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Compliance Program Seminar - Panel 2 - Compliance Program Development at Walmart

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Compliance Program Seminar panel 2 - Compliance Program Development at Walmart

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Compliance Program Seminar - Panel 2 - Compliance Program Development at Walmart

  1. 1. Jay Howell Sr. Director, Product Safety and Compliance
  2. 2. A Perspective on Assessing Compliance Programs
  3. 3. Program Fundamentals Leadership Risk Assessment Standards & Control Awareness Training Monitoring & Response
  4. 4. Product Safety Compliance Regulatory Change Management Standards and Verification Product Removals and Recalls Regulatory Reporting Program Monitoring Program Overview
  5. 5. Product Safety Compliance Risk Mitigation: Work With Supply Chain
  6. 6. Product Safety Compliance Risk Mitigation: Product Verification* Send Purchase Orders Confirm test requirements Generate certificate Manage exceptions Lab sends results Request test results, if needed Use existing test if available *Select private brand and direct import general merchandise products
  7. 7. Product Safety Compliance Thank You Regulatory Change Management Standards and Verification Product Removals and Recalls Regulatory Reporting Program Monitoring Responsibl e Product Stewardshi p Identifying Mitigating Monitoring
  8. 8. Consumer Product Safety Commission Compliance Program Seminar Lisa Pankiewicz Vice President, Global Stewardship The Clorox Company November 1, 2018
  9. 9. 2018 1 9 1 3
  10. 10. Diverse Product Portfolio Cleaning: 34% Household: 32% FY18 $6.1B in Sales International: 17% Lifestyle: 17% 14% 9% 7% Home Care 19% Laundry 9% Professional 6% 3 9% 4% 3% 3% Commitment to Safety
  11. 11. Safety Compliance Functions Corporate Governance Global Stewards hip Quality Legal
  12. 12. Corp Governance Team Product Regulatory Compliance Team All Functions Business Units Safety Compliance Infrastructure Notification and Escalation
  13. 13. Safety Compliance Core Processes Intake & Escalation Product Issue Team (“PIT”) Recall Process
  14. 14. Compliance Program- Role of Technology 7 How is technology changing Clorox’s compliance program?  Ability to integrate multiple systems  Monitor and track data from a variety of sources  Ability to perform advanced data analysis Identify trends Proactive avoidance of potential issues  Advanced software tools to assist in capturing potential safety concerns
  15. 15. Compliance Program- 3rd Party Integration 8 How does Clorox ensure that third party logistic providers and other supply chain partners are integrated into our compliance program? Supply contracts and quality agreements Change control Shared communication Integrated quality systems/processes Supplier performance management program
  16. 16. Compliance Program- Audit Checks 9 What checks/audits/stress tests does Clorox employ in order to ensure its compliance program effectively works as intended? Robust end-to-end audit processes Internal audits Raw material & packaging suppliers Co-packers & contract manufacturers 3rd party service providers Product performance / quality monitoring Mock recalls
  17. 17. Compliance Program- Customer Integration 10 How does Clorox integrate safety and quality/customer care programs to ensure that information is shared among all relevant divisions? Centralized data system to manage and analyze product issues from various sources (consumer, customer/retailer, social media etc.) Comprehensive metrics focused specifically on tracking and trending complaint data Information is shared with the appropriate functions and business units Escalation and notification CAPA / OTV Continuous improvement
  18. 18. Thank You 11
  19. 19. The Manhattan Toy Company Compliance Program
  20. 20. Founded: 1978, in New York City by Francis Goldwyn (grandson of Hollywood studio mogul Samuel Goldwyn) Goldwyn eventually sold Manhattan Toy Moved to its current home in Minneapolis, Minnesota Company Size: 28 employees at HQ 15 employees at warehouse 3 employees at European sales office Product offering: approximately 500 sku’s Retail Customers: Specialty Boutique Market Target, Barnes & Noble, Amazon Harrods, John Lewis Brands: Groovy Girls, Baby Stella, Winkel, Skwish Dr. Seuss, Wimmer Ferguson COMPANY OVERVIEW COMPLIANT FOR SALE IN THE U.S., CANADA AND EUROPE
  21. 21. COMPLIANCE PROGRAM DESIGN FACTORIES SAFETY TESTING INSPECTIONS CTPAT ASSOCIATION MEMBERSHIPS
  22. 22. KNOWLEDGEABLE DESIGN TEAM: • Design product with compliance in mind • Aware of toy safety requirements • Age Grade QA OVERSIGHT: • Quality Assurance Manager attends all product development meetings • Product is reviewed for safety compliance as it is being designed INFORMED DESIGN
