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Senior Manager, Ethics & Compliance – Investigations, EMEA

Req # JR - 051180 Location Warsaw, Mazovia, Poland Additional locations Newbury, Berkshire Job Category Legal Date posted 10/25/2021

This is where you save and sustain lives

At Baxter, we are deeply connected by our mission. No matter your role at Baxter, your work makes a positive impact on people around the world. You'll feel a sense of purpose throughout the organization, as we know our work improves outcomes for millions of patients.

Baxter's products and therapies are found in almost every hospital worldwide, in clinics and in the home. For over 85 years, we have pioneered significant medical innovations that transform healthcare.

Together, we create a place where we are happy, successful and inspire each other. This is where you can do your best work.

Join us at the intersection of saving and sustaining lives—where your purpose accelerates our mission.


This position is part of the Ethics and Compliance (E&C) group, within Baxter’s Legal Department.  The role’s primary responsibility will be to conduct and lead internal investigations of compliance-related issues across the EMEA (Europe, Middle East, Africa) region. You will apply your expertise conducting internal investigations, combined with your forensic accounting skills and experience analyzing financial and other internal data. In addition, you will participate in and support internal investigations and compliance assessments in other regions. You may also periodically participate in other efforts that contribute to the effective implementation and execution of Baxter’s global Ethics & Compliance Program. 

You may be based in Poland (Warsaw) or England (Newbury) and you will report to the Senior Counsel, Ethics & Compliance – Global Investigations, Assessments, and Business Development Due Diligence in Baxter’s corporate headquarters in the United States.


  • Lead or participate in internal investigations across EMEA concerning potential violations of the Company’s policies, procedures, or the law, with a particular focus on the U.S. Foreign Corrupt Practices Act (FCPA), regional and local ABAC (anti-bribery and anti-corruption) laws and regulations, antitrust/competition issues, interactions with HCPs and other government officials, conflicts of interest, and other types of corruption or fraud.

  • Participate in or support internal investigations in other regions.

  • Participate in internal compliance assessments globally (remote or in-person).

  • Apply forensic accounting (or similar financial and data analysis) skills in internal investigations and other compliance efforts globally.

  • Collaborate with and manage outside counsel and consulting firms (e.g. forensic accounting, due diligence, etc.) engaged by Baxter in the context of internal investigations.

  • Identify areas of legal or E&C risk; detect conduct inconsistent with the Company’s policies, procedures, and the law; and develop and monitor corrective action plans to address the risks/issues; and

  • Perform special assignments or projects.


  • Post-secondary (e.g. college/university) education from a recognized institution required.  A degree or certification in a field relevant to legal or regulatory compliance risks, such as Accounting, Finance, or Law preferred.

  • Minimum of 5 to 8 years of professional experience in any combination of in-house, consulting, government, and private practice, with a strong preference for at least 2 years in-house experience (or equivalent, e.g. embedded as a consultant or secondee).

  • Experience working for a multinational company or representing multinational clients preferred.  Big Four or similar experience preferred.  Healthcare experience preferred.

  • Experience conducting internal cross-border investigations, with a focus on investigations involving bribery and corruption (including the FCPA and similar local/regional laws and regulations), antitrust/competition issues, and fraud.

  • Substantive forensic accounting experience in the context of complex internal investigations.

  • Experience interviewing fact witnesses.

  • Experience identifying and analyzing legal and compliance risk, including issue-spotting across large amounts of information/data.

  • Experience interacting and building relationships with stakeholders from different countries, cultures, and at different levels of corporate seniority, including senior management.

  • Knowledge of and experience with compliance principles related to corruption/bribery, financial fraud, antitrust/competition law required.

  • Knowledge of and experience with compliance principles related to the healthcare industry, such as pharmaceutical or medical device promotion, preferred.


  • Unquestioned integrity and ethics in business and personal conduct;

  • Strong substantive skills and mature judgment.

  • A thorough understanding of key aspects of corporate compliance, including anti-corruption and antitrust/competition compliance.

  • Familiarity with the global legal and regulatory compliance framework affecting the health care industry, including its anti-corruption and antitrust/competition aspects, specific regulatory expectations, and rules governing interactions with healthcare professionals, institutions, and government officials.

  • Strong attention to detail.

  • Excellent oral communication and inter-personal skills.

  • Proven ability to collaborate and work effectively with others in addressing complex issues.

  • Demonstrated effectiveness operating in complex organizational environments and self-starter qualities that will translate well in a large matrixed organization.

  • Demonstrated ability to prioritize workload, meet deadlines, and work with minimal supervision in a team and matrixed environment.

  • Comfort with an informal and ‘open-communication’ style towards others, when appropriate.

  • Ability to travel up to 25% of the time.

  • Fluency in English; additional fluency or working proficiency in one or more languages spoken in EMEA preferred.


  • Permanent contract (after 3 months probation period + 1 year extension period),

  • Competitive salary in a diverse and multinational environment,

  • Possibilities for development on personal and professional level,

  • Package of benefits including Private medical care (Lux Med), Life Insurance, Multisport card or PPE program with very attractive conditions available for each employee after 6 months.

Reasonable Accommodations

Baxter is committed to working with and providing reasonable accommodations to individuals with disabilities. If, because of a medical condition or disability, you need a reasonable accommodation for any part of the application or interview process, please send an e-mail to [email protected] and let us know the nature of your request along with your contact information.

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