Global Compliance Program Report on Fiscal Year 2014


Compliance policies cannot work well without effective training.

Building a World-Class Compliance Program

A global helpline, in place for many years, ensures every Walmart associate has access to report ethics concerns. This is publicized widely through facility posters and on a website available in 14 languages and accessible globally, walmartethics.

In addition, the Everyday Integrity Link broadcast and Leadership Speaks Series gave associates at least two opportunities to hear local and corporate, senior leaders discuss the importance of integrity. In Fiscal Walmart associates that displayed exceptional levels of integrity were recognized by the company for their achievements.

The purpose of these global and market-level committees is to provide a regular opportunity for the senior management of each business unit to discuss current issues relating to integrity and compliance, to assign responsibility for improvements and review progress on past assignments, and to ensure appropriate accountability.

In Fiscal , the company will continue to develop additional standards and controls to ensure consistent application of compliance principles across all retail markets. In Fiscal , Walmart continued to develop and enhance its market-specific anti-corruption procedures tied to this global policy. Among other issues, these enhancements related to: Over the year, Walmart also continued to evaluate and improve the financial controls in its International retail markets using a team of internal personnel and external consultants.

For example, during the year the company installed or amended financial controls for non-merchandise disbursements, employee expense reimbursements, and the sale of gift cards. Walmart also improved its in-market and corporate monitoring and reporting, including key control reporting, self-assessments, and certifications, to evaluate the effectiveness of its enhanced financial controls. Recognizing fire safety as one of its top health and safety priorities, over the past year the company created and carried out a plan to conduct fire safety reviews in four international retail markets.

These reviews were headed by the new global health and safety Subject Matter Leader and international Subject Matter Expert. Following these reviews, each of these markets worked collaboratively with the global and international experts to establish new processes and controls, improve store infrastructure, and evaluate future fire monitoring plans.

Walmart has been a longstanding leader in complying with state and federal firearms laws. In Fiscal , the company continued to improve its ATF program by implementing a mandatory certification program for associates in the U.

Collectively these changes are intended to ensure that the individuals who serve our customers are trained on the appropriate legal requirements and safety issues. In addition to these improvements to staffing procedures and training, in Fiscal Walmart developed and began to use an enhanced electronic transaction system for firearms sales. This electronic transaction system seeks to reduce the potential for errors in the process of collecting and processing required data such as obtaining buyer signatures, recording transaction dates, and conducting background checks.

The electronic system requires that ATF procedures be followed and before a sale will close, which has reduced the error rate associated with manual completion of paper forms. In Fiscal , the company advanced that goal by:. Conducting a study of state-specific billing code requirements in the U. The company also conducted an analysis of the processes previously used in each International market to identify and apply for required licenses and permits.

Regulators in the U. K and elsewhere have stated that periodic risk assessments are essential to developing a risk-based compliance program. In Fiscal Walmart conducted formal compliance risk assessments in all of its retail markets and in an international procurement and logistics subsidiary. The company is utilizing the information obtained in these risk assessments to create a new list of prioritized compliance enhancements for Fiscal Systems and technology increase the effectiveness of a compliance program and reduce the burden associated with manual processes.

The purpose of the assessment was to identify opportunities to leverage global compliance technologies and move toward common systems in order to enhance the efficiency and consistency of the global compliance program.

Following this assessment, the company developed a Global Compliance Systems Roadmap, which focuses on deploying a set of core technologies across all markets, complemented with local specialized solutions where necessary. In the second half of Fiscal , the company began deploying these core technologies in some International markets, with plans to continue this deployment.

These databases help to expose some potential relationships between TPIs and foreign governments, identify whether the TPI has been subjected to certain government sanctions, and reveal adverse media stories about the TPI. These are only some examples of the improvements Walmart made to its global compliance program in Fiscal The company is creating a similar prioritized list of compliance-related enhancements for Fiscal , which will be subject to approval and oversight by the Audit Committee.

The efforts outlined here are designed to earn and keep the trust of customers, associates, investors and the public. Building a World-Class Compliance Program Since the first Walmart store opened its doors to the public in , the company has been dedicated to making a difference in the lives of its customers.

Improved Training Compliance policies cannot work well without effective training. Anti-Corruption Anti-corruption remains a key focus for compliance training in all markets. Enhanced Communication Channels During the year the company made a number of improvements to existing communication channels to provide more regular and effective compliance communications.

Assessments of anti-corruption compliance risks; Due diligence on third parties who interact with government officials; Processes and anti-corruption-related contractual provisions for engaging third parties and business partners; Business expenditures e.

Alcohol, Tobacco, and Firearms ATF Walmart has been a longstanding leader in complying with state and federal firearms laws.

In Fiscal , the company advanced that goal by: Developing the ability to print Braille labels for mail-order prescriptions in the U. After all, as anyone who's been paying attention can tell you, Walmart rarely fails in these endeavors. Because America and Europe share similar cultural and political antecedents, one might naturally assume that an American enterprise would have a better chance of succeeding in Europe than in Asia.

But the German smackdown proved that's not always the case. Indeed, while the nominal Communist regime of the People's Republic of China embraced Walmart's corporate philosophy, the Germans rejected it. Though no one can say precisely why the venture failed, there's been no shortage of explanations.

One is that Germany was too "green" for a slash-and-burn outfit like Walmart, with its plastic bags and plastic junk Another is that Walmart couldn't hack the pro-labor union culture of Germany. Another is that Germany is anti-American when it comes to name-brand retailers even though Dunkin' Donuts and Starbucks are popular there.

Another is that German consumers prefer small neighborhood stores rather than impersonal chain even though Aldi, a discount supermarket chain, is successful. While there is probably some validity to all of these explanations, three additional cross-cultural idiosyncrasies have been identified as determining factors. One issue was the chanting. Walmart employees are required to start their shifts by engaging in group chants and stretching exercises, a practice intended to build morale and instill loyalty.

Unfortunately, this form of corporate boosterism didn't go over particularly well with the Germans. Maybe they found it embarrassing or silly; maybe they found it too regimented. Or maybe they found this oddly aggressive, mindless and exuberant exercise in group-think too reminiscent of other rallies Another issue was the smiling. Walmart requires its checkout people to flash smiles at customers after bagging their purchases.