Lead Compliance Program Manager Job at Exact Sciences (Warsaw)

Job Description

The Lead Compliance Program Manager – Third Party Risk Compliance will be based in Warsaw, Poland, and report to the Director, Global Transparency, Systems & Compliance Operations. This role will be responsible for leading and enhancing our due diligence program for high-risk third parties, including but not limited to distributors, agents, and sensitive suppliers. This role is critical in ensuring our global operations remain compliant with anti-bribery, anti-corruption (ABAC) laws and internal standards, particularly in markets with elevated risk profiles.

Job Responsibility

Develop and maintain ABAC-related third-party policies, procedures, and training materials
Develop and deliver targeted ABAC training programs for third party partners and internal stakeholders, tailored to risk level, geography, and business function
Ensure third parties understand and commit to the company’s anti-corruption standards and expectations
Conduct enhanced due diligence (EDD) on high-risk distributors and suppliers, including ownership structure, reputation checks, and red flag analysis
Ensure compliance with global anti-corruption regulations (e.g., FCPA, UK Bribery Act)
Perform periodic risk assessments of third-party populations to identify ABAC exposure
Develop and maintain risk scoring methodologies and dashboards for ongoing monitoring
Lead investigations into potential ABAC violations involving third parties
Monitor training completion and effectiveness and implement corrective actions where necessary
Collaborate with internal stakeholders to embed training into onboarding and renewal processes for third parties
Immediately remediate and communicate data gaps and general issues, escalating as needed
Continuously improve risk-based due diligence processes for third parties
Support internal and external audits related to third-party risk
Collaborate with Legal, Finance, and business units to ensure alignment and integration of ABAC controls
Support relevant risk assessment processes, including but not limited to appropriateness of the third parties’ involvement in health care professional (HCP) engagement activities, grants/donations, and Commercial support opportunities
Liaise with the Commercial team responsible for distributor relationships to identify any issues and promptly assess the risks
Provide guidance and training to internal stakeholders on ABAC risks and mitigation strategies
Present findings and recommendations to senior leadership and governance committees
Identify and schedule project deliverables, milestones, and required tasks
Focus on continuous improvement, specifically to systems-related processes
Partner with executive leadership in the International Business Unit to ensure successful communication, implementation, and change management regarding regulatory or internal process changes
Ensure that systems operate in a manner comporting with laws, regulations and industry standards that include, among other topics, relevant regulatory requirements, and compliance with applicable corporate codes and policies (e.g., the Company’s Code of Conduct on Interactions with Health Care Professionals, which is based on the AdvaMed Code of Ethics on Interactions with Health Care Professionals)
Create and maintain metrics for various levels of regulatory compliance monitoring, reporting and governance
Provide metrics and reporting directly as requested from senior and executive leaders, including contributing data for quarterly Compliance Committee meetings, Board of Directors meetings, etc.
Identify potential weaknesses in the compliance program and proactively suggest improvements to address them
Collaborate with other departments to direct compliance issues to appropriate existing channels for investigation and resolution
Regularly train and educate other functions (e.g., Commercial, Market Access, Legal, etc.) on the relevance of their daily duties to due diligence processes
Independently identify trends and/or risks based upon data analysis
Work with all levels of the compliance and legal team on policy decisions, procedures and issues
Uphold the company’s mission and values through accountability, innovation, integrity, quality, and teamwork
Support and comply with the company’s Quality Management System policies and procedures

Requirements

Bachelor’s degree in Law, Business, Finance, Risk Management, or related field
5+ years of experience in third-party risk management, compliance, or legal roles with a focus on ABAC
Deep understanding of global anti-corruption laws and enforcement trends, including the Foreign Corrupt Practices Act (FCPA)
Experience conducting due diligence and managing third-party risk in complex, multinational environments
Strong analytical, investigative, and communication skills
Proficiency in compliance tools and platforms (e.g., LexisNexis, Dow Jones, NAVEX, etc.)
Experience with due diligence tools and platforms
Professional working proficiency in the English language
Proficient in Microsoft Office programs, including but not limited to Visio, PowerPoint, Excel, Word, and Outlook
Adaptable, open to change, and able to work in ambiguous situations and respond to new information and unexpected circumstances
Strong written, verbal, and presentational communication skills
Strong analytical skills and attention to detail
Ability to balance multiple projects and complex tasks, while working independently, and utilizing prioritization to work towards the achievement of projects
Ability to function productively within a fast-paced, multi-tasking, entrepreneurial environment
Demonstrated ability to perform the Essential Duties of the position with or without accommodation
Ability to work on a designated schedule
Ability to work on a mobile device, tablet, or in front of a computer screen and/or perform typing for approximately 90% of a typical working day
Ability and means to travel between local Exact Sciences locations
Work at least 60% of each week in the Exact Sciences Warsaw office
Ability to travel up to 10% of working time away from work location, may include overnight/weekend travel, including to Switzerland and the United States

Nice to have

Certification in compliance (e.g., CCEP, CCEP-I, CHC, CHPC, CHRC) is a plus
Fluency in non-English language (e.g., French, German, Italian, Japanese, Spanish, etc.)
Experience providing guidance based on the Foreign Corrupt Practices Act (FCPA)
Working proficiency in other languages such as German, French, or Spanish is a plus

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Lead Compliance Program Manager

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