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Working with Group functions (Group Compliance, Group-wide Internal Audit, Group Risk, Group Legal) and Business Units (Bus / LBUs), the Group ABC Director will contribute to the development of the Group’s ABC risk management framework (including risk appetite statements / tolerances), policies (containing key controls) and underlying standards (containing control activities). The Group ABC Director plays a strategic role in addressing all aspects of bribery and corruption prevention including (but not limited to) the prevention, detection, investigation and reporting of bribery risk. The role is also responsible for development, execution and reporting of Group-wide annual risk assessments, management of significant ABC incidents, oversight of and reporting on the condition of key controls.
Principal Accountabilities :
- Implements the Group’s ABC compliance program across all markets and regions ensuring appropriate compliance due diligence, governance, and monitoring processes are established.
- Serves as an interface between RCS and BU / LBU ABC leads, building relationships and working closely with internal stakeholders
- Reviews, enhances and oversees compliance with the Group’s ABC policies and standards, Risk Appetite Statements, Tolerances, Group-wide Operational Standards (GwOS), key controls and aligned control activities.
- Proactively contributes to the enhancement of the Group’s ABC program.
- Produces Management Information (MI) and reporting for executive and board-level Risk and Audit Committees.
- Performs annual ABC Risk Assessments, prepares and delivers resulting reports to GERC and GRC.
- Assists in the management of key audits. Maintains a strong relationship with Group Internal Audit. Ensures and reports on any internal and external review / audit recommendations are fully implemented.
- Develops Bribery and Corruption prevention plans, concurrently conducting reviews and analysis of associated risks, trends and the effectiveness of bribery prevention, detection, monitoring and control activities across the Group and Business Units.
- Oversees, provides input to and reports on the effectiveness of ABC Monitoring (detection) activity
- Leads, manages, and coordinates ad-hoc ABC projects, initiatives where required.
- Responsible for the implementation and management of LBU / BU ABC assurance ‘deep dives.’
- Coordinates the gathering of ABC related management information and intelligence from within and outside the Group, to create risk assessments and drive current and future bribery prevention methodology.
- Develops and maintains a strong network of contacts with industry, regulatory and law enforcement personnel in the ABC prevention arena.
- Benchmarks the Group’s ABC compliance program to peer programs including participation in various industry network and benchmarking group.
- Prepares, reviews and if required delivers training to BU / LBUs and RCS team.
- Identifies, assesses and where appropriate, manages the implementation of market-leading technology solutions for ABC monitoring, analysis and reporting.
- Establishes and maintains close working relationships and formal lines of communication across the Group, on ABC prevention related matters
- Represents the Group in appropriate professional networks and forums.
- Supports the wider Group Risk and Compliance function as necessary.
Contact with Others :
Daily contact with business units, Group and Regional and Compliance teams.Group functions (such as GwIA, Group Risk, Group Compliance, Group Governance and Group Strategy) and various GHO committees as necessary where there is a requirement for cross functional planning, joint papers, presentations or other activities.Liaison with external agencies and organisations as and when required, including government, national and international security organisations, in order to maintain current knowledge of trends and technologies, and to add value to the planning process.Knowledge and Experience
Strong understanding of the UK Bribery Act 2010 (UKBA), the Hong Kong Prevention of Bribery Ordinance (POBO) and the US Foreign and Corrupt Practices Act 1977 (FCPA).Strong understanding of and experience in ABC prevention.Strong understanding and demonstrable experience of developing and managing a ABC risk management strategy and programme in a financial services environment.Experience in designing, operating and overseeing ABC controls frameworks.Experience with deploying data analytics to detect bribery risk.Experience in managing multi-regional or global ABC prevention initiatives across multiple jurisdictions and regulatory environments. Experience in and knowledge of Asia and Africa is desirable but not compulsory.Ability to interact at all levels of an organisation along with the ability to influence and negotiate and have good presentation and training skills.Strong report-writing and analytical skills.Highest degree of integrity and ability to deal appropriately with and handle highly sensitive information.Understanding of the legal and regulatory requirements within the jurisdictions in which the Group operates.Understanding of data privacy requirements within the jurisdictions in which the Group operates.Core Competencies Required
High degree of expertise, gravitas, and diplomacy;Ability to plan and manage projects along with excellent written and verbal communication skills, particularly when preparing Board and other high level papers;Ability to address the concerns of multiple stakeholders is essential, as is the ability to influence senior security SMEs across multiple jurisdictions, regulatory environments and / or countries;Provide relevant, appropriate and cost-effective bribery prevention plans and manage oversight activities.A high degree of foresight, engagement, experience, and an acute awareness of the cultural nuances across multiple regions is essential.Additional desirable competencies :
Familiarity with life insurance (particularly healthcare) and asset management businesses and products.Familiarity with risks associated with procurement and TPRM control frameworks.Implementation experience in risk-management, governance, policy assurance and compliance.Good understanding of information privacy and security.Commercial awareness.Ability to utilise influencing skills and the ability to work effectively across formal organisational design boundaries.Proven experience of operating as a true strategic partner through direct and indirect reporting lines.Sound understanding of strategic drivers affecting the retail financial services industry.Self-starter dedicated and committed.Able to see the “big picture”.Good analytical and problem-solving skills; excellent communication and influencing skills.Ability to develop and oversee risk and compliance related projects.Ideally strong academic record, including a good degree.A willingness to work outside the recognised ‘core hours’ and to travel across the Group as necessary.A sound understanding of the budget process and management.