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Corporate Governance

Ethics and Compliance program

SPAENG

Ethics and
Compliance
program

Walmart de México y Centroamérica is committed to doing what is right and acting with integrity in everything we do. It is a fundamental part of who we are and the foundations over which we build our success.

We have a dynamic and effective Ethics and Compliance program designed to prevent, detect, and act on any non-compliance regarding legislation in-force and applicable policies and procedures. This program establishes the guidelines that each and every associate must follow to act correctly and in keeping with the values and fundamental principles of the Company.

We have a full time CECO –Chief Ethics & Compliance Officer– who oversees a dedicated team of ethics and compliance personnel.

Defining the Ethics & Compliance Scope

14 global compliance subject areas

    Anticorruption

    Antitrust

    International Trade

    Licenses & Permits

    Responsible Sourcing

    Environment

    Anti-Money Laundering

    Privacy

    Consumer Protection

    Labor & Employment

    Health & Wellness

    Health & Safety

    Food Safety

    Product Safety

Ethics standards and processes

  • Global Statement of Ethics

  • Multiple reporting mechanisms in local languages

  • Advisory function

  • Intake, triage and tracking for allegations

  • Case close-out & remediation

We designed Walmart’s program to manage the compliance risks associated with 14 different subject areas, ranging from anticorruption to food safety. To provide the relevant expertise in each subject area, we designated 14 Global Subject Matter Leaders and installed Subject Matter Experts for each of the 14 risk areas in each retail market. These Subject Matter Leaders and Subject Matter Experts work together to identify and coordinate common standards and procedures, share best practices, and provide training, monitoring, and support in their subjects. They report to their respective CECOs in each of their business units.

Finally, in response to a variety of guidelines provided by governments and private agencies, we developed six basic building blocks of our unified program:

  • Leadership

  • Risk assessment

  • Standards and controls

  • Awareness

  • Training

  • Monitoring and response

This process keeps our Ethics & Compliance program agile and responsive as our business and the external environment change.

These six building blocks
function together in a cycle
that we repeat each year

We evaluate whether we have the right leaders for each aspect of our program

We continually monitor and assess the execution of our program to provide data for making informed decisions

We provide training for our associates on how to implement and use those standards and controls

The results of that
assessment inform the
continual development
of our standards and controls

We make our associates aware of those standards and controls

Those leaders conduct an assessment of the company’s risks and measures for managing them

Anticorruption area is relevant for this Compliance Program. The anticorruption team, which is led by Directors in Mexico and Central America, is charged with developing and executing the principles and processes that are part of the Global Anticorruption Procedure, based on risk analysis. It is also in charge of training our associates as well as third-party intermediaries and commercial partners.

Anticorruption
trained +45,500 associates
and +690 suppliers

G4-SO4

We conducted the proper due diligence of those suppliers who interact with any government agency so as to identify if said suppliers and their primary officers have been directly or indirectly involved could constitute a risk or negative impact for the Company. Said process should be renewed at least every other year. Once approved, the supplier then receives training on the Anticorruption Policy to ensure awareness and that the policy is followed throughout the duration of their commercial relationship with Walmart. G4-SO3

We are committed to maintaining a work atmosphere that encourages our associates to voice any concerns regarding possible violations with our Statement of Ethics, and any repercussions against any associate who presents such concerns are strictly prohibited.

We conducted +29,600 hours in Statement of Ethics training to operations and staff associates, covering 87% and 79%, respectively, in Mexico, in Central America, coverage was 92% and 97%, respectively

G4-HR2, G4-HR7

Reporting mechanisms

Open-Door
Policy

Global Ethics
Hotline

Available 24/7 fully equipped to handle the majority of the local languages spoken

Operated by an
independent organization

There was a
26% increase in cases reported in Mexico, and 20% in Central America

G4-HR3, G4-HR12

14 global compliance subject areas