* Initial review focused on Brazil, China, Mexico
* Lawyers also flagged India, South Africa as high risk
* Lawmakers investigating bribery allegations
By Aruna Viswanatha
WASHINGTON, June 12 Lawyers for Wal-Mart Stores
Inc have flagged Brazil, China, India and South Africa
in addition to Mexico, as countries that represent the highest
corruption risk in a global review, according to a letter from
lawmakers investigating the company.
The lawyers said they first reviewed Wal-Mart policies in
Mexico, Brazil and China, and later recommended the company also
evaluate its operations in India and South Africa. The lawyers
referred to those five countries as regions where the risk was
the greatest, according to the lawmakers.
The company has acknowledged it is investigating bribery
allegations involving its Mexican operations, and that it
initiated a world-wide review of its anti-corruption compliance
program in March 2011, but has not provided details about the
According to the letter, from Representatives Elijah
Cummings and Henry Waxman, both Democrats, Wal-Mart continued to
review its anti-corruption policies in other countries.
The review led Wal-Mart to revise its program to include a
new procedure for escalating corruption complaints to senior
management and the board's audit committee, the letter said.
Cummings and Waxman, who are the ranking members,
respectively, of the House Oversight and House Energy
committees, asked the company on Tuesday to provide documents
about the review and the recommendations.
The pair wrote to Wal-Mart Chief Executive Michael Duke and
also asked him to allow certain witnesses to cooperate with a
congressional investigation into the bribery allegations.
"We are cooperating with the 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," Wal-Mart spokesman David Tovar said in a
Outside lawyers for Wal-Mart at two law firms, Greenberg
Traurig and Akin Gump Strauss Hauer & Feld, briefed the
lawmakers on May 21 about the company's program to comply with
the Foreign Corrupt Practices Act, a 1970s-era law that bars
bribes to officials of foreign governments.
But the lawyers did not answer any questions about the
substance of the bribery allegations, which were brought to
light in an April 21 New York Times report that said that
management at Wal-Mart de Mexico orchestrated
bribes of $24 million to help it grow quickly in the last decade
and that Wal-Mart's top brass tried to cover it up.
The two lawmakers have previously expressed frustration
about the information they have received from
While Wal-Mart has tapped the brakes on its growth in Brazil
and China, last month Walmart International CEO Doug McMillon
said the slowdown was not a result of foreign bribery concerns.
Lawyers for Wal-Mart are scheduled to brief Congressional
investigators on Wednesday about the "investigative protocols"
the company is using to examine bribery allegations in Mexico,
according to the letter.