Ethics and Compliance Officer

Job description / Role

Project Description:

NEOM Project Summary: Saudi Arabian Bechtel Company will provide executive project management consultancy services (including technical, commercial, and construction management) for the development of certain defined aspects of the NEOM Infrastructure in the Kingdom of Saudi Arabia.” NEOM is a planned cross-border city in the Tabuk Province of northwestern Saudi Arabia. The site is near the Red Sea and the borders of Egypt, Israel, and Jordan. It will cover a total area of 26,500?km2 (10,200?sq.?mi) and will extend 460 km along the coast of the Red Sea.” NEOM will be the home and workplace to more than a million residents from around the world. It will include towns and cities, ports and enterprise zones, research centers, sports and entertainment venues, and tourist destinations. As a hub for innovation, entrepreneurs, business leaders, and companies will come to research, incubate, and commercialize new technologies and enterprises in groundbreaking ways.

Role Overview:

“Business organization E&C officers may appoint Ethics & Compliance Contacts to assist with the implementation of the ethics and compliance program within their organizations and under their direction.”
Bechtel Management Instruction Ethics & Compliance 101 - Ethics & Compliance Program, §3.2.
The Compliance Contact is the Ethics & Compliance Program’s eyes and ears on the ground in the project.

Essential Role Functions:

Awareness  

Ensure that the core elements of Bechtel’s Ethics & Compliance (E&C) program are known to all Bechtel personnel on the NEOM project including Trojena (the “Project”), by:
• posting Ethics HelpLine posters that identify the names of the Ethics & Compliance Contact and GBU E&C Officer, and the local number for the Ethics HelpLine;
• verifying that the Ethics HelpLine works from local phone numbers in the office and mobile lines; the E&C myBechtel website is accessible to country employees;
• keeping a reference copy of Bechtel Code of Conduct and Anti-Corruption Compliance Guidelines are in your office;
• verifying that onboarding includes references to the Bechtel Code of Conduct and Anti-Corruption Compliance Guidelines, any country specific compliance risks or areas of increased attention, and messaging explaining Bechtel’s VVC, how to address concerns or observed misconduct, Bechtel’s prohibition on retaliation; and
• relaying messages from E&C Corporate program (e.g. upon notice from the Chief Ethics & Compliance Officer or GBU E&C Officer, when a new policy or management instruction is rolled out or new Communications are drafted).

Training: 

• Assist country’s leadership team and managers to ensure timely organization and completion of the annual Ethics Awareness Workshops
• Assist GBU E&C Officer to organize any additional ad hoc trainings (e.g. post-incident remedial trainings, trainings required by the E&C Corporate Plan, if applicable)
• Make recommendations to GBU E&C Officers and/or Project Manager about new trainings, communications or processes based on his/her observations and assessments, and feedback received from staff members.

Inquiries, allegations, investigations:

