Our Global Ethics & Compliance program is led by our Global Chief Ethics & Compliance Officer (CECO) who reports to the company’s Executive Vice President of Global Governance and Corporate Secretary. The CECO also provides regular updates to the audit committee of Walmart’s board of directors. The board of directors plays a critical and active role in overseeing the company’s ethics and compliance program. In addition to receiving a regular flow of information about ethics and compliance issues, each year the audit committee and the compensation and management development committee establish goals and metrics relating to ethics and compliance. The board assigns these goals to relevant executives and business units and establishes accountability for achieving adequate progress on the goals.
Our ethics and compliance efforts in our U.S. retail operations, our U.S. eCommerce business, and our International operations are each led by a Senior Vice President, CECO. These CECOs lead dedicated teams of ethics and compliance personnel, accounting for more than 2,000 associates worldwide. Each international market’s Ethics & Compliance program is led by a market CECO with direct reporting lines back to our company’s home office in Bentonville, providing increased transparency, consistency, and accountability. Market CECOs also sit on the leadership team of their local business, enabling a close relationship to and influence in local operations.
Ethics & Compliance Committees
We have ethics and compliance committees comprised of members of management at the global level and in each of our retail markets. Walmart’s most senior executives are members of the company’s Ethics, Compliance, and Risk Committee. That committee meets regularly to discuss current issues related to ethics, compliance, and other enterprise-level risks, with meetings structured to ensure follow-up and accountability for action items. Each of Walmart’s retail markets has its own similar committee consisting of the market’s senior management and its ethics and compliance leaders, including both the market CEO and the market CECO.
Our Program Building Blocks
The six basic building blocks of our global program help keep us consistent and responsive as our business and the external environment change:
- Risk Assessment
- Standards and Controls
- Monitoring and Response
We regularly evaluate whether we have the right leaders for each aspect of our program:
- Those leaders conduct an assessment of the company’s risks and measures for managing them
- The results of that assessment inform the continual development of our standards and controls
- We make our associates aware of those standards and controls
- We provide training for our associates on how to implement and use those standards and controls
- We continually monitor and assess the execution of our program to provide data for making informed decisions