working with hr to implement an effective compliance ... · global chief ethics officer...
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Working with HR to Implement an Effective Compliance & Ethics ProgramTracy Harlow, Sr. DirectorCommunication & Education
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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 doCommon Operating
Principles
How we do itOur Culture-Beliefs
& Behaviors
Why wedo 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 OrganizationOur 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
Case Management
Communication and Education
Global Ethics Governance
Market Operations
• Analytics
• Regulatory Tracking
• Auditing & Monitoring
• Training & Development
• Ensuring consistent global messaging and education
• walmartethics.com and digital platforms
• Day-to-day oversight of case load and investigation management
• Ensure consistency of results of investigations
• Integrated Culture
• Program implementation and optimization
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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
Track completion & compliance
metrics
Prepare Ed & Comm progress
reports for market stakeholders
Measurement
Assess associate Ethics knowledge
Feedback loop for modifying
programs
Validation
Ensure consistent execution of
program
Identify gaps & recommendations
Learning
Implement international
learning management
system
Business adoption of system for training &
communication programs
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Global Chief Compliance Officer
International Chief Compliance Officer
Global Anti-Corruption
Compliance Officer
U.S. Chief Compliance
Officer
Global eCommerce & Leverage Chief
Compliance Officer
Responsible Sourcing Vice
President
EMEA
CCOU.S.
U.S., China, Brazil eCommmerce and all
Leverage locations globally
Asia CCO
LatamCCO
All retail and sourcing markets
U.S. (5,000 + stores and clubs)
eCommerce and Leverage operations
All retail and sourcing markets
All international markets (6,400+ stores)
Global Compliance Structure – Where We’ve Been
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Global Chief Ethics Officer
International/Regional Chief
Ethics Officers
U.S. Chief Ethics Officer
Global eCommerce & Leverage Chief
Ethics Officer
EMEA EO
U.S.U.S, China, Brazil
eCommmerce and all Leverage locations
globally
Asia EO
LatamEO
U.S. (5,000 + stores and clubs)
eCommerce and Leverage
operations
All international markets (6,400+ stores)
Global Ethics Structure – Where We’ve Been
Global EthicsCommunication &
Education
Enterprise-wide
Global EthicsGovernance
Enterprise-wide
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Global Chief Ethics & Compliance Officer
U.S. Chief Ethics &
Compliance Officer
Global eComm & Leverage
Chief Ethics & Compliance
Officer
Responsible Sourcing
Vice President
Global Ethics & Compliance Structure –Where We’re Headed
Global Systems & Analytics
Vice President
Global Anti-Corruption
Officer
International Chief
Ethics & Compliance
Officer
Global Ethics &
Compliance Administratio
n Vice President