Director of Compliance & Ethics, Germany (m/w/d)

Director of Compliance & Ethics, Germany (m/w/d)

Working with Us
Challenging. Meaningful. Life-changing. Those aren’t words that are usually associated with a job. But working at Bristol Myers Squibb is anything but usual. Here, uniquely interesting work happens every day, in every department. From optimizing a production line to the latest breakthroughs in cell therapy, this is work that transforms the lives of patients, and the careers of those who do it. You’ll get the chance to grow and thrive through opportunities uncommon in scale and scope, alongside high-achieving teams rich in diversity. Take your career farther than you thought possible.

Bristol Myers Squibb recognizes the importance of balance and flexibility in our work environment. We offer a wide variety of competitive benefits, services and programs that provide our employees with the resources to pursue their goals, both at work and in their personal lives.

Position Summary:

Reporting to the Vice President, European Markets & Japan Compliance and Ethics, this role partners with the market’s executive leadership team as well as senior leaders across Legal, Commercial, Medical, R&D, Global Drug Development, Regulatory, IT, Audit, Finance and HR to ensure continuous improvement and enhancements to the BMS Germany C&E program. The Director of Compliance will work cross-functionally at all levels of the organization to embed Compliance & Ethics policies and principles into market business initiatives to ensure operations are compliant-by-design.

The role requires subject matter expertise in German and applicable EU laws, regulations and codes governing pharmaceutical manufacturer’s interactions and engagements with German healthcare professionals, healthcare organizations, patients, patient advocacy organizations and government officials. In addition, substantive knowledge and experience implementing compliance risk mitigation strategies, such as education and monitoring, with data analytics and executional risk to help the business make well-informed, risk-based decisions.

Responsibilities Include:

• Develop and execute a comprehensive annual compliance work plan for BMS Germany responsive to new business strategies, initiatives and ongoing market operations.
• Сo-Chair (with the General Manager) BMS Germany’s Compliance Committee.
• Promote the right tone throughout the organization and, working with the leadership team, ensure a steadfast commitment by all employees to integrity and compliance.
• Partner and create synergy with the market’s Regulatory Law team to provide high quality service and guidance to the market’s business teams and other enabling functions.
• Drive German market implementation of BMS Global Compliance and Ethics program initiatives.
• Develop and deliver local market compliance policies, education and strategic communications. Ensure the market has a robust compliance monitoring program in place to timely and accurately identify compliance risk exposures. Conduct live or transactional monitoring of business activities. Review data to identify outliers and implement preventive measures or corrective action.
• Ensure compliance implementation, when applicable, of global SOPs, education, training/strategic communications, and monitoring & analytics in close cooperation with the global C&E Organization.
• Design and lead the periodic compliance risk assessment for Germany.
• Support scoping of BMS Germany internal audits by collaborating with the Global Internal Audit team.
• Partner with the third-party due diligence center of excellence on assessments of third parties operating in the market. Partner with the market business controls function team on ongoing management of market third parties with a healthcare compliance risk exposure.
• Establish a network of Compliance Champions in BMS Germany to integrate compliance messaging and concepts into established business training cycles. Identify and leverage key stakeholders and cross-functional resources to create buy-in for integrity and compliance culture initiatives across the market.
• Maintain working knowledge of local industry codes and regulations as well as government enforcement actions to identify and mitigate potential compliance risks.
• Perform other compliance-related activities as directed by the Chief Compliance & Ethics Officer, the VP, European Markets & Japan C&E or the Global Compliance & Ethics Leadership Team.

Qualifications:

• Bachelor’s Degree required. Advanced degree strongly preferred.
• 8+ years pharmaceutical or healthcare related compliance or legal experience, with at least 5 years-experience directly advising clients.
• Expert knowledge of relevant German and EU pharmaceutical compliance laws, regulations, codes and binding/non-binding guidance.
• Expert knowledge of the roles and responsibilities of commercial sales, marketing, medical affairs, and market access organizations in the pharmaceutical industry.
• Ability to influence and partner with senior level executives. Work from an enterprise mindset focused on achieving company goals in a compliant and ethical manner.
• Demonstrated ability to influence business decisions across all levels of the organization.
• Comfort with using data to tell stories particularly around risk and effectiveness of risk mitigation strategies.
• Proven experience drafting principle-based policies.
• Experience utilizing adult-learning concepts in corporate educational and training materials.
• Experience conducting live monitoring of speaker programs and advisory boards, and transactional monitoring of engagements with HCPs/HCOs or patient advocacy organizations.