An ECI Member Profile: Cindy Moehring, Senior Vice President, Chief Ethics and Compliance Officer -U.S., Walmart

By ECI Connector posted Apr 17,2017 11:24


Authenticity, the Right Skillset and Doing the Best Job You Can

Be authentic. Get to yes. Become a valuable business partner.

These are three of the myriad takeaways that I learned during my recent conversation with Cindy Moehring, Senior Vice President, Chief Ethics and Compliance Officer - U.S., and longtime ECI member.

There is no question that overseeing the U.S. Ethics and Compliance program for a corporation the size of Walmart is a large mandate. To comprehend what Cindy’s responsibilities look like, I asked her about the structure of her team. “At Walmart, we have over 2,000 associates who work in Ethics and Compliance covering 14 compliance subject matters, plus ethics. In the U.S., the organization that I oversee includes over 400 Ethics and Compliance professionals.”

Because Walmart offers such a diverse array of products and services to its customers, a diverse array of compliance subject matter expertise is required. On a daily basis, Cindy tackles matters “ranging from food safety to anti-money laundering to health and wellness compliance, to environmental regulation, employment requirements and consumer protection matters.” As such, Cindy has structured her team for maximum coverage.

As I have asked all of the ECI members and guests that I have profiled in recent articles, I asked Cindy how she originally became engaged with the Ethics & Compliance Initiative. Walmart had already been a member of ECI’s predecessor organizations, but Cindy shared that what she finds most beneficial about her ECI membership is that the organization provides “offerings for ethics and compliance professionals at different levels of their careers … including opportunities for entry level professionals to engage at the Annual Conference, mid-level professionals to interact via the best practice sharing conference and senior level professionals to participate in the Fellows program.” What Cindy enjoys most about ECI is the thought leadership produced by ECI members and staff. She also finds the networking opportunities ECI provides to be invaluable.

I asked Cindy how she dispels the myth that the Ethics and Compliance department is analogous to the Principal’s Office. She agreed that there is often a perception of compliance as the people who always say no, but she explained that she dispels this perception by showing her organization’s value to the business so that compliance is viewed as a “valued business partner… you do that by figuring out how to partner with the business in a way that makes them know that you understand their business … it helps if you bring value back to the company, through savings, streamlined processes, etc., … once the business sees that you understand what they do, that you care about it and that you are trying to help improve the business, that dispels the principal’s office perception. It is imperative that compliance officers find a way to get to 'yes,' which starts with understanding what the business wants to accomplish and helping teams understand how to achieve business outcomes in a way that satisfies compliance and brings value to the organization.”

For professionals considering an ethics and compliance career, Cindy considers technical competence to be the starting point. “From there, the competencies that are incredibly important include judgment, courage, a willingness to speak up, an inquisitive mind and a keen ability to think creatively.” She went on to emphasize the importance of adaptability and collaboration. “Ethics and compliance professionals need to be adaptable, curious and collaborative … they need to build partnerships.”

As our conversation continued, I asked Cindy about her approach to building a talent pipeline and her thoughts for up-and-comers in the ethics and compliance profession. She offered the following guidance, “I encourage professionals to broaden their minds and think about how they can extend their skills beyond just giving legal advice … and that they begin to see ethics and compliance as a way to broaden and complement their legal skills. [However;] no compliance department should be entirely comprised of attorneys.”

Cindy went on to explain the importance of business and operational competencies within a compliance department. “An effective compliance organization needs to operationalize compliance. This requires industry professionals to come and share knowledge with the compliance organization … There is a benefit to a compliance organization to allow professionals who do not want to make a career out of compliance to spend a period-of -time working in an ethics and compliance function. It is a good rounding-out stop on an individual career progression ladder. Spending time in an area is the best way to understand it. An added bonus is that allowing professionals from other operational areas of the organization to spend time in compliance creates ethics and compliance ambassadors throughout the organization, and ambassadors’ voices are essential.”

She went on to offer this important career advice to up-and-comers: “life is not as planned out as I would have thought … a lot of it is luck and timing, and things that you cannot control. The only things you can control are having a broad skillset and doing the best job you can in every position, so that if an opportunity presents itself, you are ready and top-of-mind for decision- makers.”

Outside the office, Cindy enjoys spending time with her three children. Her family enjoys athletic activities and she “spends lots of time at football games, on the soccer field, and at [my daughter’s] piano and violin events … when I am not doing that, I really like to cook and to garden.” She has successfully completed a sprint triathlon and is currently getting back into running, biking and swimming. When it comes to reading, she describes herself as a “political junky,” and most recently read Hillbilly Elegy: a Memoir of a Family and Culture in Crisis, by J.D. Vance.

When Cindy first started at Walmart, the Ethics and Compliance department did not yet exist. Now, it has developed into a widely recognized program. “Last summer, New York Stock Exchange Governance Services named Walmart has having the Best Governance, Risk, and Compliance Program at a Large-Cap Company, concluding that we are demonstrat[ing] how governance, risk, and compliance programs are ingrained in the culture of a large-cap company from the top down. Our Ethics and Compliance program has evolved. It is very much embedded in the business … we have made a lot of progress and winning the award was a nice recognition.”

Cindy Moehring serves as the U.S. Chief Ethics and Compliance Officer. In this capacity, Cindy is responsible for leading a multi-disciplinary team of ethics and compliance professionals, who identify, mitigate, monitor and manage the ethics and compliance risks for the U.S. business divisions, including Walmart Stores and Sam’s Clubs. Previously, as Senior Vice President and Global Chief Ethics Officer for Walmart Stores, Inc., Cindy developed and implemented a company-wide, global ethics program to drive a values-based culture of integrity to over two million associates and oversee all internal ethics investigations. Prior to this, Cindy was Vice President and Chief Ethics Officer and before that she was the Senior Director of U.S. Ethics. Before holding that position, she served as Senior Director for the Walmart Foundation, and Associate General Counsel for Corporate Governance in Walmart’s Legal Department.

Prior to joining Walmart in 1999, Cindy was Corporate Counsel for Viasoft, Inc. in Phoenix, Arizona, Vice President of Wells Fargo Bank (formerly, First Interstate Bank), and an associate at the law firm of Meyer, Hendricks, Victor, Osborn & Maledon. Cindy clerked for U.S. District Court Judge T.S. Ellis III, graduated magna cum laude from Georgetown University Law Center,and summa cum laude from the University of Missouri, with a Bachelor of Arts in Political Science.


Megan Roudebush is Chief Compliance Officer at Crescent Grove Advisors. The views expressed in this article are her own and not the views of her employer. Megan cares about integrity based leadership, sound corporate citizenship and deep civic engagement. Outside the office, Megan is engaged with the Executives' Club of Chicago, sits on the Guild Board at the Lyric Opera in Chicago and serves on the Board of the Bryn Mawr College Chicago Club. She recently joined ECI and is also a member of the National Society of Compliance Professionals (NSCP).