Compliance & Ethics Assoc Manager SoCo
The position of SOCO Compliance & Ethics Manager has day-to-day, cluster-wide responsibility for promoting, monitoring, and enforcing the PepsiCo Compliance Program. In this role, the SOCO Compliance and Ethics Manager will need to regularly interact with, collaborate with and influence higher banded leadership (GM, CFO, CHRO, GC, and Controller) as well as other key Legal, HR, Control, Security, and Operations colleagues.
The SOCO Compliance and Ethics Manager will implement the strategic direction for the Cluster Compliance Program based on internal and external factors, such as market and cultural realities, internal risk assessments and regular analysis of Speak Up trends and other data. A key part of the role includes promoting, through training and coordination of senior leadership messaging, a country culture that is committed to high integrity performance amidst financial pressure to perform. Individual will also oversee the monitoring of the cluster environment and the effective operation of the SpeakUp complaint and escalation system and procedures to ensure the appropriate and timely response to issues, including Potentially Significant Violations of the Code of Conduct (PSVs). This position will also be charged with managing the investigation and enforcement decisions resulting from substantiated violations of the Code of Conduct within the Country.
Notably, the SOCO Compliance and Ethics Manager will need the personal fortitude to bear the formal responsibility and potential exposure, through quarterly representation letters, that the position requires despite limited resources.
- Shape the Country-wide Compliance Program, consistent with PepsiCo’s Global Compliance Program, Values and Code of Conduct.
- Primary responsibility for the management of the PepsiCo ethics hotline calls (“Speak Ups”) and other potentially significant violations of the PepsiCo Code of Conduct for SOCO (Volume of around 100 matters annually).
- Act as point person for engagement with HR, R&IC, Legal and Corporate Security business partners in providing assistance in investigation of ethics hotline calls and delivering analytics reporting, including quarterly & monthly sector/regional metrics and trend analysis.
- Primary responsibility for managing Potentially Significant Violations (PSV) & complaints to the CEO and/or her direct reports (Chairman’s Case) investigations including creating the investigation plan, conducting interviews, reviewing data, facilitating group calls and preparing closing reports for each matter
- Preparing & presenting live training and webinars on C&E agenda topics such as Speak Up onboarding, Investigations and Writing Closing Reports
- Act as Code of Conduct Training Program C&E Lead including participating in review of Conflicts of Interest disclosures with Control & Legal teams and managing any necessary action plans to resolve conflicts for Salaried & Frontline employees
- Facilitate Foods sector Control Environment Council (CEC) meetings including preparing quarterly materials and participating in meetings with Sr. Leaders.
- Work collaboratively with the Global C&E team on projects or other assignments from the Chief C&E Officer and/ or Sector C&E Officer
- Work jointly with the global team in the third party due diligence project.
- Proactively identify potential compliance vulnerability in the Cluster.
- Remain up to date with market and legal trends regarding areas of high risk.
- Promote, monitor and enforce compliance in the Cluster on key issues, including anti-bribery/corruption and the Foreign Corrupt Practices Act (the “FCPA”).
- Develop and “bring to life” PepsiCo and Sector/Region/Country policies, procedures and controls to meet the objectives of the Compliance Program.
- Strong communication skills, including ability to present material in front of groups
- Ability to work independently and manage multiple, deadline-driven priorities in a fast-paced work environment
- Strong Excel & PowerPoint skills with ability to analyze and creatively display data in multiple presentation formats
- Process oriented & highly organized with strong attention to detail and discretion in dealing with sensitive and confidential information
- Bachelor’s Degree required
- Prior experience in Compliance & Ethics preferred
- Periodic travel required
- Proven track record of influencing the organization, including more senior colleagues.
- Total team player who must oversee broad proactive agenda, while keeping daily, vigilent watch over specific issues.
- Fluency in English – speaking and writing.
Job Type: Regular