Come Work at HJF!
HJF is seeking a Vice President of Compliance to support the Administration at the Corporate Headquarters in Bethesda, Maryland. This position is a Vice President level position and reports directly to the President and Chief Executive Officer and to the Audit Committee of the Council of Directors. The principal responsibility of the VP of Compliance is to establish, maintain, and oversee an effective compliance and ethics program for the Foundation and its subsidiaries and affiliates that is consistent with: (1) the provisions of the Federal Sentencing Guidelines established by the United States Sentencing Commission; and (2) such other statutory, regulatory and ethical requirements as may be applicable to the Foundation. The VP of Compliance is responsible for establishing standards and implementing procedures to ensure that the compliance programs throughout the organization are effective and efficient in identifying, preventing, detecting and correcting noncompliance with applicable rules and regulations.
- Manages ambiguity - operates effectively, even when things are not certain or the way forward is not clear.
- Collaborates- builds partnerships and works collaboratively with others to meet shared objectives.
- Drives results- consistently achieves results, even under tough circumstances.
- Cultivates innovation- creates new and better ways for HJF to be successful.
Job Responsibilities: 95% of time
- Providing guidance to the Council of Directors, senior management, staff, and employees on compliance;
- Overseeing and monitoring the implementation of the Ethics and Business Conduct program;
- Developing the annual compliance work plan that reflects the Foundation’s highest risks that will be monitored by the compliance function as determined by conducting an annual risk assessment using an enterprise wide approach;
- Directly supervising the Ethics and Business Conduct Department, Internal Audit and the Information Governance/Records Management functions;
- Coordinating regularly with the Office of Regulatory Affairs, the Global Information Security, Human Resources and Legal Departments and as needed with Subject Matter Experts across HJF;
- Reporting on a regular basis the progress of implementation, and assisting others within HJF on establishing methods to improve efficiency and quality of services, and to reduce the vulnerability to fraud, waste, and abuse;
- Periodically revising the Ethics and Business Conduct program in light of changes in the needs of the organization, and in relevant laws and regulations;
- Developing policies and programs that encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation;
- Supervising the development of, and coordinating and participating in, a multifaceted educational and training program that focuses on the elements of the compliance program, and seeks to ensure that all appropriate employees and management are knowledgeable of, and comply with applicable laws, regulations, and policies;
- Responding to government investigations and queries as the principal point of contact, in coordination with the Legal Department;
- Independently investigating and acting on matters related to compliance, including the flexibility to design and coordinate internal investigations (e.g., responding to reports of problems, “hot-line” calls, or suspected violations) and any resulting corrective actions with all health system departments, providers and sub-providers, agents and, if appropriate, independent contractors;
- Maintaining current knowledge of laws and regulations, keeping abreast of recent changes; and
- Monitoring external audit review processes and maintaining awareness of compliance issues, and in conjunction with the relevant departments and senior management, responding to administrative inquiries related to compliance issues or audits.
The specific duties and responsibilities of the Vice President, Compliance include, but are not limited to, the following:
Tone at the Top
Working with other senior management to establish a “tone at the top” that reflects the Foundation’s commitment to ethical business conduct and compliance with the letter and spirit of the law in all aspects of the Foundation’s and its subsidiaries operations, both domestic and international.
Ethics and Business Conduct
Having responsibility for overseeing the Foundation’s Ethics and Business Conduct Department, which has principal responsibility for the administration of the Foundation’s Ethics and Business Conduct Program and Code of Ethics (Code), including:
- Revising and updating the Code, from time to time as may be appropriate;
- Providing Foundation employees, in coordination with the Legal department, with advice interpreting the provisions of the Code;
- Taking such actions as may be appropriate to investigate and enforce the Code;
- Managing conflict of interest reporting and mitigation plans
- Creating, publishing, maintaining, and interpreting such additional policies and procedures as may be appropriate to fully implement the provisions of the Code or to otherwise meet the requirements of applicable statutes, regulations, or ethical standards;
- Managing the Foundation’s Ethics Hotline.
- Working closely with the Audit Committee of the Council (and the full Council as appropriate) to undertake such compliance related activities as the Council may direct or may otherwise be required, including keeping the Council apprised of the following in a timely manner:
- The content and operation of the Ethics and Business Conduct Program so as to enable the Audit Committee and the Council to exercise reasonable oversight for the Ethics and Business Conduct Program;
- Whether the Ethics and Business Conduct Program has adequate resources; and
- Any allegations against an officer of the Foundation; where the allegations involve significant accounting or financial improprieties; or where, if proven true, the actions or failure to act would have a significant impact on the Foundation; or any other conduct by an employee which the Chief Compliance Officer believes should be brought to the Council’s attention.