• Inquiries are questions about how to apply the Code or Guidelines to any particular situation, or whether an action would be permissible.
• Respond to simple inquiries about the Program and its implementation.
• Refer inquiries you are unsure about to the GBU E&C Officers.
• Notify the GBU E&C Officers of all material inquiries and, if asked by the GBU E&C Officers, enter them in the Bechtel Case Management System (BCMS), to ensure that these are tracked for trend analysis and that the answers are consistent company-wide.
• Allegations are concerns about a specific action or lack of action that may require investigation.
• Work in accordance with the requirements of GBU E&CO to have an established process to address allegations.
• Facilitate contact to the Ethics HelpLine or GBU E&C Officer. If the Reporter expresses a preference for an in-person conversation with you, or you have reason to believe he or she would not share the concern any other way, collect as much detail as possible from the Reporter to understand the nature of the issue. Do not alert anyone of the allegation, but report it immediately the GBU E&C Officer or Ethics HelpLine Manager. Do not discuss with others unless/until approved by the GBU E&C Officer or a Bechtel Ethics & Compliance Investigator (“ECI”).
• At the request of the GBU E&C Officer, you may be asked to enter the case details in BCMS or to notify the Reporter to call or email the Ethics HelpLine so that a case may be opened on the matter.
• At the request of the ECI, you may be asked to assist in the investigation of suspected violations of Bechtel's ethical standards, applicable laws and regulations, and company policy.
• Work with the ECI or GBU E&C Officer to communicate with the Project’s management about the matter and actions being taken to address it, both during and at the conclusion of the investigation.
• Monitor for signs of retaliation against anyone raising good faith questions or concerns, or for participating in/supporting an investigation.
• Notes on addressing allegations
• If anyone on the Project asks an Ethics & Compliance Officer to investigate what they consider to be an ethics or compliance matter, explain that you are not authorized to investigate matters on your own, and contact the GBU E&C Officer or enter it in BCMS.
• The Ethics HelpLine Manager is available to assist Ethics & Compliance Officer at any time with any aspect of the use of the BCMS.
• If you have been entering case details in BCMS, notify the GBU E&C Officer when the case can be closed and the file is complete, so that he/she may concur with the decision to close it.

Other duties based on office’s E&C plan:
Knowledge of applicable E&C program expectations

• Seek and collect any documents, statements, certifications and representations made during in any tender, included in the contract terms or are dictated by legal requirements that call for specific behaviors in the area of Ethics & Compliance; make sure these are well communicated alongside the Bechtel E&C program expectations.
• Communications to/with clients
• Notify the GBU E&C Officer of any request from the client/client’s compliance team for E&C data and obtain review and approval from GBU E&CO before issuing responses.
• Where the client/contract requires reporting on E&C-related data, understand how it is kept and be prepared to collect it upon request. E.g. gifts & entertainment to client, to third parties; conflict of interest determination requests; agent/supplier due diligence records; volume of calls to the Ethics HelpLine, etc.
• Support Project leadership team and GBU E&C Officer as outlined in Project and/or country specific plans or management instructions.
• Participate in risk assessment exercises led by the leadership team or the GBU E&C Officer as requested.

Requirements

Qualifications & Skills

Basic Qualifications:

• Bachelor’s or master’s degree (or international equivalent) in finance, business management, law or other compliance related discipline from an accredited college or university with 12+ years of related Ethics & Compliance related experience. In lieu of appropriate degree 15+ years demonstrated experience in an Ethics & Compliance related discipline or function.

Additional Qualifications:

• Clear appreciation of the complexities created by a diverse employee population and sensitivity to cultural challenges
• Excellent written and oral communications skills
• Demonstrated ability to co-ordinate activities with varying levels of management and staff.
• Excellent time management skills to achieve departmental goals and objectives, while working in a high workload environment.
• Understands and performs complex and detailed work with accuracy
• Demonstrated ability to work independently, yet function within the corporate structure.
• Superior maturity and tact with the ability to exercise judgement, initiative, and discretion regarding confidential and sensitive matters.
• Advanced knowledge of Microsoft Office suite
• Ability to organise and analyse data and information gathered to support investigate findings and document the effectiveness of the ethics and compliance program.

About the Company

Since 1898, we have helped customers complete more than 25,000 projects in 160 countries on all seven continents that have created jobs, grown economies, improved the resiliency of the world's infrastructure, increased access to energy, resources, and vital services, and made the world a safer, cleaner place.

Differentiated by the quality of our people and our relentless drive to deliver the most successful outcomes, we align our capabilities to our customers’ objectives to create a lasting positive impact.

We serve the Infrastructure; Nuclear, Security & Environmental; Oil, Gas & Chemicals; and Mining & Metals markets. Our services span from initial planning and investment, through start-up and operations. Core to Bechtel are our values – ethics, safety, quality, people, culture, relationships, innovation and sustainability, and our covenants – integrity, respect, collaboration, trust, and delivery. They are what we believe, what customers can expect, and how we deliver.