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:

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

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