Investigations and Internal Audits
- Coordinating and overseeing all internal investigations and Internal audits (including international audits) and/or Compliance Management functions of the Foundation’s Ethics and Business Conduct department, Finance Department, and Human Resources department where such internal resources and expertise are sufficient and senior management, (VP and above) are not principally implicated;
- Managing, in coordination with the Foundation Legal department, outside independent investigators where it is appropriate for independent investigations rather than internal investigations to be conducted; and
- Determining and causing remedial measures to be implemented, based on the findings of an investigation and for revising or modifying the Ethics and Business Conduct Program, if appropriate, to prevent and deter future similar misconduct.
- Supervising the Foundation’s Information Governance/Records Management Officer, who manages:
- The Foundation’s Information Governance/Records Management policies; and Compliance with prescribed Foundation policies and practices.
- Directing and/or participating in regular risk assessments of the activities and operations of the Foundation, the results of which shall be used to, among other things, establish or appropriately modify the components of the Ethics and Business Conduct Program and Ethics Hotline;
- Coordinating with the Foundation Finance department with respect to risk management functions
- Having responsibility for coordinating on compliance goals and processes with the Foundation’s Regulatory Affairs Department, whose responsibilities include the following:
- To acquire and maintain accurate and complete documentation of all studies involving human subjects and animals;
- To monitor and ensure compliance on research conducted through HJF.
Cybersecurity, Safety, and Facilities Security
- Coordinating with the Foundation’s Global Information Security department to help ensure compliance with cybersecurity laws, regulations, and policies;
- Coordinating with the Foundation’s Safety and Facilities Security Officers to help ensure compliance with applicable laws, regulations, and policies.
Training and Communications
- Coordinating with the Training office of the Human Resources Department on appropriate training for employees of HJF and its subsidiaries and affiliates to help ensure and promote compliance with all applicable laws and regulations;
- Training Foundation managers about how to maintain an open working environment where employees feel free to raise issues without fear of retaliation, how to respond to an employee’s complaint and when to refer it to the Ethics and Business Conduct department, and that retaliation against any employee raising a good faith complaint or participating in a Company authorized investigation is the basis for disciplinary action.
- Implementing and conducting an effective compliance training and communications program, including:
- Providing compliance related training for the Council of Directors, executive and senior level management, and all other employees which shall be appropriate for their respective roles and responsibilities;
- Providing training for the Foundation’s agents if the Vice President, Compliance determines it is appropriate to do so; and
- Disseminating other communications as may be appropriate to convey and reinforce applicable laws and regulations, ethical standards, the Code, and other Foundation policies.
- Completes other projects as assigned.
Required Knowledge, Skills, and Abilities:
- Must be able to communicate effectively and with judgment to Council Members and Foundation executives.
- Must have prior managerial experience.
- Must be able to work independently and in teams.
- Must demonstrate ability to prioritize, be proactive, resolve conflicts, meet deadlines, follow through on assignments and be a team player.
- Must possess ability to effectively communicate across multiple practices and cultures, both verbally and in writing and have excellent computer skills, including Microsoft Suite.
- Experience with auditing for regulatory, legal, or compliance requirements for government contractors, healthcare or other regulated industry.
- Candidate must have knowledge of accounting and financial practices and procedures.
- Knowledge of the Practice of Internal Auditing.
- Familiarity with medical research international operations and government contracting.
Position Accountability/Scope: Appointed by CEO and reports to the Council of Directors.
Minimum Education/Training Requirements: Masters Degree. Law Degree, CPA, CIA or CFE preferred. Minimum of 10 years’ experience in the area of audit, compliance, ethics or related field and 5 years in leadership position in a compliance function including supervision of compliance professionals. Prior work experience with federal government contracting regulations a plus.
Supervisory Responsibilities/Controls: Supervises Director of Ethics and Business Conduct Department, Internal Audit, and Records Retention Staff.
Work Environment: Office environment; local and regional travel may be required.
Required Skills, Knowledge: Self-starter with excellent analytical, interpersonal, and oral and written communication skills. Auditing experience a plus. Strong leadership skills and demonstration of integrity and professionalism. Ability to build strong relationships with key stakeholders at all levels of the organization. Knowledge of key compliance concepts.
HJF is an equal opportunity and affirmative action employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or protected veteran status.
**Any qualifications to be considered as equivalents, in lieu of stated minimums, require the prior approval of the Director of Human Resources.**