The Ethics and Compliance Unit (ECU) ensures that the IRC integrates a culture of Ethics and Compliance into its business globally and at all levels of the organization, in accordance with the IRC Way: Standards of Professional Conduct (IRC Way), our values, and the law; and maintains effective policies, procedures, controls, processes, and systems to prevent, detect, and investigate potential violations of internal policies, law or regulation or material failures. ECU addresses the IRC’s activities, and those of related third parties that may be viewed as acting on the IRC’s behalf such as partners, sub-grantees, subcontractors, suppliers, short-term workers, and others. The ECU is responsible for the IRC’s Enterprise Risk Management, Anti-Fraud/Corruption Program, IRC Way, Safeguarding, and internal investigations.
SCOPE OF WORK
Director, Anti-Fraud/Corruption Program
• Oversees the development and implementation of IRC’s anti-fraud/corruption program, working with US programs (USP), country offices and functional leads to develop, coordinate and implement a programmatic strategy and measures to ensure that donor funds are used for their intended purposes
• Provides strategy, guidance and advice on prevention, risk mitigation and enhancing internal policies and controls, working with the country offices and functional leads, and supports efforts to build on-the-ground capacity in compliance and internal controls
• Performs as a subject matter expert on anti-fraud/anti-corruption compliance, keeping current on global legal developments, enforcement guidance and trends
• Partners with Finance, Internal Audit, Global Supply Chain, IPD and US teams to ensure that lessons learned and identified issues are incorporated into IRC’s anti-fraud/corruption program
• Liaises with donors on requests for information related to IRC’s anti-fraud/corruption program and compliance activities
Reporting to the Chief Ethics and Compliance Officer, and based in New York, the Director will work closely with the country offices and other relevant functional units (IPD and US teams, General Counsel, Internal Audit, Awards Management Unit, Finance, Global Supply Chain, Operations), and with IPD’s regional and country directors, and USP Executive Directors.
The responsibilities of the Director, Anti-Fraud Program, includes the following, as well as other activities that may arise related to their function:
Prevention and Remediation
• Program Development and Management of IRC’s anti-fraud/corruption efforts
• Provide expertise and input to IRC’s due diligence processes across the organization
• Identify local and global opportunities to increase efficiencies and improve systems related to compliance and control processes and partner with appropriate stakeholders to develop and implement enhancements
• Develop processes and systems for the tracking of findings relating to internal system failures/weaknesses/gaps and recommendations for remediation identified in investigations and audits; and disciplinary actions/terminations of employees, working with USP, IPD and operations
• Advise and support region and country teams and relevant HQ functional teams in the development of effective corrective and remedial action plans in response to ECU investigation findings, Internal Audit reports, and other relevant sources including external audits and other functional internal reviews
• Provide advice and oversight for all responses and follow-up to major donor risk assessments and audits
• Work with other HQ departments to ensure that corrective and remedial actions are incorporated into planning as appropriate. Coordinate with appropriate departments where it is identified that global policies and procedures need implementation or revision
• Create dashboards and related tools to measure progress on remediation and effectiveness of controls
Policies and Training
• Development and delivery of anti-fraud and anti-corruption training and communications in a multi-lingual and multi-cultural environment
• Regular review and updates of relevant anti-fraud/anti-corruption policies and protocols
• Partner with a variety of stakeholders to embed anti-fraud / anti-corruption requirements and controls into projects
• Respond to inquiries from internal stakeholders regarding anti-fraud / anti-corruption requirements
• Develop processes and protocols for conducting multifunctional proactive anti-fraud/corruption risk assessments of locations to identify control gaps and recommendations for fraud/corruption remediation
• Support risk assessments, including: development of methodology and focus, identification of the review team, implementation of review process, preparation of report of findings, and formulation of remediation plan - in coordination with IPD Senior Advisor for Internal Controls or other stakeholders
• Based upon results from investigations, internal/external audits, analysis’ by Procurement Quality Assurance Team, and other sources, make recommendations for the performance of risk assessments each year
Coordination with Country Compliance Managers
• Collaborate with the Sr. Director of Investigations to conduct regular meetings with Country Compliance Managers for training/discussion of relevant compliance and control topics
• Work with Country Compliance Managers on the development of training and discussion content on anti-fraud and corruption, internal controls issues, audit findings and related areas
• Build local compliance capacity by providing advice and guidance to Country Compliance Managers on the development of their work plans and initiatives to strengthen IRC’s anti-fraud/corruption program and the local control environment, in coordination with country leadership.
• Collaborate with the Senior Director of Enterprise Risk Management on the development and implementation of IRC’s Enterprise Risk Management Process
• Oversee the development and deployment of USP/country/regional risk registers, including training of country personnel and monitoring of the process Act as primary ECU liaison to the Awards Management Unit on the monitoring and further development of the due diligence process for the Sub-Award Partnership Management System
• Identify issues and subject areas for employee training programs and work with the ECU Training and Communications Coordinator and other relevant stakeholders to develop and implement programs to further develop and build capacity in compliance and internal controls across ECU operations
• Eight or more years experience in: compliance with an emphasis on fraud and corruption, law, forensic fraud analysis, or related field with focus on program development, internal controls, prevention, and remediation.
• Degree in law, finance, accounting, or related relevant experience.
• Field experience in INGO.
• Experience building programs and global initiatives for compliance and control environment
• Strong analytical and database management skills.
• Excellent presentation, written and verbal communication skills with the ability to interact at all levels of the organization
• Receptive and collaborative approach that builds and maintains strong relationships with individuals from all cultures, backgrounds, genders and viewpoints
• Ability to manage multiple tasks and objectives
WORK ENVIRONMENT/KEY RELATIONSHIPS:
Able to travel up to 20% of time.
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