Compliance

U.S. corporate compliance

The right way, every day

Walmart was built on the idea of "Saving people money so they can live better." From environmental issues to employment and workplace safety matters, our compliance team demonstrates commitment to this principle by proactively identifying, monitoring and complying with the regulatory obligations that protect our communities and environment, allowing our associates and customers to live better.

In 2011 alone, we responded to nearly 60,000 compliance-related calls to our hotline and obtained nearly 100,000 operating permits for our U.S. facilities. In addition, we completed nearly 3,100 unannounced internal assessments to monitor and respond to Environmental, OSHA, Food Safety, Privacy, Financial Services and other regulatory requirements. Our proactive involvement and support of our U.S. businesses resulted in fewer inspections with exceptions or regulatory violations.

We work to build a culture of compliance by operating by the motto, "the right way, every day." It is our responsibility as the world's largest retailer to provide both the lowest prices for our customers and safe products in a legal and compliant manner. By providing safe products and operating in a legal and compliant manner, we demonstrate the highest commitment to our customers, associates and the communities in which we operate.

Food safety

At Walmart, food safety is more than a requirement; it is part of our culture. Providing safe and affordable food to our customers is one of the reasons we continue to be successful in an increasingly competitive environment. As leaders in the retail food business, maintaining a progressive and effective food safety management system is a critical part of our continued success.

Global Food Safety Initiative

We take a farm-to-fork approach to food safety, realizing that some risks are best controlled early in the food system. As the world's largest buyer and seller of food with a vast supply base, we realize we have an important obligation to require our suppliers to adhere to stringent food safety standards.

In December 2007, we became the first U.S. retailer to require all private-brand suppliers and select categories of national-brand suppliers to achieve certification against one of the Global Food Safety Initiative's (GSFI) internationally recognized food safety standards, which exceeds Food and Drug Administration (FDA) or United States Department of Agriculture (USDA) requirements. Since the initial rollout, more than 1,000 food manufacturing facilities that provide Walmart U.S. and Sam's Club U.S. private-brand products have achieved certification, and national-brand suppliers of bottled water, produce, meat, seafood, deli and dairy products have certified their factories around the world. In addition, every international market in which Walmart has retail facilities has required all facilities producing private-brand products to become certified against one of the GFSI standards. Walmart's leadership in this area has helped drive global adoption of GFSI standards among thousands of food suppliers worldwide.

Deli meat initiative

In addition to having suppliers demonstrate conformance to strict food safety production standards, Walmart supports research and develops additional food safety requirements that are science-based and commodity-specific.

In October 2010, Walmart became the first U.S. retailer to announce a new requirement for all suppliers of bulk deli meats intended to be sliced in our stores and clubs to include a Listeria inhibitor that will not allow outgrowth of Listeria during the intended shelf life and storage of the product. Although a comprehensive Listeria control program must be multifaceted, including strict sanitation, environmental monitoring and finished product testing, this requirement provides an additional layer of protection for consumers. These same suppliers must still achieve prevention-based certification against one of the Global Food Safety Initiative (GFSI) internationally recognized food safety standards.

Walmart Food Safety High Five

A key strategy to advancing the level of food safety in the markets we operate in around the world is coordination of efforts and collaboration through a Global Food Safety Team. The U.S. and International teams work to harmonize food safety standards worldwide, such as the requirement that all private-brand suppliers, regardless of where they are in the world, obtain certification on one of the Global Food Safety Initiative's recognized food safety standards and the adoption of the Walmart Food Safety High Five in each market.

In 2010, Walmart created the Food Safety High Five, using the International Association for Food Protection's (IAFP) international food safety symbols (with permission) as its basis. The Food Safety High Five are the most important practices an associate must follow to prevent foodborne illness. They are based on the Center for Disease Control's (CDC) most common contributing factors of foodborne diseases and the U.S. Food and Drug Administration's (FDA) retail risk factors.

Food Safety High Five visual concepts are easily understood, regardless of an individual's native language. The concepts are interwoven into many aspects of our global food safety management system, including training, workplace signs and reminders, and serve an important role in our internal food safety checks and audits.

After the implementation of the Food Safety High Five in the U.S., the company experienced an increase in associate recognition of critical behaviors that can impact the safety of foods. This increased understanding has translated into three consecutive years of reduced violation rates and improved compliance as measured by both regulatory and third-party food safety audit performance.


Product safety

Providing safe and compliant products is one of the many ways we help our customers. We work with suppliers that understand the importance of product safety and provide them with resources to help them stay aware of current requirements.

With the enactment of the Consumer Product Safety Improvement Act (CPSIA) in 2008, we advanced our safety focus upstream in the product life cycle. The Product Safety and Compliance team leverages a merchant and supplier intranet as a virtual, one-stop shop for consumer product safety and regulatory requirements. We firmly believe that safety cannot be tested into a product. The product safety process starts long before a product is placed on our shelves or made available online. And, in the event an issue is detected with a product on our shelves, we take the appropriate steps to remove it, oftentimes before a national recall is ever issued.

