According to a letter from two Democratic legislators, lawyers for Walmart have recommended that the company expand its internal probe of bribery allegations concerning its operations in Mexico to several other international markets.


Walmart, internal probe, bribery allegations, Mexico, Brazil, China, India, South Africa, Elijah Cummings, D., Md., Henry Waxman, D., Calif., Mike Duke, president and chief executive officer, Maritza Munich, general counsel, Walmart International, Greenberg Traurig and Akin Gump, Foreign Corrupt Practices Act, FCPA, Associated Press, Walmart spokesman David Tovar














































































































































































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Walmart bribery review expands

June 13th, 2012

BENTONVILLE, Ark. – According to a letter from two Democratic legislators, lawyers for Walmart have recommended that the company expand its internal probe of bribery allegations concerning its operations in Mexico to several other international markets.

These include Brazil, China, India and South Africa.

The letter, sent by representatives Elijah Cummings (D., Md.) and Henry Waxman (D., Calif.) to Mike Duke, president and chief executive officer of Walmart, complains that the retailer has failed to provide the congressional inquiry any documents, to allow any Walmart employees to discuss the allegations with congressional staff members or to respond to the lawmakers’ request to speak with Maritza Munich, who was general counsel of Walmart International and who had sent a memo detailing the allegations to senior management and certain board members.

The letter mentions that attorneys with the law firms of Greenberg Traurig and Akin Gump conducted a general briefing for the lawmakers on May 21, but that they refused to answer questions about potential Walmart violations of the Foreign Corrupt Practices Act (FCPA), contending that their firms had been hired in 2011 and had no substantive knowledge of the company’s actions relating to the bribery allegations. Instead, they stated that they had been hired to conduct a broad review of Walmart’s anticorruption policies in Mexico, Brazil and China, and consequently recommended that Walmart also evaluate its operations in India and South Africa. Those five countries, they said, represent the areas of highest risk.

The letter goes on to mention that in response to the law firms’ recommendation, Walmart requested that they conduct a global assessment of the company’s anticorruption policies, and subsequently revised its policies and procedures, including creation of a new process for addressing corruption complaints to senior management and the audit committee of the board of directors.

The legislators requested that Walmart provide, no later than June 26, several documents, including among others the new anticorruption and ethics policies and procedures; those policies and procedures as they existed prior to 2010; all internal reports, reviews or other documents related to the FCPA in 2010 and 2011; and all internal complaints and reports regarding the FCPA submitted by employees since the new policy took effect.

In an e-mail to the Associated Press, Walmart spokesman David Tovar stated that the company is cooperating with ongoing federal investigations and "as appropriate, will also continue to assist members of Congress and their staffs in understanding our efforts to address FCPA issues." Walmart’s lawyers are conducting a second briefing today.

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