Associate General Counsel - Ethics & Compliance

JOB SUMMARY:

In this fast-paced role, you will provide legal advice, support and counsel on a wide range of ethics and compliance matters to Textron Aviation Inc. and its global operations to support compliance with Textron Inc.’s Business Conduct Guidelines and related policies, as well as compliance with applicable laws and regulations. The role encompasses planning, management and implementation of Textron Aviation’s Ethics & Compliance Program, including conducting risk assessments, planning risk mitigation activities, scheduling and conducting training, developing and updating policies, and reporting to senior management. The position is directly involved in conducting due diligence assessments on all of Textron Aviation’s international channel partners and supports the channel distribution and sales teams.

This position requires a candidate with varying levels of expertise and experience with a variety of compliance topics and will have demonstrated ability or expertise in at least one key compliance area, such as, anti-corruption, export control, anti-money-laundering, U.S sanctions and embargos, U.S. Government contract compliance or some comparable area of law.

This role will supervise two compliance specialists, requires on site presence, and is not a remote or work from home position.

JOB RESPONSIBILITIES:

·Provide timely, actionable guidance to Textron Aviation Inc. personnel located in the U.S. and abroad on a wide range of compliance topics including Textron Inc.’s Business Conduct Guidelines, anti-corruption, anti-money laundering, antitrust, channel distribution, antiboycott and sanctions compliance.

·Provide transactional support to various areas of the business as assigned.

·Liaise with the Textron Inc’s. compliance team to coordinate the Textron Aviation compliance programs with those of the parent organization.

·Develop and manage Textron Aviation’s annual compliance plan.

·Lead the quarterly Ethics & Compliance Steering Committee Meeting with the Textron Aviation Senior Leadership Team.

·Directly manage and supervise Textron Aviation’s Ethics and Compliance personnel, currently two Specialists in Business Ethics & Compliance.

·Oversee assigned internal and external ethics and compliance investigations.

·Interface with regulatory agencies seeking information about compliance related activities.

·Work with Human Resources, Finance and Trade Compliance to coordinate compliance activities.

·Provide legal and contract support to the channel distribution team.

·Review collected due diligence for purposes of assessing the compliance risks posed by each international Covered Business Partner (CBP) and then recommending approval or rejection of the proposed relationship.

·Provide legal guidance related to the use and tuning of the denied party screening tools and the due diligence required to resolve potential matches.

·Review and approve business unit requests to provide meals, gifts and hospitality to foreign government officials.

·Review and manage the approval of requests to provide transportation to government officials.

·Prepare and deliver training to employees and channel partners on a wide range of ethics and compliance topics.

·Manage internal and external compliance audits.

·Conduct internal self-assessments and prepare annual reports on the functioning of the compliance program.

·Lead and continue the development of the internal Compliance Liaison Program.

·Prepare and disseminate regular compliance communications on emerging compliance risks and new regulatory requirements.

·Review and provide guidance on the completion of supplier and customer ethics and compliance related certification forms.

·Review transactional documents and approve the acceptance of payments in accordance with Textron Aviation’s Acceptable Methods of Payment policy.

·Participate in and provide legal support of other legal matters and activities as assigned.

·Regularly and directly interface with Human Resources, Finance, Sales, Trade Compliance, and the Textron Inc. Ethics & Compliance team.

JOB SUMMARY:

In this fast-paced role, you will provide legal advice, support and counsel on a wide range of ethics and compliance matters to Textron Aviation Inc. and its global operations to support compliance with Textron Inc.’s Business Conduct Guidelines and related policies, as well as compliance with applicable laws and regulations. The role encompasses planning, management and implementation of Textron Aviation’s Ethics & Compliance Program, including conducting risk assessments, planning risk mitigation activities, scheduling and conducting training, developing and updating policies, and reporting to senior management. The position is directly involved in conducting due diligence assessments on all of Textron Aviation’s international channel partners and supports the channel distribution and sales teams.

This position requires a candidate with varying levels of expertise and experience with a variety of compliance topics and will have demonstrated ability or expertise in at least one key compliance area, such as, anti-corruption, export control, anti-money-laundering, U.S sanctions and embargos, U.S. Government contract compliance or some comparable area of law.

This role will supervise two compliance specialists, requires on site presence, and is not a remote or work from home position.

JOB RESPONSIBILITIES:

·Provide timely, actionable guidance to Textron Aviation Inc. personnel located in the U.S. and abroad on a wide range of compliance topics including Textron Inc.’s Business Conduct Guidelines, anti-corruption, anti-money laundering, antitrust, channel distribution, antiboycott and sanctions compliance.

·Provide transactional support to various areas of the business as assigned.

·Liaise with the Textron Inc’s. compliance team to coordinate the Textron Aviation compliance programs with those of the parent organization.

·Develop and manage Textron Aviation’s annual compliance plan.

·Lead the quarterly Ethics & Compliance Steering Committee Meeting with the Textron Aviation Senior Leadership Team.

·Directly manage and supervise Textron Aviation’s Ethics and Compliance personnel, currently two Specialists in Business Ethics & Compliance.

·Oversee assigned internal and external ethics and compliance investigations.

