Working with HR to Implement
an Effective Compliance &
Ethics Program
Tracy Harlow, Sr. Director
Communication & Education
1962 – First Walmart opens in
Rogers, Ark.
1972 – Goes public on the New
York Stock Exchange
1983 – First Sam’s Club opens
in Midwest City, Okla.
1988 – First Supercenter opens
in Washington, Mo.
1991 – First international store
opens in Mexico City
2009 – Surpasses $400 billion in
annual sales
2012 – 50th anniversary
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 More than 250
million customer
transactions each
week
 More than 2 million
associates
 11,027 retail units;
71 banners; 27
countries
 $473 billion net
sales FY14
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Our Culture: WHAT and HOW equally important
What we do
How we do it
Common Operating
Principles
Our Culture-Beliefs
& Behaviors
Why we
do it
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Without communication and collaboration
between compliance and HR, the company lacks
a unified view of several processes that are
important to building a strong, ethical culture.
- Compliance Week, April 16, 2013
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Statement of Ethics + HR = Success
The Global Statement of Ethics is our
global policy and resource providing:
clear expectations
acceptable behaviors and conduct
a global policy
reporting channels to raise concerns
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Global Ethics Organization
Our Role
 Model, inspire, and instill a global culture of
ethics
 Provide reporting channels
 Provide training and awareness regarding
ethical expectations
 Provide global consistency to the
management of associate, and certain
supplier/ third party misconduct cases
 Partner to protect Walmart’s brand
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Global Ethics Functions
Communication
and Education
• Day-to-day oversight of
case load and
investigation
management
• Training & Development
• Analytics
• Integrated Culture
• Ensuring consistent
global messaging and
education
• walmartethics.com and
digital platforms
• Regulatory Tracking
• Program implementation
and optimization
• Ensure consistency of
results of investigations
Global Ethics
Governance
Market
Operations
Case
Management
• Auditing & Monitoring
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Communication Programs
 Integrity in Action Award Program
 Posters
 Helpline
 Gifts & Entertainment
 Leadership Messaging Platforms




Tone at the Top
Everyday Integrity Link
Leadership Speaks Series
and other opportunities
 Five-Minute Integrity Focus
 Digital
 Walmartethics.com
 trueNorth
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Education Programs
Tone at
the Top
Leading with Integrity
Acting with Integrity
Statement of Ethics eLearning Module
Orientation
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Global Ethics Performance Team
Reporting
Measurement
Validation
Learning
Track completion
& compliance
metrics
Assess associate
Ethics knowledge
Ensure consistent
execution of
program
Implement
international
learning
management
system
Prepare Ed &
Comm progress
reports for market
stakeholders
Feedback loop
for modifying
programs
Identify gaps &
recommendations
Business
adoption of
system for
training &
communication
programs
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Footer goes here
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THANK YOU!
Tracy Harlow
Tracy.harlow@walmart.com
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APPENDIX
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Global Compliance Structure – Where We’ve Been
Global Chief Compliance Officer
Global AntiCorruption
Compliance
Officer
All retail and
sourcing markets
International Chief
Compliance Officer
U.S. Chief
Compliance
Officer
Global eCommerce
& Leverage Chief
Compliance Officer
Responsible
Sourcing Vice
President
All international markets
(6,400+ stores)
U.S. (5,000 +
stores and clubs)
eCommerce and
Leverage operations
All retail and
sourcing markets
U.S.
U.S., China, Brazil
eCommmerce and all
Leverage locations
globally
EME
A
CCO
Asia
CCO
Latam
CCO
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Global Ethics Structure – Where We’ve Been
Global Chief Ethics Officer
International/Regional
Chief
Ethics Officers
U.S. Chief Ethics
Officer
Global eCommerce
& Leverage Chief
Ethics Officer
All international markets
(6,400+ stores)
U.S. (5,000 +
stores and clubs)
eCommerce and
Leverage
operations
U.S.
U.S, China, Brazil
eCommmerce and all
Leverage locations
globally
EME
A EO
Asia
EO
Latam
EO
Global Ethics
Communication &
Education
Global Ethics
Governance
Enterprise-wide
Enterprise-wide
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Global Ethics & Compliance Structure –
Where We’re Headed
Global Chief Ethics & Compliance Officer
Global AntiCorruption
Officer
International
Chief
Ethics &
Compliance
Officer
U.S. Chief
Ethics &
Compliance
Officer
Global
eComm &
Leverage
Chief Ethics
& Compliance
Officer
Global Ethics
&
Compliance
Administratio
n Vice
President
Responsible
Sourcing
Vice
President
Global
Systems &
Analytics
Vice
President
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