The Vice President, Chief Compliance Officer (CCO) is responsible, on a global basis, for designing, implementing and maintaining an effective healthcare compliance program. The CCO ensures that the company and its employees are in compliance with applicable healthcare-related laws and regulations on a global basis. Further, he/she will ensure that company policies and procedures are being followed, and that behavior at the company meets the company’s Code of Business Conduct and Ethics. The CCO reviews and evaluates compliance issues/concerns within the company; monitors and reports results of the compliance/ethics efforts of the company; is responsible for leading multi-disciplinary efforts within the company related to compliance; and provides guidance for, and regularly interacts with, the Board of Directors and senior management on matters relating to compliance. This position reports to the Executive Vice President, Chief Business Officer and General Counsel. Infrequent and well-planned international travel may be required.
- Develops, coordinates, and administers an effective compliance training program to ensure that all appropriate employees and management are knowledgeable of, and comply with, pertinent laws and regulations.
- Establishes and implements periodic risk assessments, audits, and reporting procedures to identify potential areas of compliance vulnerability and risk. Develops and implements preventative and corrective action plans to mitigate identified risks.
- Develops and implements auditing, monitoring, and reporting programs to monitor compliance with applicable laws, regulations, policies, and procedures.
- Institutes and maintains an effective compliance communication program for the company. Disseminates information to and educates employees regarding a broad spectrum of compliance-related topics, including promoting (a) use of the compliance hotline; (b) heightened awareness of the Code of Business Conduct and Ethics, and (c) understanding of new and existing compliance issues and related policies and procedures.
- Ensures appropriate policies and procedures for the general operation of the global compliance program and its related activities are created, adopted, published, and communicated to employees in order to prevent illegal, unethical, or improper conduct.
- Periodically reviews and updates the Code of Business Conduct and Ethics to ensure continuing currency and relevance in providing guidance to management and employees.
- Oversees management of the compliance hotline.
- Responds to alleged violations of laws, regulations, policies, and procedures by evaluating or recommending the initiation of investigative procedures. Implements investigative protocols and oversees investigation process, including conducting or managing privileged compliance investigations.
- Ensures that compliance issues/concerns within the organization are being appropriately evaluated, investigated, and resolved, and that there is an effective and consistent system of discipline to address any misconduct.
- Ensures there is an evaluation and incentive system that promotes legal and ethical conduct.
- Provides reports on a regular basis, and as directed or requested, to keep the Compliance Committee, the Board of Directors, and senior management informed of the operation and progress of the compliance program.
- Consistently finds opportunities to strengthen and improve the culture of compliance at the company, including by partnering with department heads and country general managers to build relationships with the compliance department.
- Takes active measures to partner with senior executives to reinforce culture of compliance at the company through communications and outreach activities.
- Maintains a working knowledge of applicable laws, regulations, and enforcement actions to identify emerging risks. Alerts the company to trends and risks and assists in implementing policies and procedures in response thereto.