Senior Manager - Global Ethics and Business Integrity

Bunge Limited•Chesterfield, MO

8d•Hybrid

About The Position

Develop and manage a multifaceted ethics, compliance and training program that ensures all appropriate employees and management are knowledgeable of, and comply with, pertinent standards. Coordinate or lead internal compliance reviews, risk assessments, and compliance monitoring activities. Conduct or support thorough investigations of a wide range of misconduct and policy violations occurring within Bunge’s global operations, but primarily in support of the North America region. Coordinate and lead Global Ethics and Compliance (GEC) projects. Collaborate with other Bunge functions such as Global Internal Audit, Finance, Legal, Enterprise Risk Mgt. and Controllers in risk mitigation activities. Develop, coordinate, and lead a multifaceted educational and training program that focus on the elements of the ethics and compliance program, and seek to ensure that all appropriate employees and management are knowledgeable of, and comply with, pertinent standards. Coordinate internal compliance reviews, risk assessments, and monitoring activities. Provide operational leadership or support to all GEC functions. Provide concise and meaningful information to Global Internal Audit, Board of Directors committees, and to business management teams, including senior management. Lead and assist with special projects. Serve as a consultant to other GEC members and participate / support global GEC projects. Coordinate and manage relationships with third party suppliers and vendors supporting GEC’s compliance programs and controls. Create and present official reports on GEC activities and metrics focusing on Global Ethics and Investigations (GEI). Manage subordinates on as needed / project basis. Oversee the issuance of all GEC reports. Manage GEC computer systems focusing on GEI (case management system, learning management system, helpline, SAP access, telephone records access, etc.) Manage GEI global Root Cause Analysis and Management Action Plans resulting from investigations. Manage global policy familiarization program. Conduct or support investigations of alleged or suspected violations of criminal law and corporate policies. Gather, review, and analyze data in support of investigations. Prepare workpapers to adequately document investigations performed with supporting evidence for all findings. Conduct investigative interviews. Consult with the Legal Department to ensure consideration of attorney-client privilege in connection with compliance-related investigations and work under the direction of the Bunge Legal Department on privileged matters. Prepare clear, concise and cohesive investigative reports and memoranda in a timely manner. Identify and define compliance, fraud and misconduct issues including root causes, and provide effective recommendations and solutions. Ensure the Company’s case management system is updated with status and outcome of assigned investigations. Testify and present evidence at administrative and criminal court proceedings. Support the Bunge Corporate Security program. Up to 20% of Domestic & International travel is required. Telecommuting permitted up to 2 days per week with manager approval.

Requirements

Bachelor’s degree, or foreign equivalent, in Accounting, Law, Criminal Justice, Business Administration, or related
10 years of professional experience in the area of corporate ethics and compliance in a multi-national company
Fraud and corruption investigation skills and experience including data and evidence collection and analysis, interview and interrogation, report writing, investigative case management, and leading investigations
Project management skills related to enterprise training development and deployment, Governance, Risk & Compliance management systems evaluation and deployment, compliance awareness campaign development and deployment, anti-corruption review projects, and organizational performance and effectiveness monitoring
Experience auditing and analyzing a wide range of data (financial data, communications data, expense data, HR records, computing logs, access logs, electronic and video surveillance data, business policies / processes and operations) to effectively reach investigative conclusions and project management needs
Experience using data analytics tools and software, financial analysis, operational and financial control systems analysis, and applying financial audit regulatory requirements
Knowledge of US Dept of Justice Federal Sentencing Guidelines for ethics and compliance programs, and US state and federal laws regarding fraud and FCPA
Knowledge of widely used compliance policies such as Code of Conduct, Supplier Code of Conduct, Anti-Corruption, Conflicts of Interest, Gifts & Entertainment, and Charitable Contributions & Insider Trading
Risk assessment skills and experience related to fraud risk assessments, compliance risk assessments, and security vulnerability assessments
Must be a CFE (Certified Fraud Examiner) and CCEP (Certified Compliance and Ethics Professional)

Responsibilities

Develop and manage a multifaceted ethics, compliance and training program
Coordinate or lead internal compliance reviews, risk assessments, and compliance monitoring activities
Conduct or support thorough investigations of a wide range of misconduct and policy violations
Coordinate and lead Global Ethics and Compliance (GEC) projects
Collaborate with other Bunge functions in risk mitigation activities
Develop, coordinate, and lead a multifaceted educational and training program
Provide operational leadership or support to all GEC functions
Provide concise and meaningful information to Global Internal Audit, Board of Directors committees, and to business management teams
Lead and assist with special projects
Serve as a consultant to other GEC members and participate / support global GEC projects
Coordinate and manage relationships with third party suppliers and vendors supporting GEC’s compliance programs and controls
Create and present official reports on GEC activities and metrics focusing on Global Ethics and Investigations (GEI)
Manage subordinates on as needed / project basis
Oversee the issuance of all GEC reports
Manage GEC computer systems focusing on GEI
Manage GEI global Root Cause Analysis and Management Action Plans resulting from investigations
Manage global policy familiarization program
Conduct or support investigations of alleged or suspected violations of criminal law and corporate policies
Gather, review, and analyze data in support of investigations
Prepare workpapers to adequately document investigations performed with supporting evidence for all findings
Conduct investigative interviews
Consult with the Legal Department to ensure consideration of attorney-client privilege
Prepare clear, concise and cohesive investigative reports and memoranda in a timely manner
Identify and define compliance, fraud and misconduct issues including root causes, and provide effective recommendations and solutions
Ensure the Company’s case management system is updated with status and outcome of assigned investigations
Testify and present evidence at administrative and criminal court proceedings
Support the Bunge Corporate Security program