Social Responsibility INTEGRITY Integrity Social Responsibility INTEGRITY SOCIAL RESPONSIBILITY AND SUSTAINABLE DEVELOPMENT WALMART DE MÉXICO Y CENTROAMÉRICA Being socially responsible means acting with integrity in following our beliefs; looking for development and quality of life for our associates; operating with efficiency to achieve low costs and offering low prices to our customers; investing in Mexico to create jobs; working with our suppliers to drive their competitiveness; privileging innovation; promoting volunteer work among our associates; as well as supporting sustainable nourishment of less-favored communities in Mexico, and caring for and respecting the environment. Integrity is the cornerstone of the Walmart Culture and relies on three basic beliefs: 1. Respect for the individual means to work in a respectful and dignified environment with equal opportunities. Share information, listen to ideas and receive support for personal development are excellent examples of what respect implies. 2. Customer service refers to offering customers and members quality merchandise, product assortment and low prices every day, because that is the essence of our business. 3. Strive for excellence implies continuous improvement, innovation and always being one step ahead in everything we do to exceed customer and member expectations. The Statement of Ethics, promoted by the Global Ethics Office, governs our behavior and protects our associates. It is the pillar on which our culture is based and is presented to all associates. The Statement of Ethics presents attitudes and behaviors that create an appropriate work place and includes topics such as: harassment, discrimination, conflict of interest, fair competition, financial integrity, anti-corruption, health and safety, social and environmental responsibility, among many others. This document supplements the Federal Labor Law in Mexico and is aligned with current Mexican legislation. PRINCIPLES OF SOCIAL RESPONSIBILITY At Walmart de México y Centroamérica we have 9 Principles of Social Responsibility: 1. Acting with ethics and integrity. Walmart de México’s sustainability is based on integrity and our basic beliefs of respect for the individual, customer service and striving for excellence. We guide our behavior and protect our associates through the Statement of Ethics and good corporate governance practices Social Responsibility INTEGRITY 2. Striving to develop and improve the quality of life of our associates Striving for excellence in our associates is one of our strategic priorities. Driving their growth and development by promoting leadership in everyone is part of our day-to-day tasks, where respect for human dignity prevails, regardless of a person’s gender or social condition. 3. Being efficient in all our operations to achieve low prices for our customers Our value proposition is to offer quality merchandise, with good assortment and service, and Every Day Low Prices for customers and members in the furthest places in the country. The increase in our customers’ purchasing power and the drive to better the welfare of their families will continue to be strengthened, working hand in hand with suppliers and associates, making our operations more efficient and our distribution network responsible for our customers to be able to save money and live better. 4. Investing in Mexico As a Mexican company who opened its first store more than 50 years ago, we are committed to the country’s development by constantly reinvesting our profits in Mexico for the opening of new stores, resulting in the creation of permanent jobs, driving development in the location and by simplifying trading terms, which in turn allow us to bring our value proposition to more families. 5. Driving competitiveness of our suppliers We develop initiatives to drive the growth of our Business Partners, who are already a part of our value chain, especially Small and Medium-sized Enterprises (SMEs), through programs that allow them to strengthen their competitiveness. Furthermore to foster the procurement and growth of national industries, we are trying to add new local suppliers to our supply chain who always seek to improve their own quality and share our beliefs and values. 6. Privileging innovation Walmart de México is and will continue to be a company that anticipates customer needs, continuously improving the quality of services and products, all distribution systems and any other action required to benefit customers, associates, suppliers and, of course, the communities we serve. 7. Supporting sustainable nourishment and development of less-favored communities Since 2003, the Walmart de México Foundation took upon itself the commitment to to fight hunger and promote the development of less-favored communities through projects that improve their income and quality of life, by working with several institutions such as Food Banks. 8. Promoting volunteer work amongst our associates Social Responsibility INTEGRITY Walmart de México has one of the largest volunteer programs in the country. Year after year, more associates participate in the efforts programmed by the Walmart de México Foundation to help improve nourishment for those who need it the most. 9. Committed to caring for and preserving the environment Walmart de México has set clear goals for 2025: 100% power supply from renewable sources, zero-discharge of water contaminants, zero residues, and a catalog of sustainable products. ETHICS AND INTEGRITY Walmart de México’s (“Walmart”) is founded upon principles which have led to its many successes. One of Walmart’s most important values and basis for its culture is integrity; ethics forms a part of day to day work processes and as the company has grown, its values has served as a crucial base. Based on the foregoing, Walmart has a compliance program which is based on its fundamental values and highlights that it is crucial for associates and businesses to always act with transparency. This program enables the company to protect itself from legal and regulatory risks, financial losses or reputational harm resulting from a failure to comply with applicable laws, rules and regulations. CODE OF OF ETHICS Walmart’s governance processes include diverse elements to combat bribery and corruption and ensure ethical conduct. Specifically, Walmart has developed a strong code of conduct, known as the Statement of Ethics, which states that Walmart does not tolerate unethical behavior, of any kind, from anyone associated or affiliated with it; including associates, agents, shareholders, suppliers, consultants and other representatives. The Statement contains important guidelines, further supporting its principles. Several of the Statement’s key sections are summarized below. Moreover, a separate Anti-Corruption Policy exists which includes responsibilities, guidelines and prohibitions aimed at preventing corruption, bribery and upholding the highest ethical standards. The area of Ethics and Compliance Committee serves on the boards of Beginning and End of Year, where a message of Compliance and Ethical Culture, including Anti-Corruption