Ethics and Compliance Manager, France and Belgium H/F, Versailles - France

Ethics & Compliance Manager, France & Belgium

The Ethics & Compliance Manager, France & Belgium, will be the primary ethics and compliance advisor for and liaison to Dentsply Sirona’s businesses in France and Belgium. He/She will be responsible for promoting a strong culture of compliance at Dentsply Sirona within the region, reviewing and evaluating compliance-related issues/concerns, supporting compliance-related processes (e.g., Third Party due diligence, training), and partnering closely with management to help employees understand and follow applicable local and international laws as well as Company policies and procedures, including the Company’s Code of Ethics and Business Conduct. Additionally, this Manager will have responsibility for compliance with the French Anti-Gift Law (Loi Encadrement des Avantages) and French Transparency Law (Loi Bertrand).

This Manager will report directly to the Senior Ethics & Compliance Director, EMEA, based in the United Kingdom, and will be part of the Global Ethics & Compliance team under the direction of the Vice President, Chief Ethics & Compliance Officer, based in the United States. This role will also dotted-line report into the General Manager for France & Belgium and will directly manage the Ethics & Compliance Specialist, France & Belgium. 

Key responsibilities

• Promotes a compliant tone at the top and in the middle; serves as an influential leader within France & Belgium.
• Drafts, implements, maintains and/or revises relevant local compliance policies, procedures, guidance and other related documents.
• Assesses ethics and compliance risks and implements localised compliance controls and other mitigating measures, as needed.
• Serves as the leader and main point of contact for compliance-related queries in France & Belgium, including interactions with Healthcare Professionals (HCPs) and distributors.
• Monitors Dentsply Sirona’s locations in France & Belgium for compliance with applicable legal & ethics requirements, Company standards, policies and procedures.
• Supports internal and external audits of Dentsply Sirona’s businesses in France & Belgium.
• Implements the Company’s Business Gifts and Entertainment Policy, providing guidance as needed on local regulations, including compliance with the French Anti-Gift law.
• Oversees on-going monitoring efforts of Dentsply Sirona’s distributor network in France & Belgium.
• Assists the Director of Global Compliance Investigations regarding compliance with the EU Whistleblower Directive in France & Belgium.
• Leads and/or assists with internal investigations as directed by the regional and/or global Ethics & Compliance and/or Legal departments.
• Ensures that compliance-related issues/concerns within the Company are appropriately evaluated, investigated, and resolved.
• Monitors new compliance-related legislation and industry trends to assess changes required in Dentsply Sirona policy.
• Represents the Company before local stakeholders, as required, on legal and compliance matters (e.g., SNITEM / beMedtech / LEEM).
• Supports the company’s Data Privacy program needs, including compliance with various local Data Privacy laws in France & Belgium, working with Legal and Global Ethics & Compliance teams.
• Advises dedicated teams on FMV aspects relating to France and Belgium

Anti-Gift Law (Loi Encadrement des Avantages) - MedTech Code

• Implements policies and procedures to ensure compliance with national, European and international anti-corruption and transparency legislation, including the French Anti-Gift Law and European MedTech Code.
• Implements monitoring and internal controls to ensure compliance with relevant policies and procedures.
• Disseminates information within the Company, raising awareness and conducting training for employees and external partners.
• Serves as primary contact with vendors/employees involved in and assisting with Anti-Gift law compliance for Dentsply Sirona in France & Belgium.
• Responsible for preparing and submitting, either directly or by supervising other internal and external resources, the necessary declarations, partnership contracts, reports, responses to questions, and requests for authorizations for Dentsply Sirona France & Belgium entities to the relevant Authorities (e.g., Conseils de l'Ordre & ARS) within the deadlines set by the regulations and following the declaration procedures.
• Advise other Dentsply Sirona entities who wish to engage in cross-border interactions with French or Belgian HCPs.

Transparency Law (Loi Bertrand)

• Responsible for ensuring the capture and transmission of all necessary information required to comply with relevant Transparency laws, including but not limited to such laws in France & Belgium.

Training

• Institutes and maintains an effective compliance communication program for the organization which includes promoting the use of the Compliance Hotline, heightened awareness of Codes of Conduct, and understanding of new and existing compliance issues and related policies and procedures.
• Develops an effective compliance training program, including appropriate introductory training for new employees as well as ongoing training for all employees and managers.
• Conducts in-person and web-based trainings for employees and Third Parties in France & Belgium.
• Implements a system for validating skills acquired during Compliance training courses.

Others

• Prepares status reports on projects and programs for Compliance and Ethics Committee meetings and Audit Committee presentations.
• Participates in process improvement projects as necessary.
• Provides reports on a regular basis on the Compliance programs initiated.
• Participates in compliance-related legal and data privacy processes and projects as necessary.
• Implementation and follow up of the GDPR requirements for the countries of responsibility

Requirements and Qualifications

• A Bachelor’s degree or higher (legal certificate or degree preferred).
• 5+ years’ experience within a regulated industry in a multinational environment.
• Healthcare/Medical Device industry experience strongly preferred.

• Knowledge of and experience advising on laws and regulations in France & Belgium related to: anti-bribery and anti-corruption, Loi Encadrement des Avantages (Anti-Gift), interactions with Healthcare Professionals (public and private), Loi Bertrand (Transparency), anti-competition, data privacy (GDPR), and international trade.
• Familiar with operational, compliance, financial, and HR procedures and regulations.
• Demonstrated ability to operate independently and work as part of a team, able to build relationships across and outside the department.
• Strong written, verbal and presentation skills, with the ability to express complex information and processes in a clear, concise and compelling manner.
• Organized and detail oriented, with a high degree of ethics, integrity and professionalism.
• Solid analytical skills with the ability to respond to complex challenges with innovative solutions.
• Able to seek buy-in from management on compliance requirements.
• Fluent in English and French.
• Ability to travel as required.