  23. 23. WORK WITH A CAREFULLY CULTIVATED FACTORY PORTFOLIO: • Factories specialize in toy manufacturing • Have an in-depth understanding of toy safety regulations throughout the world • Maintain long-term relationships with factories to build partnerships – collaborate for mutual success – factories know our product, quality requirements and design aesthetic • Regular factory visits • Require all factories to be ICTI certified (or other ethical audit) FACTORY PARTNERS
  24. 24. STRATEGIC PARTNERSHIP: Work exclusively with UL (Underwriter’s Laboratories) for all of our safety and compliance testing • As a small company, we do not have teams of people in a compliance department - UL is our compliance team • Contractual arrangement ensures they are integrated into our compliance program • Resource of experts - safety testing, regulatory compliance, determining appropriate age grade, and evaluating new materials SAFETY TESTING
  25. 25. ALL PRODUCT IS INSPECTED BEFORE IT SHIPS: • Maintain a China-based team that conducts all of our final random inspections • Dedicated team that includes our China Operations Manager and two Field Inspectors who work exclusively for Manhattan Toy • Their long-term relationship with our company ensures they are well acquainted with our product line, understand our quality requirements and are loyal to Manhattan Toy (their pride in the company ensures they are tough in their assessments) • Utilize reputable outside inspection services when our team is fully booked – we typically employ UL for additional inspection services • We adhere to ANSI (American National Standards Institute) tables in determining acceptable quality limits for product inspections INSPECTION STRATEGY
  26. 26. CUSTOMS TRADE PARTNERSHIP AGAINST TERRORISM: • Part of U.S. Customs and Border Patrol’s cargo enforcement strategy • Manhattan Toy is a member and has been certified • Verifies that we have processes and procedures in place to verify a secure supply chain • Requires that we meet customs minimum requirements and review our supply chain security annually CTPAT
  27. 27. ASSOCIATION MEMBERSHIPS
  28. 28. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Best Buy Compliance Program Product Safety 28
  29. 29. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Product Compliance Governance Structure 29 BoD Quarterly Compliance & Risk Committee Bi-monthly PC Governance Committee Weekly Operational Teams As needed Business Strategy, Product Strategy New/Change in Legislation – impacts and actions, Non- compliance – actions, Risk assessments, etc. Product Compliance, Private Label, Legal Audit Committee CRCO, GC, SVPs, VPs *Typical meeting rhythms. Subject to change.
  30. 30. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Product Incident Management 30 Case management system
  31. 31. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Product Incident Review Process 31
  32. 32. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Product Recalls and Withdrawals 32 Recall entered in system System communicates and assigns tasks to multiple teams Block SKU sales Remove product from shelf Cancel open orders Remove from website Post recall notice online Tweet recall Notify Customer Care Examples Remove from inventory
  33. 33. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Integrated System Blocks 33 Product Information System Point Of Sale Orders Services Online Updates Store Removal Sales Channels • Block sales • Remove from shelves and quarantine • Cancel open orders • Identify in-flight service orders • Block sales all channels, including o Secondary Markets o B2B o Specialty retail • Remove online display and post recall notice
  34. 34. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Third Party Partnerships 34
  35. 35. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Provide Guidance 35 • New product types • Emerging technologies • Children’s products • Health care products • Rideables • Lithium ion batteries
  36. 36. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Monitoring and Continuous Improvement 36 • Monthly, quarterly, and yearly review of product incidents to identify trends • Same day confirmation of sales blocks at all store locations • Monitoring of recall task completion • Hourly systematic check confirming recalled items are set as recalled (auto corrects) • Required annual recall training for front line employees
  37. 37. BEST BUY INTERNAL USE ONLY. DO NOT COPY, PUBLISH OR DISTRIBUTE. THE MATERIAL IN THIS DOCUMENT IS CONFIDENTIAL TO BEST BUY. Thank you. 37

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