For the past six years Walmart has been working to enhance its global ethics and compliance program, with a specific focus on anti-corruption. Today more than 110 employees work full time on Walmart’s anti-corruption efforts, including screening potential business partners, providing training, answering questions and monitoring our business.
Walmart and other companies have expressed interest in certifying their anti-corruption compliance programs under the new ISO standard 37001. See Microsoft and Wal-Mart seek ISO 37001 Anti-Bribery Certification. That standard “provides guidance for establishing, implementing and reviewing an anti-bribery management system” either as a stand-alone effort or as part of a company’s broader ethics and compliance program. ISO 37001:2016. Several anti-corruption experts have asked me why Walmart is interested in ISO certification. In light of the guidance that different governments and commentators have provided regarding the elements of an effective compliance system and Walmart’s investments to enhance its program, surely Walmart doesn’t need to take the steps the ISO standard specifies?
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