones
For online purchases, the return timeframe begins on the date of your order’s arrival.
Within 15 days
Air mattresses, Contract postpaid phones*
For online purchases, the return timeframe begins on the date of your order’s arrival.
*Subject to applicable legislation. Conditions may vary by carrier. See plan terms and conditions.
Within 30 days
Televisions, DVD players/recorders, home audio systems, telephones, MP3 players, tents, pools, prescription eyewear, air conditioners, outdoor power equipment**, full sized mattresses and large appliances***
For online purchases, the return timeframe begins on the date of your order’s arrival.
**All fuel powered equipment must be returned to the store, whether purchased in store or on Walmart.ca
***Full sized mattresses and large appliances purchased online cannot be returned to the store, please contact Customer Service at 1-800-328-0402 to make arrangement for the return.
Within 1 year
Trees and shrubs (product must be returned to store)
These items must be returned unopened:
Prerecorded music, movies, software products, computer/ video games, ink cartridges, boxes of disposable contact lenses, air mattresses and breast pumps.
These items must be returned in original packaging:
Any products containing gases, flammable liquids, flammable solids, oxidizers, corrosive materials or items containing poisonous or radioactive components. Example products include perfume and cologne, lighters and lighter fluid, paints and coatings, pool chemicals, pesticides, smoke detectors and muriatic acid.
Items that can only be returned to a Walmart store:
Hazardous materials and dangerous goods. These would be items containing chemicals, compressed gases and liquids which could pose a health or safety risk. For example: Aerosol cans, household cleaners, fuel-powered equipment. If an item has been filled with fuel it cannot be returned by mail even if the tank is drained before shipping.
Sales are final:
Ammunition, fireworks, gift cards, prepaid phone cards, underwear, and pierced or personalized/engraved jewellery.
Gift Card with Purchase Offers
If your purchase included a free gift card, the free gift card must also be returned unredeemed for the purchase to qualify for a refund.
What about children’s clothing and groceries? Can I return those products as well?
Absolutely! We want you to love what you bought, so we offer the following satisfaction guarantees for children’s clothing, exclusive brands to Walmart Canada and produce, meat and seafood (with only a few exceptions):
1. Children's clothing and footwear (excluding accessories): Wal-Mart Canada Corp. guarantees that our children's clothing (sizes 0 – 16) and children’s footwear (Pre-walk / Toddler (sizes 0 – 10) and Youth (Boys sizes 11 – 13, 1 – 6 / Girls sizes 11 – 13, 1 – 4)) will not wear out before the child for whom it was purchased outgrows it. If the item does wear out, simply return it with your original confirmation of purchase to any Walmart Canada store and we'll replace it with an identical item of the same size. Excludes all accessories. If identical item is not available in identical size, Walmart will substitute a similar item of equal size and price.
2. Produce, bakery, deli, meat & seafood: 100% Satisfaction Guarantee. If you are not fully satisfied with the quality and freshness of the products you buy, simply bring it back with your receipt and we will gladly refund your purchase or replace your item.
3. Exclusive brands to Walmart (such as EQUATE, GREAT VALUE, OUR FINEST, PARENT’S CHOICE, YOUR FRESH MARKET). If you are not fully satisfied with your Walmart brand product, simply bring it back and we will gladly refund your purchase or replace your item, no receipt required.
Sustainable Chemistry in Consumables
Our customers want products that are affordable, safer and better for the environment. We are committed to supporting the advancement of sustainable chemistry practices to help minimize the negative environmental and health impacts certain chemical products and processes may cause. This commitment covers the following departments: Health & Beauty Aids (D2), Household Paper (D4), Pets + Supplies (D8), Household Chemicals (D13) and Cosmetics (D46).
Sustainable chemistry is the design of chemical products and processes that reduce or eliminate the use or generation of substances hazardous to humans, animals, plants and the environment (IUPAC definition).
Walmart Canada’s commitment to sustainable chemistry is as follows:
- Walmart Canada will continually work with suppliers on sustainability improvements through the Sustainability Index (category sustainability profiles, etc) to address chemical disclosure, risk assessment and hazard avoidance.
- Walmart Canada encourages all suppliers to publicly disclose, on their product and/or company web-sites, all ingredients for their consumable-product SKUs sold at our stores.
The Walmart US business has developed an initial list of high-priority chemicals for continuous reduction, restriction and elimination, using informed substitution principles. This list will be reviewed regularly by Walmart US to determine if additional chemicals should be prioritized. Walmart Canada supports Walmart US’ monitoring of the progress on reducing, restricting and eliminating these high-priority chemicals and their timelines to publicly report on such progress.
We anticipate any product innovations developed by US suppliers (which are also operating in Canada) to equally apply in the Canadian marketplace so that our Canadian consumers will also benefit from the above-described US efforts.
Our Canadian commitment supports Walmart US’s sustainable chemistry initiatives; it also supports related timelines stated in their Sustainable Chemistry Policy.
Walmart Canada will review this document as needed to ensure its relevancy.
Released: June 2014
Position on Sustainable Seafood
Section I: Sustainable Products at Walmart | Our Pledge to Customers/Members
Our customers and members count on Walmart and Sam’s Club to deliver affordable products in a way that is sustainable for people and for the planet. To meet those needs, we work with partners all along the supply chain to improve the sustainability of products we sell. We do this while working to offer quality products, everyday low prices and putting customers in charge of their food choices by helping provide clear, accurate information about food ingredients and production.
