Our Values Live Our Code Build Trust with Our Associates Build Trust with Our Customers and Members
Build Trust in Our Business
Never Engage in Bribery
We never bribe.
Bribery involves receiving, paying, authorizing, offering, or promising money or
anything of value to improperly influence any act or decision or to gain an
improper advantage to obtain or retain business. Bribes can take many forms,
including cash, gifts, travel, meals, entertainment, offers of employment, and
charitable or political contributions.
For us, it is simple, bribery—of anyone, anywhere, at any level—is not allowed. This
applies to all associates and any third party working on our behalf. If you are asked
for or offered a bribe, refuse it and immediately report it to
Ethics
.
Know and follow anti-corruption laws, our
Global Anti-Corruption Policy
, and all
local anti-corruption compliance and giving procedures.
Remember
You must immediately report any bribery concerns to
Ethics
.
!
What if?
Police officers have stopped trucks leaving our distribution center and demanded $50 to avoid
delivery delays. My manager suggested carrying $50 gift cards to pay the officers. Is this allowed?
No. We do not allow any bribes to influence government officials, including police officers. This
includes cash payments and other items of value, such as gift cards. Report this immediately to
Ethics
.
A new store opening is waiting on an operating license. A government official requested we
hire a company that will “take care of it”. Is this allowed?
No. We do not hire third parties at the government’s request or allow any bribes to influence
government officials. This also applies to any person or third party acting on our behalf. Report
this immediately to
Ethics
.
Compete Fairly
We believe success comes from offering quality products and services at low
prices. Effective competition leads to stronger innovation, lower prices, and better
quality, while anticompetitive practices harm our customers and members. Build
trust by:
•
Protecting and not sharing competitively sensitive information – such as pricing,
costs, bid submissions, or strategic plans – with competitors, either directly or
through a third party, such as a supplier.
•
Not reaching agreements with competitors or others that limit competition. For
example, do not agree with a competitor on prices, assortment, margins,
promotions, or other terms, and never agree to divide up products, customers or
members, or markets we serve.
•
Stopping conversations if competitively sensitive information or an improper
agreement comes up. Make it clear you do not want to participate and report the
incident to
Ethics
or Legal.
Follow all competition laws, local policies, and our
Global Antitrust & Competition
Law Policy
.
14