Key Events in Walmart Anti-Corruption Compliance

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1. We are committed to having a strong and effective global anti-corruption program in every country in which we operate.

2. Over the last few years, we have implemented a series of changes to our U.S. Foreign Corrupt Practices Act (FCPA) compliance programs. This work is ongoing and continues today.

3. As part of that effort, in the spring of 2011, we initiated a worldwide review of our anti-corruption programs. We are taking a deep look at our policies and procedures in every country in which we operate. This includes developing recommendations for FCPA training, anti-corruption safeguards, and internal controls.

4. Consistent with these efforts, with the assistance of outside attorneys and consultants, the Company has developed enhanced FCPA anti-corruption compliance programs for every market around the world in which the Company operates, some of which have already gone online and others which will continue to be implemented over the next few months. The enhanced anti-corruption compliance programs include robust policies and procedures, internal controls, training, enhanced auditing procedures and issue escalation and remediation protocols, which are designed to meet or exceed current expectations of federal law enforcement agencies.

5. Over the past 15 years, Walmart has worked to revise and improve its anti-corruption policies and procedures to promote high ethical standards of its associates doing business in international markets throughout the world.

6. Starting in 1996, Walmart’s Statement of Ethics included a provision relating to compliance with the Foreign Corrupt Practices Act (“FCPA”).

7. In 2001, Walmart revised its Statement of Ethics to provide additional guidance regarding the FCPA and further instructions regarding facilitation payments.

8. In 2003, Walmart started the process of developing a comprehensive Anti-Corruption Policy to apply to all international markets in which it operated.

9. Walmart took many specific steps in 2004 to strengthen its international compliance efforts:

  • Created a U.S. Corporate Compliance Department.
  • Formed a Compliance Oversight Committee.
  • Provided FCPA training to Walmart International Senior Executives and International Subsidiary Country Presidents.
  • Formed a Global Ethics Office.
  • Revised the Statement of Ethics; expanded the sections relating to the FCPA.
  • Instituted an International Anti-Corruption Policy.
  • Provided FCPA training to Walmart International CFOs and General Counsels.

10. Then in 2005, Walmart published an International Anti-Corruption Policy and Procedures Guide and provided additional FCPA training to its key associates.

11. In 2007, Walmart undertook a substantial effort to revise and improve its Anti-Corruption Policies and Procedures. The revised Global Anti-Corruption Policy was rolled out with education and training sessions both in Bentonville and in the international markets.

12. For several years, Walmart has aimed to provide Statement of Ethics training to all newly-hired Walmart associates in the United States, to reinforce the high ethical standards required by Walmart in conducting all business. Since 2009, Walmart has aimed to provide Statement of Ethics training to as many newly-hired associates in Walmart international subsidiaries as possible.

13. The Walmart Statement of Ethics was updated once again in 2008, including updates to the specific “Anti-Corruption” section.

14. In 2008, Walmart also published its most detailed Global Anti-Corruption Policy and Procedures Guide to date and created an Office of International Compliance.

15. By 2009, Walmart had instituted a centralized approach to anti-corruption compliance, but the Company’s size and scale made it necessary for each international subsidiary to take greater responsibility over these issues.

16. In 2009, Walmart provided a clear global framework of principles and required elements while also requiring each market to develop specific strategies for implementation. In other words, the Company mandated that every Walmart international subsidiary follow one general company-wide global anti-corruption standard. Under the revised approach, each international subsidiary was required to prepare, implement and execute policies, procedures and related controls in their market to meet Walmart’s global standard.

17. In 2010, the Walmart Office of International Compliance assessed the compliance controls in international markets in which Walmart operates. This six-month assessment process included anti-corruption risks.

18. The information derived in the worldwide regulatory assessments resulted in an amended Global Anti-Corruption Policy in late 2010. In contrast to the 2008 Anti-Corruption Policy, the revised 2010 policy provided that each Walmart international subsidiary was tasked with responsibility for implementation of anti-corruption policies and procedures.

19. The 2010 policy provided:

  • We do not tolerate, permit, or engage in bribery, corruption, or unethical practices of any kind.
  • Bribery of public officials in the U.S. and abroad is illegal under both U.S. law and the local law of the countries in which we operate.
  • Walmart’s policy goes beyond these legal requirements and prohibits corrupt payments in all circumstances, whether in dealings with public officials or individuals in the private sector.
  • Specifically, the Global Anti-Corruption Policy prohibits us from paying, promising, offering, or authorizing a payment of, directly, indirectly, or through a third party, money or anything of value to a government official or political party for the purpose of influencing an official act or decision in order to obtain or retain business or secure an improper advantage.
  • Even when local practices or customs allow behavior that violates our Anti-Corruption Policy it is not acceptable for us to do so.

20. In March 2011, Walmart consulted with outside advisors to improve and refine its worldwide anti-corruption program. Walmart retained Greenberg Traurig and KPMG to conduct an outside review to evaluate the Company’s FCPA program and Anti-Corruption Policies and Procedures worldwide. That review is currently ongoing in every market in which Walmart operates.