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The Senior Advisor – Global Anti-Corruption and Third Party Management supports the implementation of the global Ethics and Compliance program by designing, implementing, and continually improving Elanco’s global anti-corruption and third party management program maintaining Elanco’s commitment to adherence with anti-corruption and anti-bribery laws. This is part of Elanco’s commitment to doing the right thing in the right way along with following the laws, regulations, industry codes, policies and procedures that govern our business, both of which are foundations of Elanco’s culture. Additionally, the Sr. Advisor assures the anti-corruption and third party management program is effective in preventing and detecting misconduct in order to protect our company, brand, and reputation and maintain the trust of our customers, employees, and shareholders.
Functions, Duties & Tasks: Global Anti-Corruption
Design, implement, and continually improve policies and procedures, training, and communications regarding anti-corruption/anti-bribery related risks such as transactions with foreign governments including payments to foreign officials, use of third parties, gifts, travel, entertainment, sponsorships, charitable and political donations, conflicts of interest, and facilitating and expediting payments.
Monitor compliance with anti-corruption/anti-bribery policies and procedures globally. Document monitoring activities and work with stakeholders to determine the root cause along with any required remediation of observations.
Functions, Duties & Tasks: Global Third Party Management
Design, implement, and continually improve a documented third party management process with related policies and procedures, training, communications, tools, and resources that corresponds to the nature and level of the enterprise risk identified by Elanco.
Ensure the third party management process includes, but is not limited to:
An understanding of the business rationale for needing the third party in the transaction.
A documented risk based due diligence process for hiring and regular oversight of third parties to include, but not be limited to:
An understanding of the qualifications and associations of third party partners including its business reputation and relationship with foreign officials.
Review of due diligence outcomes providing an increased level of scrutiny to red flags.
Working with third party relationship managers to address red flags identified during due diligence.Tracking red flags and associated mitigating actions.
Tracking third parties that do not pass due diligence or are terminated and take steps to ensure that those third parties are not hired or re-hired at a later date.
Informing third parties of the company’s commitment to abiding by laws, prohibitions against foreign bribery, and the measures for preventing and detecting such bribery.
Reciprocal commitments from third parties.
Contract terms with third parties that specifically describe the services to be performed and provides audit rights to analyze books and records.
Compensation for third parties that is commensurate with the work being provided in that industry and geographical region.Incentives for compliance and ethical behavior by third parties.
Ensure the anti-corruption/anti-bribery requirements and third party management process is integrated into the relevant procurement and vendor selection and management processes.
Train third party relationship managers to identify and manage third party compliance risks.
Monitor third party relationships on an on-going basis through updated due diligence, training, audits, and/or annual compliance certifications by the third party. Additionally, monitor compliance with third party management policies and procedures globally. Document monitoring activities and work with stakeholders to determine the root cause along with any required remediation of observations.
Collect, track, and analyze monitoring trends and report findings to the Chief Ethics and Compliance Officer.
Perform comprehensive due diligence of any acquisition targets prior to any mergers or acquisitions, as needed or as directed by the Chief Ethics and Compliance Officer.
Participate in continuing education opportunities to maintain expert knowledge of anti-corruption and third party management related laws and practices to serve as a subject matter expert and advisor to employees.
Serve as the primary point of contact with IT and external vendors regarding the management and maintenance of systems related to this role.
Participate in selected audits performed by Elanco auditing functions.
Minimum 2 years anti-corruption experience
Demonstrated expertise in analyzing anti-corruption/anti-bribery regulations in a global setting across a broad range of topics and scenarios and overseeing processes, procedures, and programs to ensure compliance with such regulations.
Additional Skills/ Experience Preferences
Master’s Degree or advanced degree
Strong understanding of risk management fundamentals/tools and the ability to deal with ambiguity.
External mindset for evaluating benchmarks and industry best practices for anti-corruption and third party management programs in a global company.
Effective leadership and influencing skills (critical thinking, results oriented, etc.), including a strong reputation for integrity, objectivity, impartiality, fairness, sound judgment, and willingness to speak up.
Ability to partner effectively, with stakeholders in multiple geographies and positions within the company with a cross-cultural sensitivity and mindset.
Strong interpersonal and communication skills. Must understand how to influence and diplomatically challenge when needed.
High level of professional maturity and sensitivity to confidentiality.
Willingness to champion an idea or position despite dissent.
Elanco is an EEO/Affirmative Action Employer and does not discriminate on the basis of age, race, color, religion, gender, sexual orientation, gender identity, gender expression, national origin, protected veteran status, disability or any other legally protected status.