Torchora
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corporate ethics officer

title: Key Responsibilities and Required Skills for Corporate Ethics Officer
salary: $110,000 - $220,000
categories: [Compliance, Ethics, Legal, Risk Management, Governance]
description: A comprehensive overview of the key responsibilities, required technical skills and professional background for the role of a Corporate Ethics Officer.
Corporate Ethics Officer position: senior compliance and ethics leadership role responsible for designing, implementing, and managing enterprise-wide ethics and compliance programs, investigations, policy development, training, third-party due diligence, and reporting to the Board and C-suite. Ideal candidate has proven experience in regulatory risk management, internal investigations, code of conduct development, and change management.

🎯 Role Definition

The Corporate Ethics Officer is a senior leader responsible for establishing and sustaining an integrated ethics and compliance program that protects the company's reputation, minimizes regulatory and legal risk, and fosters an ethical culture across all lines of business. This role leads cross-functional efforts to develop policies, conduct investigations, implement training, manage third-party and anti-corruption due diligence, and report ethics metrics to executive leadership and the Board. The ideal candidate combines deep regulatory knowledge, proven investigative skills, strong stakeholder engagement, and the ability to translate complex regulatory expectations into practical business processes.

📈 Career Progression

Typical Career Path

Entry Point From:

  • Senior Compliance Manager or Regional Compliance Lead
  • Legal Counsel specializing in regulatory or corporate governance matters
  • Head of Ethics & Integrity / Anti-Corruption Program Manager

Advancement To:

  • Chief Compliance Officer (CCO)
  • Chief Legal Officer (CLO) / General Counsel
  • Head of Risk & Governance

Lateral Moves:

  • Head of Regulatory Affairs
  • Director of Internal Audit
  • Head of Third-Party Risk Management

Core Responsibilities

Primary Functions

  • Lead the development, implementation, and continuous improvement of an enterprise-wide ethics and compliance program, including the company Code of Conduct, policies, procedures, monitoring mechanisms, and governance frameworks to ensure adherence to domestic and international laws and best practices.
  • Design, coordinate and oversee complex internal investigations into allegations of misconduct, fraud, harassment, conflicts of interest, bribery, and other ethics-related incidents, ensuring investigations are thorough, timely, documented, and legally defensible.
  • Serve as the primary escalation point for whistleblower reports and confidential complaints, manage the intake and triage process, ensure protection against retaliation, and coordinate remediation and corrective actions.
  • Develop and deliver role-based ethics and compliance training programs—both in-person and e-learning—to employees, officers, and the Board, using metrics and learning assessments to measure effectiveness and drive continuous improvement.
  • Build and maintain strong relationships with senior leadership, business unit heads, HR, Legal, Internal Audit, Finance, and external counsel to align ethics program priorities with business objectives and regulatory expectations.
  • Manage regulatory engagement and governmental inquiries related to ethical conduct, anti-corruption, trade controls, insider trading, and other compliance matters; prepare responses, coordinate document production, and advise on remediation plans.
  • Establish and monitor key performance indicators (KPIs) and program metrics (e.g., training completion, investigation cycle times, hotline usage, remediation outcomes) and report program health and risk trends to the Board, Audit Committee, and executive leadership.
  • Oversee third-party due diligence and vendor risk programs, including onboarding and ongoing monitoring processes for agents, distributors, suppliers, and joint venture partners to mitigate corruption, sanctions, and reputational risks.
  • Lead enterprise risk assessments focusing on ethical, regulatory, and reputational exposures—identify high-risk processes and geographies, recommend risk-based controls, and partner with owners to implement remediation and monitoring.
  • Develop and maintain clear, practical policies and procedures—covering conflict of interest, gifts and hospitality, anti-bribery, data ethics, social media, and political activity—and ensure timely communication and enforcement across the organization.
  • Provide proactive compliance advisory services to business units and project teams (M&A, product launches, global expansion) to embed ethics considerations into strategic decisions and operational processes.
  • Coordinate with Internal Audit and Risk teams to design testing plans, perform control testing, and validate the effectiveness of ethics and compliance controls—drive closure of findings and preventive remediation.
  • Maintain and evolve the company’s ethics reporting channels (hotline, web intake, multilingual capabilities), ensure confidentiality and integrity of data, and oversee triage, investigation, and closure workflows.
  • Oversee privacy and data ethics boundaries as they relate to investigations and reporting, ensuring handling of sensitive employee and business information complies with applicable data protection laws and internal policies.
  • Establish and manage escalation protocols and disciplinary frameworks related to ethics violations, working with HR and Legal to ensure fair, consistent, and defensible outcomes aligned with company policy and local law.
  • Champion a culture of integrity by developing communications campaigns, leadership briefings, and behavior change initiatives that promote ethical decision-making and speak-up behavior across the enterprise.
  • Provide ethics input and oversight for business transactions—M&A diligence, strategic partnerships, joint ventures, and third-party onboarding—and recommend contractual protections and remediation conditions.
  • Lead scenario-based ethics risk workshops and tabletop exercises with senior leaders to prepare for crisis response related to ethics breaches, regulatory investigations, or reputational incidents.
  • Oversee budget, staffing, and vendor relationships for the ethics program including external investigators, consultants, technology solutions (case management, training platforms, screening tools), and benchmarking services.
  • Maintain current knowledge of global regulatory requirements and enforcement trends (FCPA, UK Bribery Act, OFAC, anti-money laundering, labor and employment law) and translate changes into operational policies and training.
  • Manage and improve conflict of interest disclosure processes for senior leaders and high-risk roles, ensuring ongoing monitoring and appropriate mitigations are in place and documented.
  • Prepare materials, deliver briefings and present program updates and incident summaries to the Board, Audit/Compliance Committees, and C-suite with clear risk analysis and actionable recommendations.
  • Conduct benchmarking and gap analyses against industry best practices and peer programs, develop multi-year roadmaps to mature ethics capabilities and prioritize investments based on risk and ROI.
  • Implement systems and processes for recordkeeping, documentation retention, and data analytics to identify trends, hotspots, and early warning signals that inform proactive interventions.

