Ethics & Compliance Senior Manager

at  Brother USA

LET’S GROW TOGETHER

Our mission is to live our “at your side” promise and simplify and enrich the lives of our customers, employees, and communities. “At your side” is more than a slogan to us; it’s the purpose we do our best to fulfill every day. With a legacy spanning over a century, this is a great place to launch or expand any career and push the boundaries of what comes next. We’re committed to achieving shared success, and we provide opportunities for you to develop through experience, exposure and education. Our people have always leveraged their unique perspectives to keep us on the right track for a lasting future. If you want to innovate, learn, and grow with a global leader that builds products, services, and a company people love, then we’ll be “at your side” every step of the way.
The Senior Manager, Ethics & Compliance has responsibility for investigating allegations of violations of Company policy, our Code of Conduct, and other internal matters which may be confidential or sensitive, including disclosures for potential conflicts of interest, fraud, corruption, bribery, or other ethical misconduct. This role works closely with employees and managers in an approachable and confidential manner to determine appropriate steps for resolution, investigates allegations of unethical activity to mitigate the possibility of future misconduct, and develops effective Ethics and Compliance communication and reporting for Brother. This role will also play a key role in the Privacy, Forced Labor, and Product Regulatory programs and support a range of compliance activities, such as maintaining and communicating compliance policies, updating compliance education programs, process development, implementation, and monitoring. The Senior Manager, Ethics & Compliance manages a team of Compliance professionals.

Compliance Education

• Lead administration of and reporting based on E&C software and learning management systems
• Partner with team members to update and refresh annual compliance training
• Support team efforts to select training assignees and track progress to completion
• Prepare and conduct ad hoc compliance training as needed to address risks
• Promote a culture of Ethics and Compliance through the development, delivery, and tracking of education and awareness training programs and presentations for all Brother Americas employees, management, and contractors through the development and implementation of the annual E&C communication plan and ancillary schedules
• Periodically review and continuously improve content and method of training provided under Ethics and Compliance by partnering with internal stakeholders and liaising with experts regarding instructional design
• Organize quarterly Ethics and Governance Committee (EGC) and Advisory member meetings by creating agenda based on Ethics and Compliance team deliverables and metrics
• Host and deliver train-the-trainer sessions for internal compliance subject matter experts
• Using known education principles, lead team in assessing instructional effectiveness and determine the impact of training on employee knowledge and KPI

WHAT YOU’LL DO

Ethics Investigations

• Collaborate with the Director, Risk, Compliance, and Assurance on high risk investigations including participating in decision-making discussions, assisting with interviews, analyzing documents, data, evidence, and drafting investigation reports
• Act as lead on mid-risk investigations in collaboration with the Director and delegate lower risk investigations and support from Compliance Manager as needed
• Manage the Compliance Hotline including triaging reports, coordinating investigations with other corporate functions, interacting with reporting persons on a confidential or anonymous basis and ensuring the final investigation report provides the information required to support the conclusions reached and actions taken
• Identify, execute, and drive investigation steps
• Perform data analytics to identify patterns and trends, anomalies or systemic issues
• Communicate investigation updates to Executives and Company committees
• Create report summaries of work performed, evidence identified, and conclusions reached
• Ensure the validity and reliability of investigation data used to create dashboard statistics for reports to Executives and/or Executive Committee
• Collaborate and/or lead the implementation and maintenance of policies and procedures to support the investigations process
• Partner with other project managers/departments to track remediation efforts to ensure adequacy and timeliness of any disciplinary and/or corrective action
• Follow up to ensure adequacy and timeliness of any disciplinary and/or corrective action

Data Privacy Oversight

• Collaborate with Director, Risk, Compliance, and Assurance to build and manage Americas regional privacy and security compliance program to address applicable laws, regulations, standards, and legal obligations
• Manage, draft, and update privacy and security policies and related SOPs
• Work with cross-functional teams including IT and Legal to help develop, implement, and validate privacy and security controls such as data lifecycle management policies and tools
• Conduct and/or oversee privacy and security risk assessments, including data protection impact assessments, to identify risks and propose risk mitigation measures
• Manage Data Privacy Impact Assessment process to ensure it has the appropriate risk-based approach and balances risk management with speed and agility for the operation
• Develop standardized processes, technical solutions, and knowledge sharing tools
• Develop and/or maintain dashboards for the Privacy program