Section II: Sustainable Seafood
Over the past half century, demand for seafood has increased five-fold. An estimated 75 percent of the world’s fisheries are at or beyond sustainable limits. Meanwhile, an estimated 1 billion people rely on fish as their primary source of protein, while another 200 million rely on the industry as their main source of income.
Section III: Walmart’s Position
Walmart aspires to help make choices easier and more transparent for people. We serve hundreds of millions of customers every year, and we advocate for them among suppliers to provide more sustainably produced products while maintaining the low prices customers expect. As part of our efforts to provide our customers affordable, safe, and healthier food, Walmart is committed to expand and enhance sustainable sourcing to cover 20 key commodities.
At Walmart, we value our relationships with the seafood suppliers who are dedicated to providing the highest in quality and safety through practices that promote sustainable fisheries and social responsibility. We know that seafood is an important source of protein, nutrition, and income for people all over the world. Therefore, we aspire to find our customers safe, affordable, and sustainable seafood that does not negatively affect global communities or the environment. Our goal is to build transparency and continuous improvement in the seafood supply chain so that we can build confidence and provide for our customers now and in the future.
Walmart believes the health of species, fisheries and ecosystems around the world is good for the planet and important to people today and in the future. We are working with our suppliers and partners to track the management of fisheries from which our suppliers source so that we can promote a sustainable supply.
In addition, we care about the men and women in our supply chain and in the seafood industry as a whole, and we are concerned about the ethical recruitment and treatment of workers. While this is a complex issue, we are actively engaged in bringing together numerous stakeholders, NGOs and other private sector companies to help find solutions.
Section IV: What we’re asking of our suppliers
Fresh and Frozen Seafood
By 2025, based on price, availability, quality, customer demand, and unique regulatory environments across our global retail markets, Walmart U.S., Sam’s Club, ASDA, Walmart Canada, Walmart Brazil, Walmart Mexico, and Walmart Central America will require all fresh and frozen, farmed and wild seafood suppliers to source from fisheries who are:
· Third-party certified as sustainable using Marine Stewardship Council (MSC) or Best Aquaculture Practices (BAP), or certified by a program which follows the FAO Guidelines and is recognized by the Global Sustainable Seafood Initiative (GSSI) as such. For our farmed supply, we expect suppliers to ensure sustainable production and sourcing throughout the supply chain, including final processing plant, farms, hatcheries and feed mills.
· Actively working toward certification or in a Fishery Improvement Project (FIP) or Aquaculture Improvement Project (AIP) that has definitive and ambitious goals, measurable metrics, and time bound milestones.
By 2025, based on price, availability, quality, customer demand, and unique regulatory environments across our global retail markets, Walmart U.S., Sam’s Club, and Walmart Canada will require all canned light and white tuna suppliers to source from fisheries who are:
· Complying with the International Sustainable Seafood Foundation (ISSF) sustainability conservation measures, including those adopted in collaboration with relevant tuna Regional Fishery Management Organizations (RFMO) and from vessels that are registered on the Pro-active Vessel Register (PVR).
· Third-party certified as sustainable using Marine Stewardship Council (MSC), or certified by a program which follows the FAO Guidelines1 and is recognized by the Global Sustainable Seafood Initiative (GSSI) as such. Walmart will also source from suppliers using better management fishing practices as validated through chain of custody (e.g. pole and line, free-school sets).
· Actively working toward certification or in a Fishery Improvement Project (FIP) that has definitive and ambitious goals, measurable metrics, and time bound milestones.
When it comes to the issue of method of catch, Walmart will offer customer choice in select markets, based on local customer preference and market retail norms.
· Walmart U.S. and Sam’s Club offer customer choice by carrying FAD-free lines of canned tuna.
· Walmart Canada will add Marine Stewardship Council-certified or FAD-free tuna to its private brand assortment by the end of 2021.
· ASDA sources all of its own-brand canned tuna and tuna sandwiches come from pole and line or FAD-free sources. For more information please see ASDA’s Sustainable Seafood Policy.
Section V: Responsible Sourcing
Walmart’s commitment includes respecting the dignity of those who grow, catch and produce products for our customers. That is why Walmart suppliers globally—including seafood suppliers—are expected to comply with Walmart’s Standards for Suppliers and applicable Responsible Sourcing program requirements. Walmart’s Standards for Suppliers set out our expectations of suppliers and their facilities regarding the ethical treatment of workers, workplace safety, environmental responsibility, and appropriate business practices. The Standards apply throughout the supply chain, including vessels, hatcheries, feed mills, farms, and final processing facilities. Walmart expects its suppliers to be transparent, to disclose facilities consistent with policy and make all facilities available for audit or inspection at any time, and to commit to continuous improvement. Suppliers are also encouraged to involve themselves in Walmart-led or -supported industry initiatives focused on improving responsible sourcing in seafood supply chains. More about Walmart’s Responsible Sourcing program requirements and collaborative initiatives can be found at corporate.walmart.com/sourcing.
FAO Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries. Revision (2009)
FAO Guidelines for the Ecolabelling of Fish and Fishery Products from Inland Capture Fisheries (2011)
FAO Technical guidelines on aquaculture Certification (2011)