Description:

Job Type (exemption status): Exempt position - Please see related compensation & benefits details below

Salary Range: 182,000.00-246,000.00

Company Description
At Western Digital, our vision is to power global innovation and push the boundaries of technology to make what you thought was once impossible, possible.

At our core, Western Digital is a company of problem solvers. People achieve extraordinary things given the right technology. For decades, we’ve been doing just that. Our technology helped people put a man on the moon.

We are a key partner to some of the largest and highest growth organizations in the world. From energizing the most competitive gaming platforms, to enabling systems to make cities safer and cars smarter and more connected, to powering the data centers behind many of the world’s biggest companies and public cloud, Western Digital is fueling a brighter, smarter future.

Binge-watch any shows, use social media or shop online lately? You’ll find Western Digital supporting the storage infrastructure behind many of these platforms. And, that flash memory card that captures and preserves your most precious moments? That’s us, too.

We offer an expansive portfolio of technologies, storage devices and platforms for business and consumers alike. Our data-centric solutions are comprised of the Western Digital®, G-Technology™, SanDisk® and WD® brands.

Today’s exceptional challenges require your unique skills. It’s You & Western Digital. Together, we’re the next BIG thing in data.

Job Description
Overview:
Western Digital®
We deliver the possibilities of data. YOU define what’s possible.

The Senior Director, Internal Investigations and ABAC is responsible for implementing and overseeing the Company’s antibribery and anti-corruption (ABAC) program while managing the Company’s Global Ethics Helpline, directing a team of investigators who conduct internal investigations globally, and ensuring that ethics and compliance concerns raised by employees, suppliers, vendors and other third-parties anywhere in the world are promptly and thoroughly investigated and appropriately redressed. The Senior Director, Internal Investigations and ABAC reports to the Senior Vice President, Chief Compliance Officer.

Essential Duties and Responsibilities:
  • Lead, manage and develop two distinct global teams within Company’s ethics and compliance function, one a team of skilled internal investigators and the other comprising ABAC and enhanced due diligence specialists.
  • Oversee Company’s global anti-corruption program, including driving the implementation of third-party risk management controls within procurement and sales business processes, managing risk-based diligence process for third parties and advising the Company on distributor channel compliance solutions.
  • Develop, advise on and drive compliance with effective anti-corruption policies and procedures governing conflicts of interest, gifts & entertainment, discounts and incentive programs and market development funds.
  • Oversee Company’s Ethics Helpline, which includes ensuring Helpline is operating and effective at all sites globally and partnering with Human Resources and other investigative functions across the Company to ensure timely responses to all concerns raised on the Helpline and other reporting channels.
  • Lead internal investigations around the globe, including overseeing and working with team of internal investigators to develop investigation plans particular to each ethics and compliance concern, collect and review documents, interview witnesses, and reach and document findings.
  • Advise the Company on internal investigations and due diligence findings, and appropriate remedial action to be taken based on the findings.
  • Provide periodic updates to the Company’s management team concerning ethics and compliance concerns, and data and trends regarding compliance culture.
  • Prepare quarterly Ethics and Compliance data for reporting to Board of Directors, Audit Committee, company leadership, and business units.
  • Prepare information for and facilitate periodic investigations review process with Company’s external auditors.
  • Develop and deliver effective skills-based training for investigators across the Company to enhance interviewing and report writing skills, among other investigation fundamentals.
  • Ensure all Company investigators understand and follow protocol for identifying and recording root cause(s), discipline, and other remediation for each concern that is substantiated following an investigation.
  • Oversee training and communication initiatives related to Western Digital’s “Speak Up” culture and non-retaliation policy, including quarterly all-employee communications, annual online compliance training, and post-investigation leadership communications as needed.
  • Analyze ethics and compliance investigations data (including root cause) to determine relevant trends and areas of compliance risk, and recommend effective modes of training, communication, and controls enhancements to address same.
  • Develop robust, enterprise-wide set of post-investigation discipline and remediation data to ensure organizational justice through horizontal and vertical consistency of outcomes, and to assist Company in making post-investigation discipline and remediation decisions.
  • Oversee administration and escalation of root cause reports and remediation plans to ensure cross-functional follow-through on remediation recommendations for preventing future misconduct or other issues.

