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Anti-Corruption Counsel

Posted on: 17 Jun 2019 450 views
: Anti-Corruption Counsel
: Flowserve
: Law Degree
: 3

Company Overview:

Flowserve is the recognized world leader in supplying pumps, valves, seals, automation, and services to the power, oil, gas, chemical, and other industries. With more than 18,000 employees in more than 55 countries, we combine our global reach with a local presence.

Position Description:

Anti-Corruption Counsel

This position, reporting to the Director, Senior Counsel, Integrity & Compliance for the Americas, requires a dynamic, self-motivated individual who will conduct high-risk global investigations at Flowserve, assist in managing Flowserve’s Ethics Hotline, and have broad responsibilities for executing and providing legal counsel related to Flowserve’s Global Anti-Corruption program in the Americas. The preferred location for this individual will be Flowserve’s global headquarters in Irving, Texas, but other U.S. Flowserve locations will be considered.

Job Responsibilities


The Anti-Corruption Counsel will be responsible for handling internal investigations related to potential legal or regulatory violations, fraud, accounting and control issues, and/or violations of Flowserve’s Code of Business Conduct (“COBC”). The Anti-Corruption Counsel will also actively support Flowserve’s global compliance program by analyzing and advising on emerging risks, and working to improve policies, procedures, and internal controls.

Specific duties include:

  • Conducting internal investigations in the Americas region and worldwide by identifying issues, interviewing witnesses, collecting and reviewing relevant data, and drafting investigation reports summarizing factual findings and recommending remedial action as appropriate

  • Provide legal counsel related to investigations, including the application of the U.S. Foreign Corrupt Practices Act (“FCPA”) and other anti-corruption laws

  • Working cross functionally to triage, assign, track, and address concerns raised via the hotline and internally

  • Performing statistical analysis of hotline and other ethics data to identify trends and areas of compliance risk and preparing periodic reports for management

  • Managing various reporting and tracking systems using SharePoint, Excel, and EthicsPoint


The Anti-Corruption Counsel will also be responsible for assisting in the implementation, management, and continuous improvement of the Anti-Corruption program in the Americas region. This position will work closely with Global Anti-Corruption Managers worldwide. This person will be expected to formally document the results of their activities including details of procedures performed and results and will be an integral part of the decision-making process involving high risk, third party relationships, and transactions.

Specific duties include:

  • Utilize internally developed processes to perform escalated due diligence on third parties in the Americas Region, analyze the results, and communicate the results to management and the Company’s business units.

  • Actively support the Company’s third party due diligence program by providing guidance regarding potential red flags and associated remediation procedures and supporting deep-dive diligence/investigative activity

  • Verifying various aspects of a proposed channel partner relationship prior to and during the engagement, including:

  • In person or telephone verification of the intermediary’s bona fides

  • Reputational interviews

  • Reference checks

  • Verification of Business Sponsor provided facts

  • