Geode Capital Management, LLC (“GCM”) is a global institutional asset manager providing core beta exposures across a range of equity and niche asset classes, including commodities and options, for registered funds, commingled pools and separately managed accounts. Geode currently manages over $1.5 trillion in AUM across the products it advises and sub-advises.
Geode is looking for a highly motivated Senior Compliance Associate to implement the firm’s ethics programs. This role ensures adherence to internal codes of ethics, regulatory standards, and industry best practices. The Senior Compliance Associate will lead efforts to identify, assess, and mitigate ethical risks, promote a culture of integrity, and support the firm’s fiduciary responsibilities to clients and stakeholders. This role will report to the Director, Compliance.
This role is based out of our office in Boston, Massachusetts and is required to follow the firm’s current hybrid work schedule: Tuesday, Wednesday and Thursday in-office, with the option to work Monday and Friday remote from home.

SKILLS YOU BRING:

• 5-10 years of experience working in an Investment Adviser compliance program, preferrable in an ethics function.
• Bachelor’s degree (or above) in a relevant field.
• A strong understanding of SEC regulations, with a particular focus on the Investment Advisers Act of 1940.
• Experience with overseeing compliance monitoring systems (StarCompliance or MyCompliance Office preferred) and demonstrated knowledge of Code of Ethics requirements.
• Excellent communication skills, both written and verbal with an ability to effectively interact and influence at all levels.
• Strong sense of ownership and accountability.
• Strong relationship building, organization, and critical thinking skills are crucial for success in this role.
• Ability to manage high volume of work within tight deadlines, ensuring accuracy and minimizing risk through effective task prioritization.
• Dedicated to collaborating in a fully inclusive manner.

• Administer Geode’s Code of Ethics Program including policies governing personal trading, gifts and entertainment, outside business activity, political contributions, and conflicts of interest.
• Lead the compliance training programs for new hires and firm-wide continuing education programs and assist with the development of compliance training materials.
• Serve as primary contact for responding to Code of Ethics policy questions.
• Act as administrator and systems expert for the ethics system Geode uses to administer the Code of Ethics and other ethics related policies.
• Monitor employee disclosures and conduct periodic reviews of ethics-related activities. Investigate potential ethics violations and recommend appropriate corrective actions.
• Perform periodic reviews of personal trade activity and identify opportunities to conduct forensic testing based on observed patterns and risks.
• Facilitate quarterly, annual, and ad hoc compliance certifications.
• Coordinate with brokers for addition of new brokerage accounts or to code new broker feeds into compliance system.
• Perform ongoing review of electronic business communications to identify instances of non-compliance with policies and procedures.
• Maintain accurate records of ethics reviews, investigations, and disclosures. Prepare reports for senior management, regulators, and Board reporting as needed.
• Identify, present recommendations, and ultimately implement solutions for improving processes within the program to build efficiencies and improve workflows, including updates to the Code of Ethics Policy.
• Maintain strong working knowledge of the firm’s compliance policies and procedures.