This position is responsible for administering the GSOC Corporate Ethics & Compliance (E&C) Program. The Corporate E&C Manager collaborates and coordinates with other FOC departments to ensure that GSOC actively maintains its E&C Program and associated activities as necessary to ensure institutional awareness of E&C and a culture of ethics and compliance. The GSOC E&C Program consists of the following areas: Code of Ethics (including Conflicts of Interest), Exception Tracking/Reporting, Records Retention and Destruction, GSOC Controlled Documents process (policies, guidelines, and procedures), Confidentiality of Information, Administration of compliance support tools, regulatory awareness, and other areas as deemed appropriate and necessary.
The Corporate E&C Manager is responsible for:
- Coordinating E&C education, training, awareness, and monitoring activities.
- Acting as the internal liaison for E&C issues.
- Maintaining and updating all documentation and tools, including internal controls, related to the E&C Program and to ensure that appropriate, applicable regulatory requirements are current and accurately reflected in the GSOC E&C Program.
- Reporting on the overall status of the E&C Program and related elements.
- Developing and maintaining the E&C risk register, including performing an annual risk assessment review and monitoring/activities schedule.
- Responding to questions and requests for assistance regarding E&C from GSOC employees.
- Ensuring that the Director, Legal and Compliance and the Chief Legal & Compliance Officer are notified and aware of any and all deficiencies or other issues relative to GSOC’s E&C Program or compliance therewith and any associated reviews or investigations.
- Coordinating and ensuring that all improvements and/or corrective actions required to address any deficiencies are completed in a timely manner.
- Administering compliance support tools for GSOC and, as requested and necessary, supporting the other compliance areas and managers.
- E&C Program: Manage, develop, implement, measure, evaluate, and enhance the E&C Program, in all areas identified above, including the Code of Ethics and all other related policies, guidelines, and procedures, education, training, and monitoring of all ongoing aspects of the E&C Program. Administer internal E&C executive steering committees, and associated sub-committees or other groups as needed, in the oversight, development, administration, and maturity of the various E&C components. Perform an annual risk assessment and review/revise associated compliance monitoring schedules. Develop and maintain procedures to satisfy the objectives of the E&C Compliance Program and internal controls to assure that quality control is maintained. Responsible for continually evaluating and tracking the effectiveness of the E&C Program and evaluating the performance of both the company and the E&C Program in ensuring that the culture of ethics and compliance meets GSOC’s expectation of excellence. Establish and implement periodic monitoring and evaluation programs to effectively assess the E&C Program and processes that are in place, and propose modifications and enhancements as necessary and appropriate to meet Best Practices and assure appropriate maturity. Actively anticipate, communicate, and help shape new E&C requirements and Best Practices and develop strategic initiatives related to the E&C Program and its maturity. Administer and maintain ARMS (or any successor system), the Corporate Compliance SharePoint/web site, and other applicable portions of the internal SharePoint web sites, ensuring that information and versions provided for employee use are current and accurate.
- Element-Specific Responsibilities:
- Records Retention and Destruction: Administer and maintain GSOC’s Record Retention and Destruction Program. Coordinate with departments to ensure that appropriate records are maintained.
- Controlled Documents: Administer GSOC’s Controlled Documents Program, including the annual review of corporate policies, as required by the Board of Directors. Coordinate with departments to ensure that GSOC controlled documents are reviewed and maintained as current.
- Confidentiality of Information: Administer and maintain GSOC’s Confidentiality of Information Program. Coordinate with and support departments to ensure that confidentiality is maintained.
- Regulatory Awareness and Cross-Training: Maintain awareness of general laws and regulations, keeping abreast of changes that may affect GSOC, including as related to the NERC Reliability Standards. Maintain a thorough and comprehensive understanding of business practices to effectively assess the impact of regulatory requirements on GSOC and to support all of GSOC’s compliance programs and managers, as requested and necessary. Stay apprised of general E&C issues as they may relate to GSOC, and propose ideas for issues/items that need to be addressed.
- Compliance Support Tool Administration and Maintenance: Administer and maintain compliance support tools, e.g., Workiva and ARMS, and ensure that such tools enhance the sustainability, efficiency, and effectiveness of GSOC’s compliance programs.
- E&C Reporting and Follow Up: Administer and monitor the Employee Hot Line and any other reporting formats/forms. Communicate any identified or reported concerns and questions to the Director, Legal and Compliance and the Chief Legal and Compliance Officer. Triage E&C-related inquiries and submissions and coordinate with internal and external counsel or other resources, as necessary, to evaluate and support such inquiries, submissions, or compliance activities.
- Communication and Training: Develop, document, and manage efforts to communicate the overall E&C Program to all GSOC employees, including written materials and training programs designed specifically to promote understanding of E&C expectations, requirements, issues, laws and regulations, and the consequences of non-compliance. Lead the effort to plan and execute annual, focused E&C activities.
- Board Reporting: Prepare and support periodic reports to the Board of Directors as requested and when regarding compliance and significant activities undertaken and planned (including an annual E&C Program Update).
- Various other responsibilities:
- Documentation: Maintain accurate and comprehensive documentation of compliance activities performed pursuant to the E&C Program as needed to successfully meet requirements of audits and to demonstrate that E&C tasks are completed timely.
- Coordination/Reviews: Work with Audit & Consulting (A&C) to support their assessments and ensure audit requirements are met. Follow up on the commitments made with regard to corrective action(s) to assure implementation/completion. On occasion, this position, in conjunction with A&C, may support and/or participate in internal compliance reviews of the Compliance Program and prepare documentation for management review.
- Backup: Serve as backup for the Director, Legal and Compliance, as needed.
- Responsible for other special projects, including, but not limited to, GNOC related efforts, as assigned.
Education: Bachelor’s degree in Business, Finance, or related field. A Master’s degree in Business Administration or Juris Doctor is very desirable.
Experience: At least ten (10) years of compliance experience, with six (6) years of utility or other regulated industry experience.
Equivalent Experience: Eighteen (18) or more years of corporate compliance, ethics, governance, risk and controls, or auditing, with one year of experience in business or finance experience.
Licenses, Certifications, and/or Registrations: Must be eligible to be authorized for access as defined in GSOC’s cyber security personnel risk assessment program.
Specialized Skills: Nationally recognized professional compliance or project management certification and experience with the NERC reliability standards preferred. Expertise in a variety of MS products is desirable. MS Project expertise is highly desirable. Should have working knowledge of process improvement tools and methods and project management processes and tools. Facilitation skills, presentation skills, excellent written and oral communication skills, and ability to influence others through excellent interpersonal skills are required. Strong analytical ability and ability to prioritize projects and multitask required. Must have experience working with individuals at multiple levels within the Company, handling sensitive and confidential matters, and resolving conflicts. Assignments are broad in nature, requiring appreciable originality, ingenuity, problem-solving ability, sound judgment, and common sense. Excellent organizational skills and customer/team communications skills are needed to be successful.