Jay T. Jorgensen, a lawyer at Sidley Austin LLP in Washington, D.C., has been hired as Wal-Mart Stores Inc.’s new global chief compliance officer, according to news reports.
Jay T. Jorgensen
In a memo today, Wal-Mart also said it had merged into one unit its legal, compliance, ethics, and investigations staff. The new merged unit reports to the Wal-Mart general counsel, Dow Jones reported.
The changes come in the wake of an explosive New York Times article in April that described widespread bribery at the retailer’s Mexican operations and an attempt by its Bentonville, Ark., headquarters to cover it up.
The retailer previously disclosed that it is on track to spend some $100 million on the FCPA investigation and internal systems review this year.
Law firm Jones Day is conducting an internal investigation into the bribery allegations in Mexico. That investigation, in turn, has opened up scrutiny of Wal-Mart’s operations in other countries.
In addition, the Department of Justice and Securities and Exchange Commission are probing Wal-Mart for possible FCPA violations.
The scope of the changes at Wal-Mart revealed in two memos reviewed by Dow Jones today is large.
The memo said that more than 300 lawyers and accountants at Greenberg Traurig LLP and KPMG have spent 79,000 hours reviewing Wal-Mart’s compliance programs in 27 countries.
Moreover, KPMG has trained more than 11,500 associates at all levels of the company, the memo said, including 7,765 associates and third-party vendors and consultants in Mexico, where Wal-Mart now runs a whistleblower hotline overseen by Deloitte Touche Tohmatsu Ltd.
According to Dow Jones:
Wal-Mart is also in the process of screening more than 20,000 third-party vendors, and KPMG has performed background checks on 3,500 vendors so far, according to the memo. Anti-corruption assessments will now be performed on at least an annual basis, the memo said, and a global compliance and ethics committee of senior executives, including [CEO] Mike Duke, will meet quarterly. Reviews were previously conducted to varying degrees in different regions, the person said, and the new approach reflects an effort to make them more systemic and integrated.
The 40-year-old Jorgensen begins his new post Dec. 3. A 1994 graduate of Brigham Young University, from which he also received his law degree in 1997, Jorgensen served as a law clerk to Chief Justice William H. Rehnquist. He also clerked for Samuel Alito when the now-Supreme Court justice was a judge on the U.S. Court of Appeals for the Third Circuit. He is a member of the conservative Federalist Society, a public policy legal group. Jorgensen has done legal work for Tyson Foods, also based in Northwest Arkansas near Wal-Mart.
Wal-Mart also recently announced that it had hired Daniel Trujillo as head of international legal compliance. Trujillo was deputy general counsel and director of compliance at Schlumberger Ltd., an oil services company also under FCPA investigation.
And in September, FBI veteran Tracy Reinhold moved into the newly created position of vice president of global investigation at Wal-Mart.
Wal-Mart in-house lawyer Tom Gean moved into a new position earlier this year overseeing FCPA compliance, international internal controls and staff training in FCPA compliance.
