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
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
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
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
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
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
The Hotline 20 13 Global Ethics Office Recognition program 17 14 Global Ethics Office 7
Communication and Training 17 15 Global Ethics Office Monitoring and auditing 19 16 Global Ethics Office 8
Enforcement and Oversight 19 17 Global Ethics Office Risk Assessments 20 18 Global Ethics Office 9
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
19 21 Global Ethics Office A question about gifts and entertainment 22 Global Ethics Office 11
20 23 Global Ethics Office Global Ethics Office Information & Contact Options Statement of Ethics Walmartstores.com/ethics Contact options Walmartethics.com 800-WM-ETHIC ethics@wal-mart.com Mauri Myers Mauri.myers@wal-mart.com 479-277-2330 24 Global Ethics Office 12
Walmart Compliance Contact Information Contact Options 1-800-Walmart (9256278) www.walmartstores.com Kirstie Sims Operations Compliance Director Office 770-690-3058 kirstie.barnes@wal-mart.com 25 Global Ethics Office Questions? 26 Global Ethics Office 13