The Russia Code of Business Conduct (COBC) Manager supports the company in continuing to create a culture of compliance by establishing standards and procedures to prevent, reduce, detect and investigate breaches of our COBC. The Russia COBC Manager is responsible for ensuring our COBC is communicated and adopted, and for monitoring compliance with the COBC as well as with other compliance policies, such as the Group Anti-Bribery (ABAC) policy. The Russia COBC Manager is responsible for coordinating general compliance efforts with the Country Compliance Officer (Legal).
- Oversee the investigation process for all COBC matters in Russia
- Develop and implement investigation plans for local matters
- Lead Head Office (“HO”) Managed investigations in Russia
- Conduct Anti-Bribery and Corruption Audits
- Ensure timely feedback on whistleblower responses and follow-up on action plans.
- Conduct analysis and evaluate reports of alleged COBC violations. Exercise independent judgment and discretion to determine the best responses for each allegation.
- Share expertise with the Local E&C committee and provide guidance in the disciplinary stage of investigations.
- Support the local Legal department with initiatives to strengthen compliance with the ABAC policy.
- Support Group COBC Manager on HO COBC Matters
- Inspire people to deliver while upholding the CCH values and demonstrating a passion for the business.
- Exercise absolute integrity, confidentially and ethical behavior in all aspects of personal and professional life
- Provide guidance to Security and ICCMs (in Region 2 countries) on the handling of COBC matters
- Serve as a member of the local E&C Committee(s) in Russia
- Conduct analysis and prepare reports and communications which are shared with Senior management.
- Ensure that an appropriate level of information on COBC cases is documented in the Case Management Tool.
- Collaborate with the Legal department and other functions, such as Security, HR and Finance, to evaluate policies and training to promote compliance with the COBC and other Group policies.
- Support Legal and other departments in new compliance programs and policy initiatives.
- Maintain strong relationships with the Regional and Senior Audit Managers and ensure timely communication of identified fraud risks.
- Develop and conduct training, raise awareness, and develop/ maintain relationships with management colleagues across the Country to identify and address key risks
- Apply effective interpersonal, presentation and influencing skills, with the ability to objectively evaluate complex and sensitive situations, while engendering trust and confidence.
- Bring awareness to CCH of the COBC and other policies through creative and targeted training and communication that can be leveraged Country-wide.
- Monitor COBC trends and develop and deploy training accordingly tailored for specific functions.
- 7+ years of related professional work experience (investigation and compliance functions)
- A University level Bachelor Degree in Accounting, Finance, Economics, related field or equivalent.
- Experience in performing complex internal investigations.
- CFE or CCEP(I)
- ACCA (or equivalent) desired
- Generate new and unique solutions and embrace new ideas that help promote and foster a culture of compliance.
- Possess strong project management skills, demonstrate an ability to make sound decisions, and exhibit initiative and intuitive thinking.
- Demonstrate very strong oral communication, presentation and facilitation skills.
- Exhibit strong written communication skills with the ability to write clear, accurate and concise reports in English for Senior Management review