Senior Manager Ethics & Compliance
Qnity · Wilmington, DE · Yesterday
HybridFull-time
Key Responsibilities
- Investigations Program Lead
- Serve as the primary US-based investigations lead — taking complex matters involving fraud, bribery and corruption, conflicts of interest, export controls violations, and Code of Conduct breaches from intake through resolution and corrective action.
- Conduct structured interviews, manage evidence collection, determine root cause, and author defensible investigation reports for senior leadership and, where applicable, regulators or external counsel.
- Provide backup coverage for global and cross-jurisdictional matters; partner with Legal, HR, and Security on case strategy, procedural fairness, and remediation.
- Manage and report on investigations volume, case aging, and corrective action trends as part of the program’s board-ready metrics.
- FCPA / Anti-Corruption + Third-Party Risk
- Leverage existing TPRM process to enhance overall TPRM lifecycle program — from a consolidated global third-party master list and risk-tier model to Tier-1 audits, ongoing monitoring, and contractual compliance.
- Mature current third-party due diligence practices by focusing on risk factors — geography, service type, government touchpoints, and spend — across suppliers, customers, distributors, and agents to build strategic reviews.
- Lead in-person ABAC training at high-risk global sites; embed standard anti-corruption and right-to-audit clauses on every contract renewal; centralize the contract repository.
- Drive continuous monitoring — replacing point-in-time onboarding with a defensible, audit-ready program that can withstand “show us your TPRM” scrutiny at a first DOJ interview.
- Coordinate with Procurement, Legal, and Internal Audit across the full vendor lifecycle; chair the cross-functional TPRM Council as the program matures.
- M&A Integrity
- Develop a charter for compliance’s seat at the Corporate Development intake table and establish the governance MOU with Strategy/M&A and Legal.
- Develop the core toolkit — Integrity Questionnaire, key-personnel interview guide, sanctions/PEPs/adverse media screening playbook, and reps-and-warranties language coordinated with Legal.
- Deliver the M&A Integrity Package on live deals: go/no-go compliance input and integration remediation plan; conduct the 100-day post-close audit with owner-tagged milestones.
- Integrate acquired third parties into TPRM and analytics monitoring; ensure the pre-acquisition diligence prong is fully evidenced for DOJ review.
- Program Analytics & Reporting
- Maintain dashboards, metrics, and trend analyses that provide leadership with clear visibility into investigations activity, speak-up volume, TPRM outcomes, and overall program health.
- Translate data into board-ready insights — surfacing hotspots, emerging risks, and mitigation recommendations; support the analytics foundation as the program’s dedicated analytics hire onboards.
- Champion data quality and automation improvements within case management and TPRM platforms.
- Team Leadership & Stakeholder Engagement
- Lead, coach, and develop team members — setting clear expectations, providing ongoing feedback, and building individual capability aligned to the program’s five strategic priorities.
- Translate the Senior Director’s strategic direction into execution-ready workplans across investigations, TPRM, and M&A workstreams.
- Represent Ethics & Compliance in internal governance forums — with Legal, Internal Audit, Finance, Corp Dev, and Procurement — and partner with business leaders on risk identification and culture-building initiatives.
- Contribute to policy updates, training content, and cross-functional initiatives that strengthen controls and advance the company’s culture of integrity.
- 10+ years of progressive relevant experience in ethics & compliance, internal investigations, FCPA/anti-corruption, or enterprise risk management — ideally spanning both a program-build and steady-state operation.
- Demonstrated expertise leading complex, multi-jurisdictional investigations and third-party risk programs with strong judgment on sensitive matters.
- Experience with or strong familiarity with DOJ ECCP expectations — able to architect a program that is defensible, evidenced, and adequately resourced under current standards.
- Comfort operating across TPRM, M&A due diligence, and analytics — this role covers significant ground and requires range.
- Proficiency with data, dashboards, and case management or TPRM platforms; ability to translate program data into leadership-ready insights.
- Excellent communication, interviewing, and executive stakeholder engagement skills; proven ability to build trust across Legal, Finance, Internal Audit, and business partners.
- Bachelor’s degree required; advanced degree or professional certification strongly preferred (CFE, CPA, ACAMS, or equivalent).