·Interface with regulatory agencies seeking information about compliance related activities.

·Work with Human Resources, Finance and Trade Compliance to coordinate compliance activities.

·Provide legal and contract support to the channel distribution team.

·Review collected due diligence for purposes of assessing the compliance risks posed by each international Covered Business Partner (CBP) and then recommending approval or rejection of the proposed relationship.

·Provide legal guidance related to the use and tuning of the denied party screening tools and the due diligence required to resolve potential matches.

·Review and approve business unit requests to provide meals, gifts and hospitality to foreign government officials.

·Review and manage the approval of requests to provide transportation to government officials.

·Prepare and deliver training to employees and channel partners on a wide range of ethics and compliance topics.

·Manage internal and external compliance audits.

·Conduct internal self-assessments and prepare annual reports on the functioning of the compliance program.

·Lead and continue the development of the internal Compliance Liaison Program.

·Prepare and disseminate regular compliance communications on emerging compliance risks and new regulatory requirements.

·Review and provide guidance on the completion of supplier and customer ethics and compliance related certification forms.

·Review transactional documents and approve the acceptance of payments in accordance with Textron Aviation’s Acceptable Methods of Payment policy.

·Participate in and provide legal support of other legal matters and activities as assigned.

·Regularly and directly interface with Human Resources, Finance, Sales, Trade Compliance, and the Textron Inc. Ethics & Compliance team.

EDUCATION/ EXPERIENCE:

• Juris Doctorate degree from an accredited law school.
• Must be a member of the Kansas bar or meet eligibility requirements for admission to the Kansas bar under Rule 721 for a corporate law license.

• Minimum 7-10 years law firm or in-house experience relevant to international business transactional or defense contracts (with at least 5 years of compliance experience).

QUALIFICATIONS:

• Experience working in-house or representing a publicly-traded company is preferred.

• The innate ability to collaborate with the business to drive transactions toward completion.

• Proven track record of confronting and successfully resolving complex legal, commercial, and compliance matters with significant financial and business impact.

• Demonstrated ability to recognize and weigh business and legal risks; lead strategically and advance innovative solutions.

• Strong interpersonal skills and ability to interact effectively, work diplomatically, and foster relationships with individuals at all levels including internal contacts, outside attorneys and vendors.

• Extensive knowledge of and experience with ethics & compliance programs, FCPA, OFAC, international trade sanctions, and other government laws and regulations pertaining to corporate compliance.

• Inspires trust and confidence throughout the organization; a drive to deliver quality results on time and in a highly ethical and professional manner.

• Ability to effectively manage multiple assignments simultaneously with a minimum amount of supervision.

• A team player with an open, mature and positive personality who is willing to share and communicate information effectively.

• Must have strong work ethics and a desire to consistently perform at the highest levels of competence.

• Open to periodic travel, both domestically and internationally.

• Experience in the aerospace or defense industry is preferred.

Textron Aviation Inc. must comply with U.S. export control laws and regulations. If a position requires access to sensitive information controlled under these laws and regulations, a successful applicant must be eligible to meet any requirements to access controlled information.

The above statements are intended to describe the general nature and level of work being performed by employees assigned to this job. They are not intended to be an exhaustive list of all responsibilities, duties, and skills required of personnel so classified.

EDUCATION/ EXPERIENCE:

• Juris Doctorate degree from an accredited law school.
• Must be a member of the Kansas bar or meet eligibility requirements for admission to the Kansas bar under Rule 721 for a corporate law license.

• Minimum 7-10 years law firm or in-house experience relevant to international business transactional or defense contracts (with at least 5 years of compliance experience).

QUALIFICATIONS:

• Experience working in-house or representing a publicly-traded company is preferred.

• The innate ability to collaborate with the business to drive transactions toward completion.

• Proven track record of confronting and successfully resolving complex legal, commercial, and compliance matters with significant financial and business impact.

• Demonstrated ability to recognize and weigh business and legal risks; lead strategically and advance innovative solutions.

• Strong interpersonal skills and ability to interact effectively, work diplomatically, and foster relationships with individuals at all levels including internal contacts, outside attorneys and vendors.

• Extensive knowledge of and experience with ethics & compliance programs, FCPA, OFAC, international trade sanctions, and other government laws and regulations pertaining to corporate compliance.

• Inspires trust and confidence throughout the organization; a drive to deliver quality results on time and in a highly ethical and professional manner.

• Ability to effectively manage multiple assignments simultaneously with a minimum amount of supervision.

• A team player with an open, mature and positive personality who is willing to share and communicate information effectively.

• Must have strong work ethics and a desire to consistently perform at the highest levels of competence.

• Open to periodic travel, both domestically and internationally.

• Experience in the aerospace or defense industry is preferred.

Textron Aviation Inc. must comply with U.S. export control laws and regulations. If a position requires access to sensitive information controlled under these laws and regulations, a successful applicant must be eligible to meet any requirements to access controlled information.

The above statements are intended to describe the general nature and level of work being performed by employees assigned to this job. They are not intended to be an exhaustive list of all responsibilities, duties, and skills required of personnel so classified.