Walmart is one of the largest and most successful retail companies in the world, with operations in 27 countries and more than 2.2 million associates. Walmart’s mission is to save people money so they can live better, and its vision is to be the most trusted retailer. To achieve this, Walmart strives to do business the right way, by setting high standards of ethics and compliance for itself and its suppliers.
However, doing business ethically is not always easy, especially in countries where corruption and bribery are prevalent. This was the case for Walmart in Mexico, where it faced allegations of paying millions of dollars in bribes to local officials to obtain permits and favors for its expansion in the country. The scandal was exposed by The New York Times in 2012, and it triggered a series of investigations and lawsuits by the U.S. authorities and shareholders.
In this blog post, we will explore how Walmart has responded to the allegations, how it has improved its ethics and compliance program, and how it has been recognized for its efforts to build trust in its Mexican operations.
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Walmart’s Response to the Allegations
Walmart admitted to violating the Foreign Corrupt Practices Act (FCPA), which prohibits U.S. companies from bribing foreign officials, and agreed to pay $282 million to settle the charges in 2019. Walmart also agreed to enhance its anti-corruption compliance program and to retain an independent corporate monitor for two years.
Walmart’s CEO Doug McMillon said in a statement: “We’re pleased to resolve this matter. Walmart is committed to doing business the right way, and that means acting ethically everywhere we operate. We’ve enhanced our policies, procedures and systems and invested tremendous resources globally into ethics and compliance, and now have a strong Global Anti-Corruption Compliance Program. We want to be the most trusted retailer, and a key to this is maintaining our culture of integrity.”
Walmart cooperated with the U.S. Department of Justice and the Securities and Exchange Commission throughout the investigation and provided them with extensive information and access to witnesses. Walmart also conducted an internal investigation into the allegations and took action against several associates involved in the misconduct.
Walmart’s Improvements to its Ethics and Compliance Program
Since 2012, Walmart has made significant improvements to its ethics and compliance program, both globally and in Mexico. Some of these improvements include:
- Strengthening its anti-corruption controls, such as conducting risk assessments, implementing due diligence processes, and monitoring transactions and third parties.
- Training its associates on FCPA compliance, ethics and values, and providing them with resources and tools to report any concerns or issues.
- Implementing a global helpline that allows associates, suppliers, customers and stakeholders to report any violations of Walmart’s Code of Conduct or policies anonymously and without fear of retaliation.
- Enhancing its oversight and accountability mechanisms, such as appointing regional ethics officers, conducting audits and reviews, and imposing disciplinary actions for misconduct.
- Working with its suppliers to ensure they comply with Walmart’s Standards for Suppliers, which cover various aspects of responsible sourcing, such as labor rights, environmental protection, product safety and quality, and anti-corruption.
- Collaborating with industry experts, NGOs, government agencies and other stakeholders to address systemic challenges in the retail supply chains and promote best practices.
Walmart’s Global Ethics & Compliance Program is led by Daniel Trujillo, Executive Vice President & Global Chief Ethics & Compliance Officer. He reports directly to Walmart’s CEO Doug McMillon and the Audit Committee of the Board of Directors. He oversees a team of more than 2,300 associates who are responsible for implementing Walmart’s ethics and compliance policies across all markets.
Walmart’s Code of Conduct is the foundation of its ethics and compliance program. It describes the values, principles and expected behaviors that guide its business decisions. It applies to all associates of Walmart and its subsidiaries worldwide. It also sets expectations for suppliers, contractors, consultants, agents and other third parties who do business with Walmart.
Walmart’s Code of Conduct is based on four core values: respect for the individual, service to the customer, strive for excellence and act with integrity. These values are reflected in the following principles:
- Lead with integrity
- Follow the law at all times
- Be honest & fair
- Respect others & promote diversity
- Protect our assets & information
- Be responsible stewards
- Speak up
Walmart provides regular training on its Code of Conduct and other ethics and compliance topics to all associates, especially those in high-risk positions or locations.