Ethics and Complaince

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Identify processes that wal-mart uses to comply with SEC regulations-Kunika. The Securities and Exchange Commission (SEC) will not allow Wal-Mart to exclude from consideration an NLPC-sponsored shareholder proposal asking for a report on the company’s lobbying priorities. The subject matter of meetings, conversations, discussions or other communications with Investment Community Members will be limited to explanations or clarifications of publicly available information concerning Wal-Mart, will not discriminate among recipients of information disclosed by Wal-Mart or its representatives based on a recipient’s prior research, opinions, recommendations, earnings estimates or conclusions relating to Wal-Mart. In addition, Wal-Mart will…show more content…
Any planned disclosure of material nonpublic information must be made only at such time and in such manner as to allow for simultaneous public disclosure in accordance with Regulation FD. If Wal-Mart or any “person acting on behalf of Wal-Mart” (as defined in Regulation FD) inadvertently discloses any material nonpublic information to any Investment Community Member, such disclosure must be immediately reported to the Legal Department so that appropriate action may be taken to comply with Regulation FD. Wal-Mart will publish all of its sales releases, earnings releases, earnings scripts, financial webcasts and presentations to Investment Community Members on its web site and will archive such documents on Wal-Mart web site for at least one year. The Annual Meeting for the Investment Community, all or a portion of which will be made available via a live webcast. Wal-Mart will furnish to the SEC and will make each quarterly earnings press release prior to conducting any telephone calls or other communications with the Investment Community to discuss Wal-Mart sales, earnings or other matters disclosed in those press releases. Any Additional Communication will be widely available to the Investment Community through press release, telephonic means, webcast, SEC filing or any combination of the these media. Wal-Mart will publish on its website (http://www.walmartstores.com/) the dates of its quarterly

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