Boehringer Ingelheim Corporation Chief Compliance Officer Job Description
Title:
Chief Compliance Officer
Department:
Legal/Compliance Department
Reports to:
General Counsel
Corporate Management Committee - chaired by CEO (dotted line)
Corporate Compliance Committee (member)
Purpose of Position:
The purpose of this position is to continue to develop, implement, revise and oversee the Boehringer
Ingelheim Corporation and its subsidiaries’ (collectively referred to as “BI”)
Corporate Compliance Program (“CCP”). Responsibilities include maintaining and expanding
visibility for the CCP at all levels within BI; training senior management regarding BI’s CCP;
acting as executive director of the CCP, including managing the agenda of and arranging for ongoing
meetings of the Corporate Compliance Committee; developing and maintaining internal resources for
administering the CCP; recommending and implementing compliance initiatives which match the pharmaceutical
industry regulatory environment; overseeing BI’s Compliance Helpline; evaluating company processes
for compliance impact; investigating any reported or identified compliance concerns; and auditing the CCP
and/or specific substantive areas and addressing audit findings in order to continually evolve and
improve the CCP.
Major Accountabilities:
- Administer BI’s CCP.
- Oversee the development and subsequent refinement of the BI Code of Conduct and continue to implement the Code of Conduct throughout BI.
- Advise the organization’s internal compliance department members and designated business partners with respect to the implementation and/or operation of an effective compliance program.
- Act as the primary contact point and internal expert with respect to compliance matters requiring external reporting to, or inquiries made by, regulatory and law enforcement agencies.
- Develop and implement (or assist, coordinate, and/or supervise the development or implementation) appropriate compliance-related policies and procedures throughout all areas of BI.
- Ensure that appropriate training on compliance-related topics, policies and/or procedures is provided to relevant employees.
- Develop, implement and/or oversee robust auditing and monitoring systems to ensure the effectiveness of the CCP.
- Manage the corporate Compliance Helpline and other internal reporting systems. Identify compliance matters that require follow-up and/or investigation, and refer issues to the appropriate internal investigating body. As appropriate, such management shall include directly investigating some complaints; overseeing the investigation of others; and partnering with Human Resources to ensure the implementation of consistent disciplinary action which strengthens the integrity of the CCP.
- Manage the meetings of the Corporate Compliance Committee, including setting the agenda, providing CCP updates and notifying the Corporate Compliance Committee, as necessary, on specific substantive matters requiring Board advisement and/or action.
- Develop external contacts and participate in professional organizations that will help position BI as a leader in pharmaceutical industry compliance programs.
- Work with internal business and department managers to increase awareness of the importance of the CCP, including the managers’ reporting obligations under the Program.
- Build strong, effective relationships within BI to foster a culture of ethical awareness and dedication to continuous improvement of our compliance efforts.
Qualifications:
- Significant experience and/or deep understanding of compliance issues confronting the pharmaceutical, bio-tech, device and/or health care industry generally.
- Demonstrated knowledge and understanding of the requirements for effective compliance programs as set forth in the U.S. Sentencing Guidelines.
- Demonstrated knowledge and understanding of the legal and regulatory framework affecting the pharmaceutical industry; including, but not limited to, sales and marketing Fraud and Abuse issues, OIG and other industry guidance documents, FDA regulations on the promotion of marketed products, clinical trial regulations and issues arising under the False Claims Act.
- Demonstrated effectiveness operating in complex organizational and regulatory environments.
- Excellent written, oral and presentation skills.
- Proven ability to work with all levels of management and the general workforce.
- Strong problem solving skills.
- Demonstrated ability to partner effectively with others in addressing complex issues.
- Strong influencing skills and sound business judgment.
- Motivated, self-starter with ability to appropriately prioritize issues and allocate resources.