Director, Internal Investigations
Position establishes the overarching strategy & tactics for implementing and maintaining AbbVie's global investigations department. The role also conducts, leads and/or oversees internal investigations relating to alleged violations of the AbbVie Code of Business Conduct (and other policies and procedures) and legal or regulatory requirements by (1) reviewing facts and analyzing legal and policy requirements; (2) working independently or with cross-functional teams to investigate allegations; (3) providing guidance on the handling of investigations; (4) reviewing findings and recommendations with management. Will ensure effective functioning of the internal investigations process, oversee a database of case information, monitor the performance of investigators, perform trend analyses, and recommend follow-up actions based on investigatory conclusions and analyses. Will make recommendations to Chief Ethics and Compliance Officer (CECO) and Office of Ethics and Compliance (OEC) leadership, as well as corporate management, regarding internal investigations and follow up actions (e.g., preventive and corrective actions).
Key Responsibilities Include:
- Support the CECO in the management, assessment, and conduct of whistleblowing issues and investigations; review the overall accuracy and completeness of investigations on the case management system
- Responsible for investigating allegations relating to compliance with the AbbVie Code of Conduct and policies and procedures, as well as legal and regulatory requirements.
- Leads company investigations involving issues such as the U.S. Foreign Corrupt Practices Act (FCPA), the U.S. Anti-Kickback Statute, the U.S. False Claims Act, the U.S. Federal health care programs, the U.K. Bribery Act, other bribery laws, and food and drug laws around the world.
- Provides leadership and guidance to personnel performing investigations at OEC's direction.
- Build, oversee, train and mentor a team of global investigators
- Ensures that investigations are completed in a thorough and timely manner, and reviews all investigation reports and conclusions. Analyzes investigation results to identify compliance risk areas and unfavorable trends.
- Drafts policies and procedures relating to investigations and provides training regarding investigations.
- Build, maintain and strategically influence relationships across the organization. Make recommendations and problem solve in a manner that shows both strategic and tactical thinking.
- Work successfully, individual and within a team environment, building strong relationships and maintaining rapport with departmental and business colleagues.
- Minimum 12+ years' experience in the legal or compliance fields conducting investigations, preferably in the following areas: FCPA, Anti-Kickback Statute, False Claims Act, pharmaceutical promotion issues, antitrust.
- Must have extensive experience questioning witnesses in an investigation, deposition, or similar setting.
- Familiarity with data protection laws and the coordination of data protection requirements in the investigative process.
- Proven ability to communicate with internal and external stakeholders in a manner that builds, maintains, and enhances a positive and productive working relationship.
- Excellent verbal and written communication and strong analytical and conceptual thinking.
- Proven ability to positively influence others at all levels/functions of the organization.
- Proven ability to tolerate ambiguity and to remain flexible when the pressure is on.
- Proven ability to work independently with minimal supervision and direction.
- Experience with anti-kickback, government contracting, training and global corruption risks is required.
- JD strongly preferred.