The processes and requirements outlined on the merchant and supplier intranet are identified, assessed, written, developed and monitored by internal product safety managers. Our merchants and suppliers can access this information at the beginning stages of the product life cycle, so safety and regulations can be built into the product. We also use the world's largest, third-party consumer product testing labs to ensure our products meet or exceed requirements. A team of quality experts assess each product we import directly that requires a General Certificate of Conformity (per the CPSIA). This review is designed to guard against products requiring proof of compliance with the CPSIA being imported by Walmart into the U.S. without the required certification.

For nearly a decade, the Consumer Product Safety Commission (CPSC) has recognized Walmart as an industry leader in self-reporting product safety concerns. Our internal systems are equipped to notify our stores, clubs and online businesses within hours of a product safety concern; registers are subsequently locked to disallow sale of the affected product, and facilities then report back when the product has been removed. We post up-to-date information on product recalls on our corporate website or via direct mail or phone where possible.


Financial services

Providing customers financial services and products at Everyday Low Prices in a safe environment is central to our business. Because consumers can be targeted by criminals seeking to defraud them through a variety of schemes, including lottery and sweepstakes scams, Walmart implemented a proactive, fraud prevention strategy, guided by four pillars to help protect our customers:

Consumer awareness

We provide information on common scams to our customers at the point-of-sale, including fraud awareness signs and brochures. In 2011, we aired a public service announcement via in-store televisions at our Walmart MoneyCenters and partnered with the Federal Trade Commission to provide nearly 1 million customers with bookmarks featuring educational resources as part of National Consumer Protection Week.

Associate education

Helping our associates understand how to spot signs of fraud and protect the financial interests of our customers remains a priority. In 2011, we trained tens of thousands of associates on fraud and money laundering as part of our prevention strategy. We also included financial education materials in the March 2011 edition of Walmart World, a monthly publication for our 1.4 million U.S. associates.

Technology

We utilize an anti-money laundering software solution to monitor financial services activity for potential financial crimes. This technology allows us to identify trends and specific cases of apparent consumer fraud.

Government reporting

We actively report suspicious activity to the Financial Crimes Enforcement Network (FinCEN) and law enforcement, resulting in the filing of tens of thousands of suspicious activity reports. We also participate in the U.S. Treasury's Bank Secrecy Act Advisory Group, which improves the level of information sharing toward financial crime reduction and enforcement objectives.


Environmental compliance

We are committed to preserving our natural resources and achieving full compliance with all applicable laws and regulations. Our comprehensive Environmental Management System (EMS) enables us to proactively identify environmental regulatory requirements for each of our facilities, while conducting the necessary training, procedures, services and audits.

We have identified, documented and associated more than 9,600 federal, state and local environmental regulatory requirements with individual facilities, while tracking obligations for another 16,000 permits. In addition, the continual analysis of data captured by our Environmental, Health and Safety (EH&S) Compliance Information system allows us to strategically enhance our compliance programs in a sustainable manner.

In 2011, Walmart also developed standardized auditing protocols with contracted environmental service providers to further enhance our EMS and proactively monitor compliance obligations.

Our more than 4,400 retail facilities in the U.S. were the subject of more than 2,000 compliance inspections by environmental regulatory agencies in 2011. No deficiencies were found in 59 percent of those inspections. Minor deficiencies that did not result in a Notice of Violation (NOV) were identified in another 32 percent, while 9 percent required corrective action.

Environmental services

Compliant. Sustainable. Profitable.

Running sustainable and compliant programs is the right thing to do for our customers and communities, and has also been proven to be a competitive advantage for Walmart. Sustainable disposal and transportation practices have become key incentive components of performance-based contracts for environmental-related services at stores and clubs. These contracts, which promote sustainability and service efficiencies have been key in developing programs that strengthen compliance efforts by identifying the right solution tailored to meet specific compliance needs. The combination of sustainable practices and rising commodity values has allowed Environmental Health & Safety (EH&S) to manage recycling and service programs to leverage costs and generate income. For the first time on an annual basis, the revenue generated by these recycling programs exceeded the cost of services.

Waste minimization

Aerosol recapping program

In 2011, Walmart, in partnership with SC Johnson, continued the replacement cap program for Glade® aerosols. The caps on these cans are susceptible to breakage during shipping and from sales floor traffic. Previously, an aerosol can with a broken or missing cap had to be managed as waste. With the replacement cap program, we are able to order new caps and return the merchandise to the sales floor without adding to the waste stream. This reduced related waste by 58 percent since 2010 and has saved approximately 234,000 aerosols from being treated as waste to date.

SMARXT DISPOSAL partnership

In 2011, we joined a national partnership to educate customers about the proper way to dispose of unused prescription drugs. Unused portions of these medicines must be disposed of properly to avoid harm to wildlife, pets and people. We were the first company to launch a national educational program in more than 3,500 of our pharmacies, promoting the SMARXT DISPOSAL campaign. In addition to posting signs, we have made information available online and will begin printing SMARXT DISPOSAL directions on our pharmacy bags.