Qualifications
Required:
  • JD degree with a strong academic record
  • Minimum of 8 – 12 years of legal experience with emphasis on internal investigations, white collar litigation, and/or ethics & compliance
  • Understanding of compliance laws including the Foreign Corrupt Practices Act, U.K. Bribery Act, global Competition laws, and data privacy
  • Experience administering a corporate ABAC compliance program and familiarity with distribution channel sales models is highly desirable
  • Experience in a company selling to distribution channels is a plus
  • Experience investigating financial fraud, procurement improprieties, and employee misconduct preferred; experience as Assistant U.S. Attorney is highly desirable
  • Experience in conducting and managing document reviews and electronic discovery
  • Demonstrated ability to exercise independent judgment, to be proactive and manage multiple projects simultaneously, and to focus on critical priorities
  • Strong work ethic and ability to produce high quality work under deadline pressures

Skills:
  • Excellent oral and written communication skills and executive presence, including the ability to deliver crisp, clear and concise executive presentations
  • Excellent organizational and analytical skills and a demonstrated record of cross-functional collaboration; understands and effectively balances internal and external stakeholder requirements, expectations and needs
  • Strategic mindset; articulates credible visions of new possibilities that will create sustainable value to the Ethics and Compliance investigations function
  • Maneuvers comfortably through complex policy, process and people-related organizational dynamics; is sensitive to how people and organizations function and plans approach accordingly
  • Demonstrated ability to persuade and to inspire trust and confidence through effective communication and interpersonal skills; uses compelling arguments and positions them appropriately to gain the support and commitment of others
  • Relates comfortably and works effectively with people across levels, functions, culture and geography; acts with diplomacy and tact to build constructive relationships
  • Is sensitive to cultural norms, expectations and ways of communicating
  • Regular and, at times, unpredictable travel, including regular international travel, is required

Additional Information
Western Digital is committed to providing equal opportunities to all applicants and employees and will not discriminate based on their race, color, ancestry, religion (including religious dress and grooming standards), sex (including pregnancy, childbirth or related medical conditions, breastfeeding or related medical conditions), gender (including a person’s gender identity, gender expression, and gender-related appearance and behavior, whether or not stereotypically associated with the person’s assigned sex at birth), age, national origin, sexual orientation, medical condition, marital status (including domestic partnership status), physical disability, mental disability, medical condition, genetic information, protected medical and family care leave, Civil Air Patrol status, military and veteran status, or other legally protected characteristics. We also prohibit harassment of any individual on any of the characteristics listed above. Our non-discrimination policy applies to all aspects of employment. We comply with the laws and regulations set forth in the Equal Employment Opportunity is the Law poster.

Western Digital thrives on the power and potential of diversity. As a global company, we believe the most effective way to embrace the diversity of our customers and communities is to mirror it from within. We believe the fusion of various perspectives results in the best outcomes for our employees, our company, our customers, and the world around us. We are committed to an inclusive environment where every individual can thrive through a sense of belonging, respect and contribution.

Western Digital is committed to offering opportunities to applicants with disabilities and ensuring all candidates can successfully navigate our careers website and our hiring process. Please contact us at staffingsupport@wdc.com to advise us of your accommodation request. In your email, please include a description of the specific accommodation you are requesting as well as the job title and requisition number of the position for which you are applying.

Compensation & Benefits Details
  • An employee’s pay position within the salary range may be based on several factors including but not limited to (1) relevant education; qualifications; certifications; and experience; (2) skills, ability, knowledge of the job; (3) performance, contribution and results; (4) geographic location; (5) shift; (6) internal and external equity; and (7) business and organizational needs.
  • The salary range is what we believe to be the range of possible compensation for this role at the time of this posting. We may ultimately pay more or less than the posted range and this range is only applicable for jobs to be performed in Colorado or remote jobs that can be performed in Colorado. This range may be modified in the future.
  • You will be eligible to participate in Western Digital’s Short-Term Incentive (STI) Plan, which provides incentive awards based on Company and individual performance. Depending on your role and your performance, you may be eligible to participate in our annual Long-Term Incentive (LTI) program, which consists of restricted stock units (RSUs) or cash equivalents, pursuant to the terms of the LTI plan. Please note that not all roles are eligible to participate in the LTI program, and not all roles are eligible for equity under the LTI plan. RSU awards are also available to eligible new hires, subject to Western Digital’s Standard Terms and Conditions for Restricted Stock Unit Awards.
  • We offer a comprehensive package of benefits including paid vacation time; paid sick leave; medical/dental/vision insurance; life, accident and disability insurance; tax-advantaged flexible spending and health savings accounts; employee assistance program; other voluntary benefit programs such as supplemental life and AD&D, legal plan, pet insurance, critical illness, accident and hospital indemnity; tuition reimbursement; transit; the Virgin Pulse Program; the Applause Program, employee stock purchase plan, and the Western Digital Savings 401(k) Plan.
  • Note: No amount of pay is considered to be wages or compensation until such amount is earned, vested, and determinable. The amount and availability of any bonus, commission, benefits, or any other form of compensation and benefits that are allocable to a particular employee remains in the Company's sole discretion unless and until paid and may be modified at the Company’s sole discretion, consistent with the law.