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A shopper carts her purchases from a Wal-Mart store in Mexico City, April 24, 2012.EDGARD GARRIDO

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 were retained to review 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 is conducting a global review of its anti-corruption compliance program, but has not provided details about the review.

According to the letter, from Representatives Elijah Cummings and Henry Waxman, both Democrats, Wal-Mart asked its lawyers to expand the review to a worldwide assessment of the company's anti-corruption policies.

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.

Mr. Cummings and Mr. 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 officer Michael Duke and also asked him to allow certain witnesses to cooperate with a congressional investigation into the bribery allegations.

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 Wal-Mart.

Wal-Mart representatives did not immediately respond to a request for a comment, but the company has said it is "committed to a full and independent investigation," and that "it would be inappropriate for us or others to come to conclusions before the investigation is complete."

While Wal-Mart has tapped the brakes on its growth in Brazil and China, last month Walmart International chief executive officer 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.

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