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Benchmarking Alert: Here's Walmart's full global anti-corruption policy


7:48 am
In June 2019, Walmart paid the DOJ and SEC $282 million to settle allegations that it violated the FCPA by paying an intermediary in Brazil for help obtaining construction permits and having weak anti-corruption internal controls in Brazil, China, India, and Mexico. How does its three-page anti-corruption policy compare?
1. It’s global. 
To effectively implement this policy, Walmart shall maintain an effective risk-based Global Anti-Corruption Program (the “Program”) designed to prevent, detect, and remediate bribery and recordkeeping violations. As part of the program, Walmart shall adopt operating procedures specifically targeted to the corruption risks that exist for all of its operations, worldwide. ....

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