Enterprise Compliance & Ethics Sr Manager

Overview

This role leads the Compliance & Ethics function for the Egypt business, being responsible for implementing all aspects of PepsiCo’s global compliance program, including:

overseeing a complex Speak Up docket and ensuring proper investigation and remediation of all issues, particularly PSVs;

delivering ethics and ABAC training to key stakeholders and functions; 

supporting a strong tone at the top by promoting and coordinating senior leadership messaging;

maintaining the effectiveness of the Third Party Due Diligence program across Egypt;

supporting a robust control environment, including leading Egypt’s Control Environment Council and providing all C&E information required for each quarter close; and 

identifying and working to remediate compliance risks to Egypt’s businesses identified through various avenues (e.g., Speak Up, internal risk assessments, corporate audits, etc.). 

Responsibilities

• Provide proactive, high quality support to the MU on promoting, monitoring and enforcing the PepsiCo Compliance & Ethics program for the Egypt MU, with the support of the C&E Associate Manager and C&E Analyst. Accountable for decision-making and execution in all areas of the C&E Program.
• Be an active member of the Egypt Control Environment Council (“CEC”); schedule and attend quarterly as well as other regular, special meetings of the CEC to discuss the Compliance & Ethics Program and PSVs. Create and update the presentations required for such forum. Has shared decision-making responsibilities and accountability for execution.
• Speak Ups:
  • Participate/lead in-depth, and often complex, PSV investigations, engaging correct subject matter expertise, to determine root causes, appropriate actions and track remediation.
  • Responsibility for managing all PSV and routine matter investigations from reviewing initial reports to closure.
  • Manage trend analysis that monitor, assess and mitigate risks faced by PepsiCo (across the key elements in the Control Environment. In particular, monitor key problematic areas to ensure effective root-cause analysis and remedial action implementation.
  • High-level of decision making and accountability with regards to the Speak Up process.
• Partner with Legal to oversee the Anti-Bribery and Anti-Corruption (ABAC) compliance program, including risk assessment for target training population, delivering training, providing guidance and handling pre-approval requests.  
• Collaborate with Legal and the People Function to ensure practical, effective ABAC, Act with Integrity and other compliance training are delivered, to guide MU leadership and its employees in making day-to-day decisions that are consistent with PepsiCo’s Code of Conduct, the law and all applicable PepsiCo and Region policies to promote a culture of integrity. Prepare all materials needed for such trainings.
• Collaborate with the People Function to create and support Culture of Integrity campaigns across the MU, including identifying and training Code Ambassadors, conducting roundtables and values dilemma sessions, conducting F2F training for the entire frontline population and delivering on-site activation days.
• Responsibility for managing the entire BU’s Third Party Due Diligence program ensuring awareness of the In-Scope Matrix, actioning TPDD requests, assessing the TPDD reports and escalating and managing the Resolution Committee where applicable.  Also responsible for the re-vetting and monitoring processes of the TPDD program.
• Responsibility for implementation of Egypt's Licenses and Permits (L&Ps) program to ensure that all material L&Ps for the MU are accounted for and effectively tracked. Monitor and re-assess the process and policy periodically for enhancements.
• Attend the MU Audit Committee to present all matters and areas related to Compliance & Ethics on a quarterly basis.
• Ensure new employees, current employees and third-party agents (as appropriate) are educated in the Compliance Program, specific policies and procedures as well as the compliance and ethical requirements relevant to their job responsibilities for the BU.
• Participate in Anti-Corruption Risk Assessments for the Egypt MU and lead the remediation for any observations related to C&E.
• Partner in a broader coalition of departments that monitor, assess and mitigate risks faced by PepsiCo such as Communications, Government Affairs, Security, Health & Safety, Environmental, Antitrust, M&A/Joint Ventures, Conflicts of Interest, Human Rights and Privacy.   
• Responsibility for all aspects of the C&E program, including Speak Ups, training, TPDD and licenses and permits, of the rapidly expanding populations of the Cairo Capability Center.

Qualifications

• 7-8 years of experience, preferably in a senior role in Compliance & Ethics, Legal, Employee Relations or Audit role
• Experience in handling and leading Speak Up investigations.
• Fluent in English and Arabic.
• Excellent report writing skills.
• Detailed knowledge of PepsiCo’s policies and relevant state laws