In my last post about Walmart’s compliance reforms, we looked at how Walmart built a centralized, independent compliance function and decided its 14 key responsibilities worldwide. Now let’s look at how the company set specific compliance objectives and focused on achieving them.
Jorgensen started with the audit committee. In its 2013 proxy statement filed one year ago, Walmart announced that the audit committee would develop specific compliance goals for named executive officers to achieve: building new compliance systems, hiring key compliance personnel, and the like. Those goals were decided at the start of Walmart’s 2014 fiscal year, which was Feb. 1, 2013. Jorgensen briefed the audit committee throughout the year on the executive team’s progress toward those goals.
