• Ensuring an effective compliance program is established and internal controls are in place and support business compliant solutions
• Promoting a value based compliance culture through communication and training initiatives throughout the Business.
• Supporting early and proactive identification of risks in all aspects of the Business’ strategy and activities.
• Advising senior leaders in the business on risk associated with emerging business strategies and pragmatic options for risk mitigation.
Scope of responsibility
• Working with business leaders, Global Compliance, Audit and Assurance, and other support functions to embed a Values-based culture and accountability for compliance within the business in a way that supports the business unit and GSK strategies.
• Driving accountability throughout the organisation toward greater business transparency and reinforcing trust in GSK from customers, business partners and patients.
• Partnering with business leaders to support proactive mitigation or risks and prompt responses to issues to appropriately minimise potential impact to GSK.
• Acting as a change leader for cutting edge practices and standardisation, where appropriate, to simplify the complexity of our practices.
• In collaboration with the business and other stakeholders, developing and implementing tools which empower our employees to make ethical and compliant decisions.
Oversight (Risk Management, Compliance and Governance Framework)
• Sets minimum governance framework expectations and ensures effectiveness
• As the risk management process owner ensures the Business Unit (BU) has an effective Risk Management and Compliance strategy.
• Drives the development of the local Risk Management and Compliance Board (RMCB) agenda and ensures appropriate visibility and mitigation of significant compliance-related issues (e.g audit outcomes investigations, compliance initiatives such as Anti-Bribery And Corruption (ABAC)).
• Understands the remit of the supporting governance groups / committees and key results, and has assurance that the governance framework effectively manages all significant BU risks. Represented in key Governance Boards
• Participates in content development and facilitates the implementation, communication and reinforcement of the GSK Code of Conduct.
• Provides advice on interpretation on GSK wide standards & policies.
• Ensures that the development, review and roll out of Corporate Policies are done effectively within the BU.
• Ensures the appropriate implementation of a controlled document process for BU specific policies.
• Facilitates coordination of cross- BU Policy development.
Training and Education
• Ensures that training and education is built in into the culture and practice in the business and raises to management if this is not the case.
• Compliance responsibility may include collaborating with the business to create the curriculum and developing content for training.
• Ensures roll out within the respective BU of training for GSK-wide Compliance initiatives (e.g., ABAC, Data Privacy) in partnership with the Policy Owner
• Works with the business to establish minimum expectations on monitoring, globally (focusing on significant risks).
• Check that appropriate Level 1 and Level 2 monitoring is in place and robust and proposes enhancements.
• Supports, advises and reinforces communication on ethics and values, learning from mistakes and previous problems, and communication to units to avoid repetition of previous errors/breaches.
Responding to Detected Problems
• Responsible for investigations; may either lead or delegate as appropriate to other individuals outside of Compliance. In such case, sets minimum expectations / standards and provides oversight.
Discipline and Enforcement
• Collaborates with other Compliance Departments to enable consistent input into disciplinary discussions.
Risk Identification and Treatment (Risk Management)
• Facilitates the BU level risk identification and management process.
• Assists with setting of BU risk appetite and assures that accountability for risk treatment plans is defined and executed
• Supports the BU in driving a risk management culture
• Conducts annual / ongoing review with Leadership Team of BU’s most significant risks
• Partners with the Leadership Team and the business and provides risk & compliance advice and expertise for business strategies and activities.
Other activities – Audit
• Provides advice / input to Audit & Assurance in the development of their audit universe, annual audit program (schedule), and individual audit engagements
• Assists BU in the preparation for audits and development and closure of CAPAs for significant findings from Level 3 audits
• Compliance and Audit Lead interact to determine level of direct involvement of individual audits (e.g. Closing Meeting)
• Sets the tone with Management to engage Audit constructively to decide CAPA and carry them out.
• Plays a Mediator role between Audit & Assurance and Auditee to make sure the company’s best interest is represented
Other activity – Upward Reporting
• Facilitates and coordinates escalation of significant compliance issues to ROCC and ARC (6x/year+ annual report)
• Assists with writing and works with BU to develop the ARC annual Report
Other Activities – Company Wide Projects
• Responsible for deploying Ethics & Compliance generated Projects
Responsible for assisting and tracking (as appropriate) the implementation of CET endorsed projects to determine appropriateness of BU approach and plans
Knowledge & Capabilities Required
• Bachelors Degree in Business Administration, Law, Finance, or other applicable degree
Demonstrated experience in the current selling and marketing, medical, or regulatory environment of pharmaceutical products.
• Demonstrated significant compliance and/or internal control experience in a global pharmaceutical, related healthcare organisation, or consultancy firm supporting healthcare clients.
• Ability to work effectively and sensitively in a highly matrixed organisation across geographies and cultures.
• Track record in providing high degree of reliance, accountability, and value-added consultation/support to senior business managers and other support functions.
• Ability to maintain confidentiality and trust around sensitive compliance issues.
• Strong interpersonal skills with the ability to influence individuals at all levels of the organisation to work in accordance with company Values.
Proven track record in being able to analyse complex situations to determine root cause.