Counsel, Investigations

at  IBM

Introduction
At IBM, work is more than a job - it’s a calling: To build. To design. To code. To consult. To think along with clients and sell. To make markets. To invent. To collaborate. Not just to do something better, but to attempt things you’ve never thought possible. Are you ready to lead in this new era of technology and solve some of the world’s most challenging problems? If so, lets talk.
Your Role and Responsibilities
Corporate Legal Investigations (“Investigations”) is responsible globally for handling privileged and sensitive investigations of matters that present significant legal, financial and reputational risks to the company. You will be conducting complex, cross-border internal investigations in all jurisdictions where IBM maintains business operations and will be part of a team that handles such matters that arise globally, with a primary focus on Europe, Middle East and Africa (EMEA). Your role will sit within IBM’s legal department reporting to the Head of Investigations for EMEA.
As Counsel in the Investigations team, you will work on and oversee cross-border matters involving allegations of, among other things, violations of criminal and civil regulatory statutes and violations of IBM’s Business Conduct Guidelines, with a focus on EMEA.
In the course of your work, you will direct investigators, and collaborate closely with other IBM stakeholders, including Trust & Compliance, Litigation, HR, Internal Audit and IBM business units. You will also assist with engaging with and managing outside counsel, where needed, and engaging with external parties such as regulatory bodies and law enforcement.
The Investigations organization has overall responsibility for conducting the investigations, the content of final reports and alignment on disciplinary actions, process recommendations and other actions. As such, you will also be responsible for regular reporting on developments in investigations to Investigations management and the General Counsel as well as to the company’s senior management and the Audit Committee of the Board.

Investigations frequently involve allegations relating to:

• Misconduct, wrongdoing or failure to act by IBM senior management members;
• Violations of criminal laws such as bribery, money-laundering, insider trading;
• Non-compliance with laws or corporate policies by a Business Partner or supplier;
• Matters that may have significant revenue recognition, accounting, auditing or financial statement impacts;
• Sensitive government requests and investigations by law enforcement and regulatory entities;
• Antitrust/competition law and sensitive data privacy and cybersecurity matters.

Required Technical and Professional Expertise
You must be a licensed attorney with significant experience in white-collar criminal defense, internal investigations and regulatory enforcement, whether from similar in-house positions, outside counsel positions and/or government service.You must demonstrate excellent written and verbal communication skills, strong interpersonal skills, and an ability to effectively engage with individuals at all levels of seniority. Experience designing complex investigation plans; collecting, organizing and reviewing large volumes of data; using data review platforms; conducting interviews; drafting reports; and presenting findings. Must be collaborative, collegial and possess critical thinking skills. Flexibility and facility with respect to collaborating with employees across geographies and cultures. Substantive knowledge of the Foreign Corrupt Practices Act and similar laws in the EMEA region as well as accounting fraud are strongly preferred. Some travel required.
Preferred Technical and Professional Expertise
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About Business UnitIBM Corporate Headquarters (CHQ) team represents a variety of functions such as marketing, finance, legal, operations, HR, and more, all working together to solve some of the world’s most complex problems, help our clients achieve success and build collaborative work environments for IBMers.
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