Insights From Walmart on Using a Gift Policy to Create a Corporate Culture of Integrity

Gifts and hospitality are an accepted part of business culture, but they are also the source of many anti-corruption law violations. Because the practice is so entrenched, creating a gift policy that suits a company’s business needs is a significant challenge. In a guest article, Daniel Trujillo, the chief compliance and ethics officer for Walmart’s international operations, discusses how Walmart has implemented a strict no-gifts policy and used it as a tool to underscore the company’s corporate culture rooted in personal and professional integrity. See The FCPA Report’s three-part series on travel and entertainment corruption risks: “Five Hallmarks of an Acceptable Hospitality Expenditure” (Mar. 9, 2016); “Three Musts for a Strong T&E Policy and Five Ways a Company Can Customize Its Program” (Mar. 23, 2016); and “Internal Controls to Ensure the Program Is Working” (Apr. 6, 2016).

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