Last updated: 04/27/2021
- Anti-Corruption Due Diligence Privacy Notice
- What personal information do we collect and how do we use it?
- What do we do with it?
- How long will we keep your personal information?
Anti-Corruption Due Diligence Privacy Notice
Please read this notice in conjunction with our Privacy Notice.
What personal information do we collect and how do we use it?
Before making certain donations or engaging any contractor or supplier that falls within the definition of a third party intermediary, Walmart conducts due diligence including the collection of information, the specific purpose of which is to: (i) assess the anti-corruption risks associated with each potential donation recipient, contractor or supplier (together known as “Candidate”) for compliance with our legal obligations, specifically to determine if a Candidate represents a risk of non-compliance with any applicable anti-bribery, anti-corruption or similar laws, including and the Corruption of Foreign Public Officials Act (Canada), the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and the UK Criminal Finances Act; (ii) evaluate, select, and approve or reject the Candidate; (iii) communicate with Candidates; and (iv) where required, to assess the suitability of suppliers providing specialist services; (v) monitor compliance with our anti-corruption process and (vi) obtain legal advice from external legal advisers (when applicable). For successful Candidates, these checks will be refreshed every two (2) years.
This due diligence will include:
1. Completion of a Candidate questionnaire that, where applicable, requires information such as:
- Candidate’s personal and business information (information that personally identifies the Candidate and their business and qualifications)
- Contact information for the individual(s) responsible for the business relationship between Candidate and Walmart, including name, year of birth, country of residence, telephone number and email address
- Information relating to the services provided or proposed donation
- Information relating to any sub-contractors, subsidiaries and/or related parties (e.g., partnerships, sister companies, joint ventures), third parties, intermediaries, or other persons or entities the Candidate will engage when providing services, including name, year of birth, country of residence, telephone number and email address
- Information relating to owners, partners or shareholders of companies Candidate will engage when providing services, including name, year of birth, country of residence, citizenship, ownership percentage and indication of whether they are associated with a government entity or political party or campaign
- Reference information (company and individual contact information for Candidate’s references)
- Information regarding any formal charges or convictions against Candidate, its trustees, officers, or its executives, including bribery or corruption related violations
2. Searches on the Internet or other public sources of information (e.g., public data registries), and from a third party provided database (Dun & Bradstreet).
To the extent you have provided personal information about another individual in connection with this questionnaire, you must provide assurance that you have obtained their written consent for Walmart to process their information as outlined within this privacy notice and you agree that you will maintain a record of all these consents and provide them upon request.
The information collected from you and other sources will be stored on behalf of Walmart in an electronic database provided by Dun & Bradstreet. This database is hosted in the United States. Dun & Bradstreet may also use the business and contact information collected from you to update its global business database. The information maintained by Dun & Bradstreet as part of its global business database is the responsibility of Dun & Bradstreet and is subject to their privacy notice available at https://www.dnb.com/utility-pages/privacy-policy.html.
What do we do with it?
Other than as provided in the Privacy Notice, we may share the information you provide with our domestic and international Walmart affiliates for the purposes described above. We also share this information with Dun & Bradstreet so that they can supply commercial data about organizations to the Walmart anti-corruption teams to inform the due diligence assessment. Walmart will engage Dun & Bradstreet to complete Candidate searches using their global business database.
We may transfer the personal and business information we collect to other countries where we do business, which may not have the same data protection laws as the country in which you reside. We have taken steps to provide an adequate level of protection in accordance with applicable data protection laws in the countries in which we operate.
How long will we keep your personal information?
We keep Candidate’s information for as long as it’s required for the purposes described in this notice. Personal information related to due diligence checks, either in hard copy or electronically, is kept for five (5) years or as otherwise required by law or Walmart policy, from the date that the last related action occurred.