As Walmart’s business has been changing, the company has also evolved and changed in our corporate governance. In 2012, the company started a significant effort to enhance our ethics and compliance programs. Prior to that time the company maintained separate compliance efforts in different countries. For example, Walmart’s business in the United States had a well-developed compliance program. The company had separate compliance-related activities and personnel in our businesses in Canada, China, Mexico, and elsewhere. All of these compliance programs operated independently of each other, reporting to their local business leaders.
Jay T. Jorgensen,
The Foreign Corrupt Practices Act Turns 40: "Reflections on Walmart's Enhanced Ethics & Compliance Program",
Tex. A&M L. Rev.
Available at: https://scholarship.law.tamu.edu/lawreview/vol5/iss1/11