Sr. Legal Counsel and Country Compliance Officer

Job Title:

Sr. Legal Counsel and Country Compliance Officer - India

Department

G&A, General Management – Other

Reports to (Name & Job Title):

Head of Legal & Compliance – ISEA

Major Accountabilities   (Describe the main results of the job to be achieved)

Compliance Environment and Practice (India Commercial entity and AGS-Bangalore)

Establish compliance standards and compliance frameworks based on internal policies (e.g., Code of Conduct, The Lens and SOPs) and local law and regulations Collaborate with franchise to conduct compliance reviews and approvals for various activities, including (a) GTM models (b) Marketing strategies (c) pricing and discounts/ rebate aspects, (d) promotional practices (e) product launches etc. Collaborate with Franchise for implementing/enforcing regulations on pharma /MedTech marketing practices. C o n du c t on-boa r ding a s w e ll as c o n tin u o u s trai n i n g on co m plia nc e s t a nd a r ds, busi ne ss pra c tic e s and current developments. Participate in the meetings of Industry association (where applicable) Lead and conduct compliance monitoring and risk self-assessments Support investigations of alleged misconduct as may be assigned from time to time Develop processes to self-monitor the compliance program Actively engage in Global Compliance initiatives Actively follow trends in the market and regulatory environment as well as in business practices and advise relevant stakeholders on compliance related aspects

Promote Compliance Standards (India Commercial entity and AGS-Bangalore)

Champion speak-up, transparency and a culture of integrity throughout the organization Foster ethical behavior by promoting the same through various initiatives and roadshows Actively engage in Global, regional Compliance initiatives and be an active member of Alcon’s compliance community

Enforce Compliance Standards (India Commercial entity and AGS-Bangalore)

Conduct compliance risk assessments including supporting third-party due diligence/audits (where applicable) Regularly update on the status of the compliance program Support investigations of alleged misconduct Support in proposing and implementing sanctions resulting from employees’ misconduct

Legal Support (India Commercial entity and AGS-Bangalore)

Provide legal advice for all matters (primarily for AGS and other relevant matters of franchise) requiring legal and compliance support are handled effectively; provide recommendations and advice enabling AGS Bangalore/franchise to appreciate its contractual and statutory obligations; Support for entire contract management of AGS. manage disputes and litigation independently and evaluate projects with a robust risk assessment, driving compliance awareness and effectiveness, especially on new verticals getting implemented in Bangalore; is responsible for providing strategic and legal advice in (and for ensuring the legal sufficiency of) all matters that are relevant to day-to-day operation of AGS Bangalore. In addition, he/she is responsible for establishing, promoting, and reinforcing compliance standards, aligned with local laws and regulations and company-wide compliance policies in close collaboration with other member of India Legal Team;

Key Performance Indicators (Indicate how performance will be measured: indicators, activities…)

All compliance standards established and aligned with applicable laws, local regulations/standards and company-wide policies  Local processes and SOPs covering non-promotional material/content, interactions with HCPs / patients, grants, fair competition, conflict of interest and anti-bribery, established and monitored All associates trained on Code of Conduct, the Lens and other relevant policies Internal investigation processes implemented and communicated to all associates  Compliance-related risk assessment conducted.  Implementation of new processes and trainings rolled-out by global compliance.

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