Compliance Manager Northern Europe and Central

Recordati, established in 1926, is an international pharmaceutical group, listed on the Italian Stock Exchange (Reuters RECI.MI, Bloomberg REC IM, ISIN IT 0003828271), with a total staff of more than 4,300, dedicated to the research, development, manufacturing and marketing of pharmaceuticals. Headquartered in Milan, Italy, Recordati has operations in Europe, Russia and the other C.I.S. countries, Ukraine, Turkey, North Africa, the United States of America, Canada, Mexico, some South American countries, Japan and Australia. An efficient field force of medical representatives promotes a wide range of innovative pharmaceuticals, both proprietary and under license, in several therapeutic areas including a specialized business dedicated to treatments for rare diseases. Recordati is a partner of choice for new product licenses for its territories. Recordati is committed to the research and development of new specialties with a focus on treatments for rare diseases.

**Role purpose**:
To be the compliance business partner, with a focus on Ethics, Anti-Bribery, Anti-money laundering, Anti-trust, Privacy, Healthcare compliance (e.g.: interactions with HCPs, HCOs, grants, donations, etc.), trade sanctions, disclosure and transparency obligations. To guarantee compliance with legal requirements, enable and drive ethical business conduct through the effective implementation of Group Ethical Code, Group Anti Bribery Program and Group Policies. To share best practices and guarantee synergies between Affiliates under his / her responsibilities.

To provide guidance, support and coordination to local resources partly or fully dedicated to Compliance.

To guarantee proper implementation of HQ Guidelines.

**Location: Paris, Ulm or Warsaw**

Major Accountabilities, to be implemented directly or in collaboration with local resources:
**Policies**:

- Design and operate the Compliance Process according to Group Ethical Code, Group Anti-Bribery Program, Group Policies and local legislation.
- Establish compliance standards based on internal policies and guidelines, SOPs for relevant policies, align local standards with Group standards and ensure that in all cases the most stringent is applied.
- Actively follow trends in the market, in the regulatory environment, in industry associations and in other compliance related stakeholder groups.
- Periodically revise procedures, reports etc. to identify / mitigate hidden risks or non-conformity issues.
- Contribute to the continuous improvement of the existing processes.
- Develop and implement compliance communications.
- Guarantee best practices are duly shared between affiliates under his / her responsibility.
- When possible, guarantee synergies between affiliates under his / her responsibility.

**Monitoring / Assessment**
- Oversee and continuously improves the internal control systems to prevent or deal with violations of legal guidelines and internal policies.
- Draft a yearly compliance plan, approved by Business Regional Directors NE - CEE and by Group Audit & Compliance.
- Design, perform and coordinate compliance monitoring activities, on the basis of either the approved plan or ad-hoc request from Business Regional Directors / General Managers.
- Assess and develop internal controls related to Group Ethical Code, Group Anti Bribery Manual and group polices.
- Prepare and conduct / give inputs to compliance reviews.
- Monitor compliance with data protection legislations and internal policies and regulations.
- Establish a yearly compliance risk assessment process: inform Business Regional Directors NE - CEE / General Managers and senior management on identified compliance risks and define compliance risk mitigation plan.
- Conduct self-assessments to monitor the status of the compliance program at local level.

**Collaboration**
- Collaborate with Group Audit and Compliance Department and other relevant departments to monitor enforcement of standards and regulations.
- Provide support to Business Regional Directors NE - CEE / General Managers.
- Provide support to Group Audit and Compliance teams on specific projects / topics.
- Provide timely and practical compliance advice and support to the Business Regional Directors NE - CEE / General Managers and various departments.
- Work closely with internal legal advisors to ensure appropriate management of legal risks.
- Coordinate the preparation of self-certifications, providing guidance on spot check requests, responding to requests for information, preparing self-reports and exception reports, responding to complaints and conducting compliance investigations.
- Review and revise agreements for what it concerns compliance topics.

**Reporting**
- Prepare reports for senior management, Group Audit & Compliance teams and external regulatory bodies (when required).
- Regularly update the Business Regional Directors NE - CEE / General Managers, senior management and Group Audit and Compliance teams on the status of the complian