VP, Ombuds & Ethics

VP, Ombuds and Ethics

The VP, Ombuds and Ethics will champion a culture of integrity, fairness, and transparency within the organization. This leader will serve as a trusted advisor and resource for employees, management, and executives to address potential ethical, compliance, and conduct-related matters. The role involves ombuds (ethics/integrity) program management, conflict of interest program management, as well as providing guidance on appropriate conduct risk metrics, themes and potential issues.

This leader must demonstrate a strong commitment to a workplace where ethics and fair and responsible conduct are prioritized and reinforced at all organizational levels.

Essential Responsibilities:

Ombuds Program

• Own the Ethics/Ombuds Program charter and operating model, including scope, independence, decision rights, escalation thresholds, and relationship to HR/Legal investigations. Ensure the program respects confidentiality, anti-retaliation principles and embraces impartiality and objectivity.
• Ensure consistent taxonomy and documentation standards for concerns (categorization, substantiation/outcome labels, root-cause tagging) to improve trend accuracy and defensibility.
• Establish and monitor service standards (SLAs) for intake, triage, handoffs, case updates, time-to-close, and communications to concern raisers, with periodic quality reviews.
• Act as a confidential and neutral resource for employees to discuss concerns, conflicts, or potential misconduct and foster a culture where employees feel empowered to speak up and report concerns.

Conflict of Interest

• Oversee the Conflict-of-Interest Program and Policy ensuring proper and timely notification to all employees of their requirement to complete the conflict-of-interest survey periodically, evaluation and assessment of employee conflict of interest disclosures in partnership with business leaders, HR and Legal, and regular reporting and escalation of past due surveys to leadership.
• Enhance COI program and escalation criteria for high-risk disclosures (outside employment, gifts/entertainment, vendor relationships, political activity where relevant) and ensure consistent dispositioning.
• Perform periodic COI control testing (sampling, validation, timeliness, completeness)

Conduct Risk

• Partner with Fraud, Legal and relevant Compliance leaders on enterprise "conduct risk" governance, including enhancement of conduct risk appetite/indicators and integrating ethics themes into enterprise risk reporting. Develop a forward-looking emerging conduct risk view (e.g., incentive risks, customer harm signals, workforce pressures, new products/partners) and recommend proactive controls.
• Partner with applicable stakeholders to perform root-cause analysis and thematic remediation for recurring issues (e.g., sales practices, servicing, collections, management behavior), including tracking corrective actions to closure.

Policies and Training

• Oversee the review and potential revisions of the Code of Conduct
• Develop and deliver ethics and conduct training programs to educate employees on relevant policies and risk management.

Reporting

• Chair the Ombuds Subcommittee providing data regarding trends and themes related to concern reporting in various geographical locations and business functions. In conjunction with the Legal Department, identify and report on issues that may arise out of investigations as well as actions to appropriately mitigate the risk identified.
• Prepare and present reports to the Audit Committee of the Board on a regular basis on ethics, conduct and concern trends and themes as well as related risks and corrective action leveraging key performance and key risk indicators associated with the Ombuds program.

Supplier Management

• Perform supplier management duties related to the third-party vendor who provides the Conflict-of-Interest platform and the Ombuds hotline, website, and case management/reporting tools for the Ombuds Program including SOC reports, privacy/security requirements, BCP/DR testing, and periodic vendor performance and risk reviews.
• Integrate ethics expectations into the supplier lifecycle in partnership with Third Party Risk…