The Position

The Senior Ethics and Compliance (E&C) Investigator will conduct investigations into ethics and compliance issues and remediate employee adherence to Novo Nordisk policies, federal and state laws, and regulations. The Senior Investigator will identify and analyze ethics and compliance risk to the company, including by providing assistance with the development and implementation of remediation measures for matters identified through investigations. The Senior Investigator also will partner with key stakeholders to provide guidance and subject matter expertise on ethics and compliance issues and work to promote a culture of ethics and compliance at the company.

Relationships

Reports to the Director, E&C Risk Insights & Management. Internal stakeholders include Ethics & Compliance (E&C) colleagues across Novo Nordisk globally, Legal, People & Organization, and colleagues throughout other E&C Department functional areas. External relationships include outside counsel, vendors and consultants as well as developing and maintaining relationships with the broader ethics and compliance network within the industry.

Essential Functions

• Manages and conducts internal USO investigations of alleged violations of policy or unethical or illegal conduct independently with limited supervision and ensures that allegations are promptly, thoroughly and objectively assessed in accordance with company standards and expectations
• Develops and maintains an investigative workplan, performs source documentation review/analysis, and conducts witness and subject interviews
• Develops case files and reports that are factually complete, accurate, well-organized, and prepared with evidentiary and procedural standards that may be necessary for downstream enforcement, recoveries, or defense
• Responsible for maintaining consistent, fair, and unbiased investigation processes (e.g., triage, discipline recommendation, preparation of investigation reports and summaries)
• Performs root cause analysis and identifies potential remediation and/or discipline recommendations based on relevant information gathering
• Prepares and delivers clear and concise written reports and oral briefings that translate complex investigative facts into clear narratives for senior leadership and other stakeholders
• Ensures the Director, E&C Risk Insights & Management, is aware of significant cases under investigation in a timely manner for alerting E&C leadership and senior leadership, as relevant
• Partners with in-house and external counsel to conduct legally privileged investigations, as needed
• Identifies patterns, trends, and risks emerging from investigations and recommends mitigation measures
• Collaborates with colleagues across the E&C Department (e.g., Business Partners, Monitoring & Auditing, Policies and Training) to share investigations trends, insights and lessons learned to support risk management efforts, including training and the annual E&C Risk Assessment
• Supports the Ethics & Compliance Program, raising awareness and fostering accountability for ethics & compliance throughout the organization
• Champions a proactive approach to ethics and compliance that is focused on partnership, prevention, and risk management
• Serves as a trusted extension of the Director, E&C Investigations, providing leadership support and stepping in as needed to ensure continuity, consistency, and effective execution of investigations
• Maintains an understanding of laws and regulations, enforcement actions and evolving practices relevant to pharmaceutical compliance and proposes updates to Ethics & Compliance program, as appropriate
• Participates in industry associations and events as appropriate to raise the profile of the Ethics & Compliance program and the company

Physical Requirements

5-15% overnight travel required.

Qualifications

• A Bachelor's degree from an accredited institution is required. A Juris Doctorate law degree, or Advanced Degree from an accredited college, university, or graduate program in the compliance and health-care related fields, preferred
• Certified Fraud Examiner (CFE) certification is highly preferred
• Minimum of eight (8) years combined pharmaceutical, compliance, legal, regulatory, or audit experience required OR a minimum of six (6) years of experience required if accompanied by an advanced degree or certificate (MBA, JD, PMP, etc.)
• A minimum of five (5) years' experience as an investigator/auditor, preferably in the pharmaceutical industry, with particular emphasis on investigating/auditing marketing and sales
• High standard of ethics and integrity
• Treats stakeholders and parties with respect and upholds the foundational principles of the Novo Nordisk Way
• Experience using data driven tools (AI/ML), Microsoft Excel tools (e.g., Pivot Tables, VLOOKUP, etc.), social media sources, or other investigative tools (e.g., Relativity) to support information gathering and analysis
• Demonstrates strong interpersonal skills and ability to influence at all levels of the organization
• Ability to partner and collaborate effectively with stakeholders
• Exceptional attention to detail and the ability to apply sound judgement and critical thinking to complex situations
• Knowledge of federal and state laws, regulations and industry guidance applicable to the pharmaceutical industry
• Handles confidential information with discretion
• Must be able to analyze and present data in an efficient and logical format
• Excellent organization skills and ability to communicate (written and verbal) complex issues with simplicity and efficacy
• Ability to respond to competing priorities across the department and manage workload effectively, set priorities, and deliver results
• Ability to exercise independent judgement, think objectively, and use sound reasoning principles
• Effective time management skills

The base compensation range for this position is $120,300 to $222,600. Base compensation is determined based on a number of factors. This position is also eligible for a company bonus based on individual and company performance. Novo Nordisk offers long-term incentive compensation and or company vehicles depending on the position's level or other company factors.

Employees are also eligible to participate in Company employee benefit programs including medical, dental and vision coverage; life insurance; disability insurance; 401(k) savings plan; flexible spending accounts; employee assistance program; tuition reimbursement program; and voluntary benefits such as group legal, critical illness, identity theft protection, pet insurance and auto/home insurance. The Company also offers time off pursuant to its sick time policy, flex-able vacation policy, and parental leave policy.