Ethics & Compliance Officer

**Requisition ID: 266662**
- ** Relocation Authorized: None**:

- ** Telework Type: Part-Time Telework**:

- ** Work Location: New Delhi**

**Role Overview**
- “Business organization E&C officers may appoint Compliance Contacts to assist with the implementation of the ethics and compliance program within their organizations and under their direction.”_

**_ The Compliance Contact is the Ethics & Compliance Program’s eyes and ears on the ground in the project._**

**Essential Role Functions**
- ** Awareness**
- Ensure that the core elements of Bechtel’s Ethics & Compliance (E&C) program are known to all Bechtel office personnel and available on all project sites in country, by:

- posting Ethics HelpLine posters that identify the names of the Ethics & Compliance Contact and GBU E&C Officer, and the local number for the Ethics HelpLine;
- verifying that the Ethics HelpLine works from local phone numbers in the office and mobile lines; the E&C myBechtel website is accessible to country employees;
- keeping a reference copy of Bechtel Code of Conduct and Anti-Corruption Compliance Guidelines are in your office;
- verifying that onboarding includes references to the Bechtel Code of Conduct and Anti-Corruption Compliance Guidelines, any country specific compliance risks or areas of increased attention, and messaging explaining Bechtel’s VVC, how to address concerns or observed misconduct, Bechtel’s prohibition on retaliation; and
- relaying messages from E&C Corporate program (e.g. upon notice from the Chief Ethics & Compliance Officer or GBU E&C Officer, when a new policy or management instruction is rolled out or new Communications are drafted).
- ** Training**
- Assist country’s leadership team and managers to ensure timely organization and completion of the annual Ethics Awareness Workshops
- Assist GBU E&C Officer to organize any additional ad hoc trainings (e.g. post-incident remedial trainings, trainings required by the E&C Corporate Plan, if applicable)
- Make recommendations to GBU E&C Officers and/or Country Manager about new trainings, communications or processes based on his/her observations and assessments, and feedback received from staff members.
- ** Inquiries, allegations, investigations**
- Respond to simple inquiries about the Program and its implementation.
- Refer inquiries you are unsure about to the GBU E&C Officers.
- Notify the GBU E&C Officers of all material inquiries and, if asked by the GBU E&C Officers, enter them in the Bechtel Case Management System (BCMS), to ensure that these are tracked for trend analysis and that the answers are consistent company-wide.
- Allegations are concerns about a specific action or lack of action that may require investigation.
- Work in accordance with the requirements of GBU E&CO to have an established process to address allegations.
- Facilitate contact to the Ethics HelpLine or GBU E&C Officer. If the Reporter expresses a preference for an in-person conversation with you, or you have reason to believe he or she would not share the concern any other way, collect as much detail as possible from the Reporter to understand the nature of the issue. Do not alert anyone of the allegation, but report it immediately the GBU E&C Officer or Ethics HelpLine Manager. Do not discuss with others unless/until approved by the GBU E&C Officer or a Bechtel Ethics & Compliance Investigator (“ECI”).
- At the request of the ECI, you may be asked to assist in the investigation of suspected violations of Bechtel's ethical standards, applicable laws and regulations, and company policy.
- Work with the ECI or GBU E&C Officer to communicate with country management about the matter and actions being taken to address it, both during and at the conclusion of the investigation.
- Monitor for signs of retaliation against anyone raising good faith questions or concerns, or for participating in/supporting an investigation.
- Notes on addressing allegations
- If anyone at the office asks an Ethics & Compliance Officer to investigate what they consider to be an ethics or compliance matter, explain that you are not authorized to investigate matters on your own, and contact the GBU E&C Officer or enter it in BCMS.
- The Ethics HelpLine Manager is available to assist Ethics & Compliance Officer at any time with any aspect of the use of the BCMS.
- If you have been entering case details in BCMS, notify the GBU E&C Officer when the case can be closed and the file is complete, so that he/she may concur with the decision to close it.
- ** Other duties based on office’s E&C plan**
- Knowledge of applicable E&C program expectations
- Seek and collect any documents, statements, certifications and representations made during in any tender, included in the contract terms or are dictated by legal requirements that call for specific behaviors in the area of Ethics & Compliance; make sure these are well communicated alongside the Bechtel E&C program expectations.
- Communications