Daniel Trujillo is Senior Vice President and Chief Ethics & Compliance Officer with Walmart International. Originally from Argentina, he speaks five languages and has worked in over 60 countries. Before joining Walmart International, he served as Deputy General Counsel and Director of Compliance at Schlumberger Ltd., a global supplier of technology, integrated project management and information solutions for customers working in the oil and gas industry. Before joining Schlumberger, he supported the legal and compliance efforts of two international companies—Cargill and Impregilo S.p.A.
Time-zone hopping, internal meetings, program development and triathlon training—it’s all in a day’s work for the CECO at the world’s largest retailer, Walmart International. In this exclusive interview with Ethisphere, he discusses leadership, discipline, talent retention and the need to embrace change.
Q: Describe a typical day in the life of Daniel Trujillo.
Working for the largest retailer in the world and dealing with a global ethics and compliance program of this size means there is no such thing as a typical day for me. With all of our different time zones, it can seem like I have traveled around the world before 9am.
To help get ready for a fast-paced day, I like to start at 4 or 5am and swim, bike or run (I am a triathlete). One constant in my day is that I have a full plate of meetings, although the topics vary: sometimes it means checking in on issues or briefing our key stakeholders and other times it involves addressing pressing matters that have arisen or designing strategy for our next initiative.
I always make time during my week to think about strategy and the big picture.
Even though my day is normally pretty scheduled, I make sure that I am accessible for anyone—both on my team and in other functions—to stop by with questions and concerns throughout the day.
After I leave the office, I have dinner with my family and get my kids ready for bed and then spend at least an hour with my laptop in the evening. It is a full day, but it is important to me to balance my work with spending time with my family and training for my next race.
Q: Tell us a bit about your ethics and compliance program at Walmart.
With more than two million associates in 28 countries, we need an ethics and compliance program that can accommodate our scale and scope of operations. To that end, we structure our program around 14 global subject matters with a centrally led team of experts in each area: Anticorruption; Antitrust; Consumer Protection; Environmental; Financial Services; Food Safety; Health & Safety; Health & Wellness; Labor & Employment; Licenses & Permits; Privacy; Product Safety; Responsible Sourcing; and Trade.
Outside of the United States, we are also organized geographically by markets and a Bentonville-based team that reports up to me. By creating a single global team that has local teams in each market but reports centrally, we bring consistency to our key risk areas while tailoring our program to the needs of each market.
We focus our program development on three critical areas: adding and retaining the right talent; embedding compliance through clear and effective policies and processes; and driving compliance through systems and technology. My philosophy has always been: ‘Get ready for the worst. Hope for the best. And enjoy what you have.’ You only control what you can control.
As CECO, I am confident in the strength of our program and culture to prevent, detect and remediate pitfalls that may arise. I am proud of what we have built so far: a robust organization flexible enough to adapt to changing risks, regulations and business priorities.
Q: You were hired into a newly created role when you began with Walmart in 2012. How did you set about establishing your place in the department and linking with existing personnel to create and implement policies?
One of the main reasons I joined Walmart in 2012 was the level of commitment to ethics and compliance from senior leadership. I first spent a lot of time listening and asking questions before putting a plan together. Establishing relationships with people and learning about their business before starting to plan new initiatives was critical to our success.
I also spent time learning how the company uses data and technology, which is a key ingredient for our compliance program with systems tracking data points across 14 subject matters in 27 countries internationally. Walmart is too large to handle our ethics and compliance risks effectively without the visibility and functionality that technology can provide, so increasing our systems capabilities has been one of my significant efforts.
One of the benefits of working for a company like Walmart is that we have a great pool of talent to draw upon, and I make sure to utilize all this combined experience. I sat down multiple times with all of the relevant stakeholders and we all got together as a team to create a cohesive plan for developing the international program.
Q: Which stakeholders do you rely upon most heavily to assist you in your compliance efforts?
Senior leadership. They set the tone for the whole company, and I have been very lucky to have a great partnership with our leaders who so clearly understand and support what we are doing. I also know that I need to engage everyone, most importantly our associates, to be successful, particularly at a company of our size. We have a strong company culture founded on doing the right thing.
Q: Can you share any advice as to how compliance leaders can influence staff and management to support and buy into the compliance function?
