Saving people money. so they can live better. Walmart Ethics vs. Compliance 9/9/2011. Global Presence Retail Market Locations.

Transcription

1 Walmart Ethics vs. Compliance Kirstie Sims, Divisional Compliance Director Mauri Myers, Director, U.S. Ethics Saving people money Image Area so they can live better Global Presence Retail Market Locations Canada U.K. Mexico U.S. China Japan Central America - Costa Rica - El Salvador - Guatemala - Honduras - Nicaragua Chile Brazil Argentina Africa - Botswana - Ghana - Lesotho - Malawi - Mauritius - Mozambique - Namibia India - Nigeria - Swaziland - South Africa - Tanzania - Uganda - Zambia - Zimbabwe 2 Global Ethics Office 1

2 Ethics & Compliance Structure Two organizations Separate reporting structures Partnerships for success 3 Global Ethics Office Global Ethics Office Structure Company Values Focus 4 Global Ethics Office 2

3 Global Ethics Office Structure Global Reporting and Oversight 5 Global Ethics Office Global Ethics Office Structure Board Access Regular reporting to the Audit Committee of the Board of Directors Regular phone calls with the Audit Committee Immediate notification of significant issues Ethics training to the full Board of Directors 6 Global Ethics Office 3

4 Ethics Structure Organizational Structures That Work: Large Company Edition Board of Directors EVP, Global People CEO Audit Committee of Board of Directors Chief Ethics Officer 7 Global Ethics Office Compliance Office Vision Supporting Walmart s business Our role is to protect our by proactively identifying, customers, associates and business mitigating, by ensuring and monitoring regulatory compliance compliance. risks. 8 Global Ethics Office 4

5 Compliance Office Structure Compliance Reporting and Oversight 9 Global Ethics Office Compliance Structure Organizational Structures That Work: Large Company Edition Board of Directors Chief Administration Officer Walmart Stores CEO Sam s Club Audit Committee of Board of Directors Chief Compliance Officer CEO International 10 Global Ethics Office 5

6 Compliance Organizational Structure Home Office based Teams Environmental Health & Safety Product Safety ATF/Weights & Measures Privacy Employment Compliance Licensing Food Safety and Health Financial Services/Global Anti-Money Laundering Compliance Systems and Reporting Field Based Compliance Team Operations support Auditing Mitigation Training 11 Global Ethics Office Program Elements Broken Down How are the various elements of having an effective Ethics & Compliance program broken down between the two organizations? 12 Global Ethics Office 6

7 The Hotline Global Ethics Office Recognition program Global Ethics Office 7

8 Communication and Training Global Ethics Office Monitoring and auditing Global Ethics Office 8

9 Enforcement and Oversight Global Ethics Office Risk Assessments Global Ethics Office 9

10 Digging Deeper: Specific examples of situations and which team would handle the issue 19 Global Ethics Office A confidential information breach 20 Global Ethics Office 10

11 19 21 Global Ethics Office A question about gifts and entertainment 22 Global Ethics Office 11

12 20 23 Global Ethics Office Global Ethics Office Information & Contact Options Statement of Ethics Walmartstores.com/ethics Contact options Walmartethics.com 800-WM-ETHIC Mauri Myers Global Ethics Office 12

13 Walmart Compliance Contact Information Contact Options Walmart ( ) Kirstie Sims Operations Compliance Director Office Global Ethics Office Questions? 26 Global Ethics Office 13