Career Biography

Ximena Santibañez is Vice President of Legal & Corporate Security and General Counsel at Walmart Chile, where she serves on the Executive Leadership Team and leads an integrated organisation spanning Legal, Legal Operations, Contract Administration and Corporate Security, supporting more than 1,000 associates across the company. She is responsible for enabling Walmart Chile’s strategic priorities through legal innovation, governance, operational resilience and business-focused risk management.

Since joining Walmart Chile in 2013 as Chief Ethics & Compliance Officer, Ximena has held several leadership roles across the organisation, including leading one of the company’s retail formats, Central Mayorista, before being appointed General Counsel in 2021. In late 2024, she also assumed responsibility for Corporate Security, further expanding her role in strengthening the company’s resilience and supporting its longterm growth. This combination of legal and operational leadership has shaped her conviction that legal strategy starts with the business strategy, positioning Legal not simply as a risk management function, but as a driver of innovation, growth and value creation.

Under her leadership, Walmart Chile’s Legal function has undergone a significant transformation through the integration of Legal Operations, the implementation of a centralised AI-enabled Contract Administration model, and the development of the company’s AI governance framework. Her team has also supported many of Walmart Chile’s most strategic initiatives, including the expansion and automation of distribution centres, the continued growth of eCommerce and Marketplace, new logistics services for sellers, and Data Ventures. Her vision is to build a legal function that combines legal excellence, technology and operational insight to deliver measurable business value, enhance customer experience and strengthen organisational resilience.

Before joining Walmart, Ximena held leadership positions at ING in both Chile and the Netherlands before founding her own consulting firm. She holds a Law degree from Pontificia Universidad Católica de Chile, an MBA from Universidad Adolfo Ibáñez, and executive education certifications in Digital Transformation from IMD and Customer-Centric Growth from The Wharton School. She also lectures in postgraduate programmes at Pontificia Universidad Católica de Chile and Universidad Adolfo Ibáñez.

Her leadership has been recognised through several distinctions, including Walmart Chile’s Executive Entrepreneur of the Year Award, being named one of Chile’s 100 Women Leaders by Mujeres Empresarias and El Mercurio, and inclusion in the Legal 500 GC Powerlist Chile.

How does your team contribute to the overall business strategy of the company? Can you share an example of a recent legal-led initiative that had a significant impact?

At Walmart Chile, our legal strategy starts with the business strategy. I believe the role of a modern General Counsel is to help the business grow responsibly, move faster and make better decisions. That perspective was shaped by an experience that has been invaluable in my career: before becoming General Counsel, I had the opportunity to lead one of Walmart Chile’s business formats, Central Mayorista. Running a business gave me first-hand exposure to commercial decision-making, operations, logistics and customer needs. It fundamentally changed the way I lead Legal.

Today, my team is expected to think like business leaders first and lawyers second. As Vice President of Legal and Corporate Security, I lead a multidisciplinary organ ation that brings together Legal, Legal Operations, Contract Administration and Corporate Security. We have intentionally built these capabilities as business enablers rather than support functions. Our ambition is for Legal and Corporate Security to be recognised for creating value, not only by protecting the company from risk, but by delivering measurable financial impact, improving operating performance and contributing to a better customer experience.

One significant initiatives has been the creation of a centralised Contract Administration function supported by AI. More than an operational improvement, it has become a strategic capability that strengthens contract governance, delivers measurable savings, improves service levels and allows our lawyers to focus on complex, business-critical matters. At the same time, we are redesigning our Corporate Security strategy to strengthen investigations, criminal enforcement and operational resilience across our stores, distribution centres and manufacturing facilities, helping reduce losses while enabling safer operations and a better experience for both customers and associates.

This same business-first approach has enabled us to support Walmart Chile’s most strategic initiatives, including the expansion and automation of distribution centres, the continued growth of eCommerce and Marketplace, new logistics services for sellers, Data Ventures and the company’s AI governance framework. The most rewarding recognition for our team is when Legal and Corporate Security are no longer seen as cost centres or control functions, but as strategic partners that create value, strengthen business performance and ultimately improve the experience of the millions of customers we serve every week.

AI has been taken seriously as a potentially revolutionary technological change in the legal world for a number of years now. Has it had a meaningful impact in how your legal team works in this time?

Absolutely, but only because we have been intentional about how we use it. AI is not our strategy; it is an enabler of our strategy We have embedded AI into contract management, document review and knowledge management to eliminate repetitive work and allow our lawyers to focus on what creates the greatest value: judgment, negotiation, strategic advice and anticipating risk. This has enabled us to manage increasing complexity while improving responsiveness to the business.

Equally important, Legal has played a leading role in establishing Walmart Chile’s governance framework for the responsible adoption of AI, ensuring that innovation is accompanied by appropriate controls, data protection and ethical oversight. I believe the future of the legal profession will not be defined by who adopts the most technology, but by who best combines technology, governance and business judgment to create sustainable value for the organisation