Sr Counsel, Anti-Bribery & Anti-Corruption

Foster City, CA
Apr 27, 2022
Required Education
Bachelors Degree
Position Type
Full time

This is a unique and exciting opportunity for an attorney to join a diverse and dynamic team responsible for Gilead's company-wide anti-corruption program. This individual will help implement an effective cross-functional anti-bribery anti-corruption (ABAC) program at Gilead Sciences, including providing anti-corruption advice on new and complex company initiatives and interactions with government officials, healthcare professionals, and other external stakeholders across commercial, medical, and clinical activities. In partnership with the Company's Internal Audit department, this individual will conduct audits to ensure compliance with the company's ABAC, anti-kickback, healthcare compliance, and Business Conduct policies. This individual will also develop and carry out policies and procedures; provide business conduct and compliance support to Gilead's Global Patient Solutions organization (Gilead's program to increase access to medicines and healthcare in low and middle-income countries); assist the Litigations & Investigations legal team on investigations and government inquiries; support the Corporate Development team with M&A due diligence and assess and act upon issues identified during due diligence processes; assist in implementing training and communication plans; and contribute to monitoring and enforcement activities to ensure consistent application of Company policies. This position will report directly to the Senior Associate General Counsel, Anti-Bribery Anti-Corruption.

Essential Duties and Job Function:
  • Provide legal counseling on high-value business initiatives, third party and partner relationships, payment arrangements, and other areas with potential corruption risk.
  • Coordinate with other colleagues in Legal, Business Conduct, Internal Audit, and client departments on an international basis to ensure efficient and effective implementation of the Company's ABAC and Business Conduct programs;
  • In partnership with colleagues from the Company's Internal Audit department, conduct audits of Gilead's affiliates, operating units, business partners, and other third-party service providers, to ensure compliance with the Company's ABAC, anti-kickback, and Business Conduct policies; and assist in implementation of corrective actions;
  • Participate in implementation of the Company's ABAC program, including assessment and appropriate follow-up on issues identified during due diligence processes relating to engagement of third parties;
  • Provide business conduct and compliance support to Global Patient Solutions, including development and refinement of policies and procedures;
  • Provide support to corporate legal and clinical legal teams on ABAC contract provisions and contractual arrangements;
  • Provide input on development and maintenance of anti-corruption and trade compliance-related policies;
  • Develop and deliver training for employees, consultants and agents;
  • Assist in providing day-to-day guidance, support and problem solving;
  • Participate in monitoring and reporting framework for key activities to assess the effectiveness of the program; analyze and monitor results to identify trends and recommend program improvements;
  • Assist in monitoring external environment and recommend improvements to the company's anti-corruption program based on identified industry best practices;
  • Significant international travel required, subject to company health guidance.

Education and Experience:
  • J.D. from a nationally accredited law school.
  • Admission to applicable state bar, registration as in-house counsel, or ability to gain admission or registration for either in applicable state within 90 days.
  • 8+ years of prior industry, law firm, or government experience providing legal counsel relating to international corporations.
  • Experience in fraud & abuse laws required (e.g., Foreign Corrupt Practices Act; UK Anti-Bribery Statute; Anti-Kickback Statute)
  • Investigative interview experience
  • Experience in biotechnology or pharmaceutical industries, and counseling relating to drugs or medical devices preferred.
  • Proven regulatory compliance experience with ability to analyze and interpret sales and marketing laws and regulations, and effect related organizational changes to ensure alignment.
  • Demonstrated leadership and project management in enterprise-wide projects.
  • Ability to present complex information in an accurate and persuasive manner to all levels of management.

  • Strong project management, communication and interpersonal skills.
  • Substantial knowledge of specific areas of law and business and ability to independently and effectively apply this knowledge to the relevant areas of responsibility to counsel members of the senior Legal team and senior managers in other departments.
  • Ability to identify and analyze risk associated with complex problems within area of responsibility.
  • Must be a team player who can easily handle shifting priorities, multi-tasking in a deadline-oriented environment.
  • Must be motivated and willing to take initiative.
  • Must have excellent written and verbal communication skills.
  • Must have proven judgment in working through complex issues, including those with significant strategic risk to the company.

For jobs in the United States:

As an equal opportunity employer, Gilead Sciences Inc. is committed to a diverse workforce. Employment decisions regarding recruitment and selection will be made without discrimination based on race, color, religion, national origin, gender, age, sexual orientation, physical or mental disability, genetic information or characteristic, gender identity and expression, veteran status, or other non-job related characteristics or other prohibited grounds specified in applicable federal, state and local laws. In order to ensure reasonable accommodation for individuals protected by Section 503 of the Rehabilitation Act of 1973, the Vietnam Era Veterans' Readjustment Act of 1974, and Title I of the Americans with Disabilities Act of 1990, applicants who require accommodation in the job application process may contact for assistance.

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