From Compliance to Commitment: The Way We Work at Walmart

Abstract

Walmart was my first introduction to the retail business. Before moving from Houston, Texas, to Bentonville, Arkansas, I spent the prior twenty years working for other large corporations in different industries around the globe (e.g., the largest civil construction firm, an oilfield services giant, and the largest privately held company). With over 2.2 million employees, Walmart made the others look small by comparison. My first task at Walmart was to enhance my understanding of the retail business. I learned early in my career that a key ingredient to designing a successful ethics and compliance program is developing a deep understanding of the business and company culture. I had experienced Walmart as a customer and followed the company’s tremendous success and growth, but I needed to understand what makes the world’s largest multi-channel business tick. For any new chief ethics and compliance officer (“CECO”), this background knowledge becomes part of the roadmap for integrating the program. If you do not understand the business, you cannot help the company embed the program in a way that allows ethics and compliance to become part of the way the business works. By using this approach, the ethics and compliance program remains focused on satisfying all the regulatory requirements, while working for and with the business, identifying ways to add value and speed, and doing the right thing and protecting our shareholders. This article outlines a few lessons I picked up in my twenty years working in compliance.