Compliance Program Management

• Develop methods to promote and bring awareness of the Ethics and Compliance (E&C) program and expectations of Brother’s business ethics policies
• Proactively advocate for the integration of ethical organizational practices and a commitment to compliance in all aspects of the business
• Draft, conduct, and provide analysis and reporting of periodic E&C risk assessments, including partnering with various stakeholders to identify areas of weakness and recommended control enhancements
• Liaise with Latin America, US, and Canada offices by collaborating with the Advisory Committees in each subsidiary to provide and maintain support for implementation and continuous improvement of the E&C program
• Address any other areas deemed necessary to ensure the effective operation of Brother’s E&C Program
• Third Party Due Diligence: Evaluate escalated third-party due diligence red flags and either clear or escalate to Director for guidance
• Forced Labor Program: Assist in building and responsible for overall management of the Forced Labor program ensuring it effectively manages the risk while remaining practical and user friendly to Brother’s operations and third-party relationships
• Record Retention: Lead and act as the key point of contact for Brother’s Records Retention Program and ensure the program’s effectiveness and continuous improvement
• Product Compliance: Assist in building and responsible for overall management of the Product Compliance program ensuring it effectively manages the risk
• Maintain requisite knowledge of compliance and ethics and related fields by participating in relevant professional organizations and conferences, seminars, and meetings

Compliance Education

• Lead administration of and reporting based on E&C software and learning management systems
• Partner with team members to update and refresh annual compliance training
• Support team efforts to select training assignees and track progress to completion
• Prepare and conduct ad hoc compliance training as needed to address risks
• Promote a culture of Ethics and Compliance through the development, delivery, and tracking of education and awareness training programs and presentations for all Brother Americas employees, management, and contractors through the development and implementation of the annual E&C communication plan and ancillary schedules
• Periodically review and continuously improve content and method of training provided under Ethics and Compliance by partnering with internal stakeholders and liaising with experts regarding instructional design
• Organize quarterly Ethics and Governance Committee (EGC) and Advisory member meetings by creating agenda based on Ethics and Compliance team deliverables and metrics
• Host and deliver train-the-trainer sessions for internal compliance subject matter experts
• Using known education principles, lead team in assessing instructional effectiveness and determine the impact of training on employee knowledge and KPIs

Strategic Planning and Leadership

• Act as a change agent to drive ethics and compliance cultural change and inspire others to action through collaboration and influence
• Create, implement and manage project plans related to the Brother Compliance programs
• Set measurable targets and implement management programs that include designation of responsibility, resources and timelines
• Manage annual budget and monitoring for data privacy, forced labor program, third party due diligence and compliance programs related to team expenditures and improvement efforts
• Establish and cultivate positive working interactions with co-workers and team members with the intention to exceed their expectations
• Use a structured approach to organizing work including planning, ability to judge and prioritize critical issues, and attention to detail
• Lead and facilitate special projects as needed

Monitoring and Reporting

• Routinely monitor the effectiveness of the E&C program, review reports from internal compliance audits, investigations, and external assessments for the purpose of identifying troublesome issues and deficient areas, and implement corrective and preventative action
• Review and analyze employee reports in HelpLine and take necessary actions to address or manage identified risks
• Create and present staff meeting presentations regarding E&C activities as needed
• Provide reports to BIL on various E&C initiatives as required

ADDITIONAL DETAILS FOR THIS ROLE

This role will be a hybrid role. Subject to business needs, employees may work remotely up to two days per week. Assigned office days will be determined by managers. #LI-Hybrid

• The salary (or hiring) range for this position is $135,000 - $155,000 per year
• Starting salary to be determined by the education, experience, knowledge, skills and abilities of the applicant, internal equity, location, and alignment with market data
• This position is eligible to participate in the relevant Brother variable pay incentive plan(s). Applicable bonus awards are discretionary and contingent upon 1) achievement of your individual objectives and 2) Brother achieving its corporate and business-level objectives
• Benefits include, but are not limited to, healthcare and wellness coverage, life and disability insurance, 401K, tuition reimbursement, and Paid Time Off. Details are available at https://mybenefits.nfp.com/Brother/2024/guidebook/