Policy, is given to the Management team of all business. Both the Statement of Ethics and the Anti-Corruption Policy specifically prohibit corrupt payments of any kind, as well as, giving and receiving bribes or gifts; whether to or from the public or the private sector, thereby exceeding applicable legal standards. Also, both documents establish an expectation that all direct, affiliated and/or third parties know about and follow the requirements detailed in the policies. Both documents Social Responsibility INTEGRITY declare that disciplinary action will be taken, up to and including termination, if someone is discovered to be violating said policies or applicable laws and regulations. The Statement of Ethics includes the company’s Gift Policy. This Policy explains that Walmart’s culture requires that its associates never accept gifts or objects of value from a supplier, potential supplier, public official, candidate for public office or any other associated person who may seek to influence business decisions or commercial transactions. An established and transparent process also exists for authorizing donations. This process occurs under the supervision of executives involved in the process. Associates are prohibited from making political contributions in Walmart’s name and from conducting political activities during work hours and on Walmart’s premises. Among the previously mentioned controls for combating bribery, mitigating risks and ensuring ethical standards, systems and procedures exist for: due diligence on third parties, seeking appointment to act on behalf of Walmart before government entities and payments to agents and other third parties. Risk assessment processes exist to identify risks inherent to business operations and to establish action plans for mitigating such risks. Internal audit independently verifies the anti-corruption program and the Audit Committee is required to assess and report on the company’s anti-corruption controls, among other matters. The Statement of Ethics provides several escalation mechanisms for reporting ethical and other concerns, including, an anonymous free 1-800 hotline. Another reporting mechanism is a worldwide Hotline, which is attended by a third party provider, equipped to attend calls in various languages. This Hotline is available 24 hours a day. The Ethics Office maintains records of ethics reports, supervises investigations, action plans and sanctions processes; all of which follow strict standards of confidentiality. Additionally, the Statement contains a provision prohibiting retaliation against employees who report such information. The Statement is reviewed annually. Training and awareness are considered key elements for maintaining high ethical standards and preventing corruption. Participation in live and web-based trainings is required for associates and other affiliates. Constant communication with the different business formats and associates, via talks and meetings to review key policies and risk mitigation activities, forms a part of the basic compliance strategy. The Statement of Ethics is provided to each new associate, along with a required training. Each associate is required to electronically affirm his/her commitment to following it at all times. All executives receive an in person lecture regarding the Social Responsibility INTEGRITY Statement, sign a letter promising to comply with it and are required to annually fill out a questionnaire for disclosing possible conflicts of interest with the company. The Walmart Board of Directors’ structure and responsibilities, the Declaration of Ethics and all business activities are governed by best practices in corporate governance; transparency and integrity for shareholders and interest groups. The Executive Committee meets at set intervals through out the year and is comprised of ten members; three of which are independent from the company. The Board of Directors supports the Executive Committee, the Audit Committee and the Business Practices Committee. COMMUNICATION WITH ASSOCIATES We have established confidential channels of communication for use by our associates, so they may be heard and may find alternatives to solving their questions, expressing concerns or suggestions, with the guarantee of confidentiality. Some of these programs include: Open-door Policy A mechanism devised to allow the associate to be heard by the immediate supervisor. Should the associate in question feel he/she cannot speak to the immediate supervisor, then the following level of report or any executive may be approached. Associate Hotline Walmart has a call center whose purpose is to listen to the associates. Reports can be made regarding incidents, congratulations, abuses, harassment, etc. The department is obligated to then conduct an investigation into each of the cases and issue a decision or recommendation for each report received. Associates may contact the Hotline via telephone, email, conventional mail and/or in person. Ethics and Compliance All associates must read and sign the Statement of Ethics that governs our behavior and protects our associates. If any associate is found in violation of the law, a report must immediately be filed with the Manger, with the Ethics and Compliance Committee, with the Global Ethics Office, or with the local Ethics and Compliance Office. Human Resources Since the Walmart culture includes listening to our fellow associates, the People Division also serves as the area in charge of listening to and advising our associates so as to be in a position to make the right decision. Each area and department of the People Division must act as a formal channel of communication within the company. An Associates’ Opinion Survey is conducted each year to help measure the Social Responsibility INTEGRITY organizational climate of the organization. The score reached with the survey is broken down by area and by total company. We focus on five primary behaviors and the five top areas of opportunity detected so as to develop specific action plans by area, but without overlooking other elements. Said action plan is then put into place, with constant progress reports analyzed throughout the year. 2009 STATISTICS Corruption T he company follows the highest ethical standards and has no knowledge of any act of corruption. 100% of the units are analyzed for corruption-related risks. The Statement of Ethics sets forth that corruption may be grounds for termination Walmart’s Global Ethics Award was granted to one of our associates by showing extraordinary ethical courage under risky circumstances Public Policies and Lobbying We carry out public participation activities through different national and local Chambers of Commerce. We also have recognized firms that follow our corporate governance and integrity policies We do not make donations to political parties or related institutions, thus there have not been any actions in this regard Competition No anti-trust or unfair trade activities have been incurred. Competition applicable legislation is followed Legal There is no record of penalties, significant fines or non-monetary penalties