From Compliance to Commitment: The Way We Work at Walmart

Daniel Trujillo, Chief Ethics & Compliance Officer Walmart International, Wal-Mart Stores, Inc., USA

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.

Read full paper Subscribe to the IICJ
USA Compliance Retail March 2018 Vol.11, No. 42, Winter 2018

Daniel Trujillo

More

Daniel Trujillo is the Senior Vice President and Chief Ethics & Compliance Officer for Walmart International. He joined Walmart in 2012, leading a rapidly expanding division that spans over 27 countries outside the United States. In his role, Daniel supports Walmart’s organization that includes over 1,900 compliance and ethics professionals spread across the world managing 14 different subject matters. In 2014, he was featured on the cover of Corporate Counsel magazine in an article that discussed his focus on integrating technology and efficiency into compliance programs. Daniel has also been named several times to Ethisphere’s list of Attorney’s Who Matter. In addition to several speaking roles, he has authored a number of articles on developing and implementing risk-based compliance programs using empirical data, including how to use statistics and analytics to forecast compliance risk—the so-called “Moneyball” approach to compliance. Originally from Argentina, Daniel speaks five languages and has worked in over 60 countries on five continents—addressing compliance areas ranging from anti-corruption to trade. Before joining Walmart, he served as Deputy General Counsel and Director of Compliance at Schlumberger Ltd.—a global supplier of technology, integrated project management, and information solutions for customers working in the oil and gas industry. During Daniel’s 15-year tenure at Schlumberger, in addition to oversight of the compliance program, he worked in numerous legal and compliance roles providing advice on international operations and mergers and acquisitions. He previously worked at Cargill and Impregilo S.p.A. Daniel graduated from Buenos Aires University Law School and went on to complete a Master in Business Administration (MBA) at Salvador University (Argentina) and Deusto (Spain), as well as a Master in International Commercial Law (LLM) at University of California, Davis. In his free time, Daniel enjoys travelling with his wife Deborah and their two young children. He is also an avid triathlete, participating in several races per year.

Wal-Mart Stores, Inc.

More

As a Fortune #1 company, Walmart operates under nearly 60 different banners around the world, including eCommerce sites, and has more than 11,600 stores and clubs in 28 countries. The company opened its first international location in Mexico City in 1991 and launched Walmart.com in 2000. Walmart helps people around the world save money and live better—anytime and anywhere—in retail stores, online, and through their mobile devices. Each week, over 260 million customers and members visit Walmart's stores and eCommerce websites. With fiscal year 2017 revenue of $485.9 billion, Walmart employs approximately 2.3 million associates worldwide. Walmart continues to be a leader in sustainability, corporate philanthropy, and employment opportunity.

USA Compliance Retail March 2018 Vol.11, No. 42, Winter 2018
False