Secondary Functions

  • Support ad-hoc ethics data requests, perform trend analysis on incidents and hotline data, and produce executive-level dashboards that inform risk prioritization.
  • Collaborate with Technology and Security teams to evaluate and implement case management systems, third-party screening platforms, and automated monitoring tools for enhanced program scalability.
  • Contribute to cross-functional policy reviews and change initiatives (HR processes, procurement, sales incentives) to minimize unintended ethical risk exposures and ensure alignment with compliance standards.
  • Partner with Talent and HR to integrate ethics criteria into hiring, performance management, and promotion processes to reinforce behavioral expectations.
  • Participate in industry working groups and trade associations to share best practices, stay current on evolving compliance trends, and represent the company in regulatory dialogues.
  • Provide coaching and advisory support to regional ethics leads and local compliance officers to ensure consistent program execution and escalation across jurisdictions.

Required Skills & Competencies

Hard Skills (Technical)

  • Proven expertise in designing, implementing, and operating enterprise ethics and compliance programs, including policy development, monitoring, testing, and remediation.
  • Strong investigative skills with experience conducting workplace, fraud, AML, anti-bribery/corruption, and whistleblower investigations using defensible and legally compliant methodologies.
  • Knowledgeable in global regulatory regimes and enforcement priorities (FCPA, UK Bribery Act, OFAC, AML, GDPR, anti-trust basics) with practical experience translating regulation to controls.
  • Experience with third-party due diligence platforms, sanctions screening, anti-corruption risk assessments, and vendor management tools.
  • Familiarity with case management and whistleblower systems, data analytics for compliance (hotline analytics, RCM tools), and experience deploying e-learning and role-based training platforms.
  • Ability to design and interpret compliance metrics and KPIs, build executive dashboards, and produce Board-level reporting using BI tools (Power BI, Tableau, or equivalent).
  • Contract and transactional diligence experience, including embedding ethics clauses and remediation conditions into M&A and commercial agreements.
  • Budgeting, vendor management, and program governance experience, including oversight of external investigations, consulting engagements, and technology vendors.
  • Working knowledge of employment law and HR processes as they relate to disciplinary actions, investigations, and confidentiality across multiple jurisdictions.
  • Practical experience with privacy and data protection requirements relevant to handling investigation-related data (PII, sensitive personnel records).

Soft Skills

  • Exceptional judgment and discretion handling sensitive, confidential, and high-profile matters with integrity.
  • Strong leadership skills with the ability to influence senior executives, build cross-functional partnerships, and drive cultural change.
  • Excellent oral and written communication skills for preparing concise Board-level presentations, policy documents, and investigative reports.
  • Analytical and critical thinking with the ability to synthesize complex issues into clear risk-based decisions and actionable recommendations.
  • Resilient under pressure and able to manage competing priorities, tight deadlines, and crisis situations calmly and effectively.
  • High emotional intelligence and ability to manage stakeholder expectations, mediate disputes, and navigate complex organizational dynamics.
  • Change management and training facilitation skills to embed new policies, processes, and ethical behaviors across diverse teams.
  • Negotiation and conflict resolution skills, particularly when coordinating remedial actions with HR, Legal, and business leaders.
  • Strategic mindset with a focus on continuous program improvement, scalability, and measurable business impact.
  • Cultural sensitivity and global mindset to apply consistent ethics standards while respecting local laws and business practices.

Education & Experience

Educational Background

Minimum Education:

  • Bachelor's degree in Law, Business Administration, Ethics, Finance, Criminal Justice, or related field.

Preferred Education:

  • Juris Doctor (JD), Master of Laws (LLM), MBA, or advanced degree in Compliance, Public Policy, or Ethics.
  • Professional certifications such as CCEP (Certified Compliance & Ethics Professional), CFE (Certified Fraud Examiner), CAMS, or similar are highly desirable.

Relevant Fields of Study:

  • Law / Legal Studies
  • Business Administration / Corporate Governance
  • Criminology / Fraud & Forensic Accounting
  • Public Policy / Ethics
  • Finance / Risk Management

Experience Requirements

Typical Experience Range:

  • 8–15 years of progressively responsible experience in compliance, ethics, legal, internal investigations, or regulatory roles; including experience leading enterprise-wide programs.

Preferred:

  • 10+ years in a multinational or highly regulated industry with documented success leading investigations, building compliance frameworks, and reporting to senior leadership and Boards.
  • Proven track record managing cross-border issues, third-party risk programs, and interfacing with external regulators and law enforcement.
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