Editor’s Note
This article outlines the foundational pillars of our company’s Ethics and Compliance program, which is central to fostering a culture of integrity and trust across all our operations and relationships.
At all levels of our company, we work to create a culture that inspires trust among our associates, customers, suppliers, and the communities we serve.
Our Ethics and Compliance program promotes a corporate culture of integrity that provides the basic elements for an effective program inspired by continuous improvement and based on the needs of our operations.
To this end, our Ethics and Compliance program encompasses nine fundamental pillars: Leadership; risk identification, policies, procedures, and controls; training and communications; internal monitoring, confidential reporting; investigations and remediation; and continuous improvement.
The Walmart Code of Conduct is our internal guide and statement of values, principles, and expected behaviors, which applies to all Walmart associates and its subsidiaries.
The Code of Conduct establishes that all Walmart associates, regardless of their level in the company, are responsible for complying with the Law, relevant regulations, and internal policies and procedures.
Among other matters, the Code covers topics such as ethical decision-making, conflicts of interest, use of insider information, protection of Walmart’s property, and other fundamentals of ethics and compliance.
We also expect our suppliers, marketplace sellers, service providers, and other business partners to act with integrity and respect our values.
The Walmart Supplier Standards establish the fundamental expectations for our suppliers. These apply to all suppliers who sell us their products for resale or for Walmart’s own use. Suppliers are also expected to apply the requirements described in our Standards throughout their supply chains, including suppliers of raw materials, components or ingredients, and subcontractors.
Walmart Chile also has a Crime Prevention Model that provides a detailed analysis of its compliance risks under Law 20.393, which is regularly reviewed and updated.
Furthermore, our Ethics and Compliance Program specifically addresses certain matters, such as Free Competition, Anti-Corruption, Responsible Sourcing, Global Sanctions, Risk Prevention and Food Safety, among others.
Walmart Chile has a firm commitment to compliance with the law and free competition. Therefore, we have a Global Free Competition Policy and a Local Free Competition Compliance Guide, in addition to specific policies and procedures, such as those related to the participation of associates in Trade Associations.
We also train all our new associates on Free Competition matters and take all measures, adopting the necessary controls to compete actively and effectively in all markets where we participate, following the guidelines of the competent authorities.
Walmart has a Global Anti-Corruption Policy through which it seeks to prevent any improper action by its directors, workers, agents, or representatives when interacting with public officials.
This policy prohibits acting on behalf of Walmart, directly or indirectly, to make or receive improper payments, thus aligning with the strict compliance with various existing regulations, including, among others, the Chilean Penal Code, the Corporate Criminal Liability Law, the Economic Crimes Law, the United States Foreign Corrupt Practices Act (“FCPA”), and the UK Bribery Act.
Government officials include, among others, any official or employee of a foreign government, an international public organization, a member of a political party, a candidate for foreign political office, a foreign government department or agency, or an official or employee of a state-owned enterprise.
Walmart Chile is part of the Company’s Global Responsible Sourcing Program. This seeks to drive significant and sustainable changes for the workers involved in our global supply chain.
This program focuses its efforts on setting demanding parameters regarding what is expected from its suppliers in social and environmental matters, verifying compliance through on-site audits.
