Director of Compliance and Integrity

Position Summary:

The Director, Compliance & Integrity (C&I) will be responsible for supporting the Sr. Director C&I and the Chief Compliance Officer (CCO) with the oversight of our ethics and compliance programs in the U.S.  This regional role includes designing, implementing and continually improving upon the elements of an effective regional program based on the core principles of the global program. Primary responsibilities consist of assessing, monitoring, detecting, reporting, and training on current and developing compliance issues and risks to the company for the region; interfacing with key businesses in the region, and supporting functions such as Human Resources, Legal, etc., to help ensure a coordinated approach on all related compliance matters; and maintaining an effective and consistent regional compliance program. These duties directly support our global commitment to doing the right thing in the right way along with following the laws, regulations, industry codes, policies, and procedures that govern our business, both of which are the foundations of our culture.

The role is a new US role aligned to the new legal regional support model; the role is regionally managing compliance education, issues, and processes which includes but is not limited to directly developing and updating policies and procedures, supporting monitoring, leading, and representing in governance matters, reporting and assisting in corrective actions and preventative recommendations to the business for assigned cases, data management, etc., and being a key interface to the internal resource network for the region (providing guidance/ direction to internal clients).

Responsibilities:

• Compliance and Integrity (C&I)
  • Design, assess, and continually improve an effective C&I program that promotes compliance based on principle-based policies and procedures and prevents and detects wrongdoing, globally.
  • Assist the Sr. Director of C&I and the Chief Compliance Officer (CCO) in developing C&I strategic and annual plans, budgets, and resource alignment.
  • Support and service a principle-based Code of Conduct for the region; support its implementation (policy and execution) stating the company’s commitment to full compliance with relevant laws applicable to the company commensurate with industry risks, comparative benchmarks, and in association with appropriate and individualized employee engagement mechanisms; develop and identify feedback and report to stakeholders and leaders on improvements, execution, and enhancements annually.
  • Support leadership in creating and fostering an engaged global culture of C&I, compliant with all laws, and clearly understood by all employees.
  • Lead assigned projects, indirect and cross-functional teams, and act as an owner for assigned tasks in the region and beyond.
  • Ensure and establish policies and procedures are world-class, principle-based, and readily accessible with clarity and understanding to all employees to aid in employee awareness and reducing risks
  • Manage and oversee the completion of the compliance risk assessment for all businesses and affiliates.
  • Develop training and communication strategies that are responsive to our needs and effectively raise awareness and understanding through education of the programs.
  • Ensure a monitoring program is established and implemented to monitor business activities in identified risk areas to identify potential misconduct. Ensure root cause analysis is conducted to develop corrective and preventative measures
  • Periodically assess and evolve the program over time to address existing and changing compliance risks, coordinating all efforts with leadership and with team members.
  • Lead policy discussions and education in the region with the integrated network and client teams (including Conflicts of Interest, Speak Up, Interacting with Integrity, Transacting with Integrity, and Privacy) and develop appropriate level (as adapted) training content, SOPs, written instructions, templates, in-take forms, etc. to support implementation and execution successfully in and across the region.
• Governance
  • Support and/or represent compliance on various governance committees, or as may be assigned, in the region and beyond.
  • Develop strong relationships and act as a business partner with the company’s business units and affiliates.
  • Develop strong relationships with our integrated resource network to ensure our service model is well-aligned, resources are comprehensively educated and knowledgeable, and able to assist the business in decision-making for the right outcomes with consistency.
  • Routinely support CCO and senior-level stakeholders, ensuring content and operations of the program are accurately stated, regular reporting on the effectiveness of the program, and immediate awareness and escalation of complex or sensitive matters, if/as such arise
• Enterprise Risk Management (ERM) and Integrated Controls (IC)
  • Support the ERM/IC initiatives as may be directed from time to time. matters including providing the ability to assess and define appropriate risk profiles and socialize risk profiles to stakeholders.
• Anti-Corruption and Third-Party Management
  • In the region, provide oversight to the future development and execution of the Anti-Corruption and Third-Party Management Program to assess third-party partners
  • Ensure a risk-based due diligence process is established to assess and manage third-party partners
  • Ensure the anti-corruption/anti-bribery requirements and third-party management process is integrated into the relevant procurement and vendor selection and management processes
  • Ensure an ongoing monitoring program of third-party relationships is established and implemented
  • Coordinate all efforts with and across the team.
• Global Hotline and Investigations
  • Support cases and issues involving the Company’s Integrity Line as assigned.
  • Support the Investigations Oversight Committee.
• Privacy
  • Provide support to the Privacy Program as may be assigned from time to time.
• Integrated Resource Network (IRN)
  • Be the regional interface to the IRN, providing consulting, advise, education, and clear and concise answers to policies, operating procedures, and matters raised by the internal clients, stakeholders, and business partners assigned.
  • Closely align with IRN members to enhance and publish communications, share insights and knowledge, and look for ways to improve processes, policies, and awareness across the client base.

Basic Qualifications:

• Undergraduate degree, Bachelor’s minimum.
• Significant experience in compliance, regulatory role, or related field as an individual contributor, director, or leader.
• Strong understanding of risk management fundamentals/tools and the ability to deal with ambiguity
• Proven change management and project management skills, including the successful transformation of a centralized function to a decentralized or hybrid model of operation.
• Effective leadership and influencing skills (critical thinking, results-oriented, etc.), including a strong reputation for integrity, objectivity, impartiality, fairness, and sound judgment
• Demonstrated knowledge of industry best practices for policies and procedures, training, and communications in a global company
• Preferred past experience or demonstrated abilities to lead in the following areas:
  • performing compliance risk assessments
  • developing and administering training programs, including an understanding of the efficacy of training and learning and developing best practices
  • policy writing and development
  • conducting internal investigations
  • drafting communications that set a tone at the top for support of compliant and ethical behavior
  • third-party risk management
  • comprehensive successes and experiences in all 7 elements of an effective compliance program, with a strong ability for advising and educating clients on the subject.
  • Advising and consulting key client groups with the ability to quickly adapt and provide solutions, answers, and insights to issues that arise.
  • Extensive experience in the region assigned.
• Ability to partner effectively with stakeholders in the region assigned with cross-cultural sensitivity and mindset.
• Proven experience integrating compliance through integrated networks, supporting the company via program training, communique, and internal client engagement.
• High level of professional maturity and sensitivity to confidentiality
• Ability to handle multiple projects in a fast-paced environment and quickly step in in situations where resources may be restricted, or timing is constrained.
• Excellent interpersonal, strategic thinking, communication, and organizational skills.
• Proven ability to educate internal clients on complex compliance, integrity and privacy processes, procedures, and risks associated with awareness education.

Additional Skills & Preferences:

• Strong business acumen and mindset towards collaboration
• Strong ability to develop ideas visually and communicate messaging and guidance to senior leaders with a dedicated following
• Demonstrated and recognized E&C leadership in the field
• Six Sigma certification obtained or actively pursuing
• Consistent support to DE&I initiatives throughout the professional career