WalMart settled its long-standing FCPA enforcement action yesterday. Under the administrative order, WalMart agreed to pay $327M.
While this amount seems large, our friend Matt Kelly reminds us that WalMart’s global sales will raise as much in 5 hours. A small price to pay given the expansion provided by the corrupt practices.
To be fair, Walmart also spent $900M to improve its controls and systems after the fact. The mighty retailer is now in a position to become a leader of good compliance and ethical practices. Will it seize the opportunity?
If you see an illegal or unethical practice in your organization today, imagine yourself five years down the road after an enforcement action. Create a vivid picture of paying fines, beefing up your compliance program and trying to restore your reputation. Then, instead waiting for the inevitable, take immediate action.
Every day offers an opportunity for ethical leadership.