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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.

Violations 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.

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.

As part of the program, Walmart shall adopt operating procedures specifically targeted to the corruption risks that exist for all of its operations, worldwide.

Last modified 15-Jul-2016 17:28