You need to: (1) know and care about your business, and (2) know and care about your company culture. We have two ears, two eyes and one mouth for a reason: listen and observe twice as much as you talk. Once you do that, focus on who at your company can really move the needle in terms of compliance. For us, that is our store manager—he or she picks up on the tone set by leadership and serves as an example for other store associates. To reach the store manager and really make an impact, you have to understand the business and the culture to know how to talk about compliance in a way that will resonate.
Q: As someone who speaks five languages and has worked in more than 60 countries, how do you feel your broad international experience has helped you in this role?
One of the challenges of this role is recognizing that an approach that works well in one market may not work in another. You have to understand the differences in the traditions and cultures of different countries in order to design a truly global program. My background and experiences give me insight into some of these nuances as well as the awareness that doing something one way today does not mean we could not do it differently and better tomorrow.
I am constantly trying to improve at everything I do, and I want our program to be that way too—we need to be flexible, to embrace change and to recognize that getting better requires effort and discipline.
Q: What commonalities and differences have you found in terms of ethics and compliance both at the individual and corporate levels from nation to nation and culture to culture?
You will always have someone who wants to do the right thing and someone who is not interested. My role as CECO is to give the former the tools and knowledge to get it right and to make sure we identify the latter in time and react appropriately.
Q: What do you foresee as your greatest challenge over the short and long term?
Having the right talent in the right roles and at the right time is so critical to the success of our program, both short and long term. I want to develop and retain our best people, as the greatest talent always has the first opportunity to leave. I also focus on continuing to be a good partner to our business and having the agility to evolve within a rapidly changing commercial environment.
Q: What influenced you to pursue a degree in law?
Initially, I wanted to be a diplomat. I decided not to pursue that after learning it would be challenging both to have a career in diplomacy and to have the family life I have now.
Q: What have been the turning points in your career?
First, in 1997, I decided to respond to a newspaper ad soliciting attorneys interested in an international career. I was selected out of 90 candidates to start with Schlumberger and I spent six months in Paris in training. That set me down the path I am on today.
Second, in 2001, I left my home country of Argentina and embarked on a global career. I was based in Italy and covered continental Europe and Africa. I spent a lot of time traveling and working in many different countries, which gave me new perspectives and experiences that I rely on every day.
Q: What do you wish you had known when you started this position?
When Walmart’s leadership recruited me, they went out of their way to give me the information I would need to succeed. They were thoughtful and intentional in showing me exactly where we were as a company, what they wanted, what they expected and why. I am grateful for that—there were no surprises when I started this position.
For anyone considering a compliance leadership position at a new company, I recommend considering the extent of transparency and engagement that the company’s leadership demonstrate with you. Walmart’s approach was so helpful to me.
Q: Based on your experience, what tips and best practices can you share with your peers in the industry and those just starting out in the field?
Follow your instincts and never try to be someone you are not. Most mistakes I see people making come from a lack of confidence. You have to be confident in yourself, choose a path and go for it. If you realize you made a mistake, correct it, learn from it and use it to keep improving.
Q: If you weren’t working in ethics and compliance, what would your dream job be?
I would like to be a professional soccer player or a professional triathlete. I love the discipline, consistency and knowledge of yourself that you gain when you practice competitive sports.
Q: What issues keep you up at night?
Unless my five-year-old son wakes me up, I sleep well. We have a great program in place and I am glad for the chance to continue moving it forward.
Q: What keeps you motivated?
My family and life in general. I am a positive person and I enjoy what I do.
Q: What do you do outside of the workplace for enjoyment?
I split my time between work, family and training for my next triathlon. And I enjoy all three.
Q: One of our favorite interview questions here at Ethisphere is ‘What’s the worst job you’ve ever had—and why?’ What comes to mind for you?
I am not sure I have had a ‘worst’ job—as I said before, I like to enjoy what I do. If I no longer enjoy something, I will stop doing it. The most exhausting job I have ever had, though, was probably coaching kids at a sports summer camp as a teenager.
Upcoming events:
Ethisphere’s 2016 Latin America Ethics Summit is happening on June 8-9 in Sao Paulo, Brazil. Walmart’s Flavio Cotini, President and CEO, Brazil along with other members of the C-suite and leaders across industries and geographies will assemble to advance corporate integrity and performance. For more information about this exclusive event and to register, click here.
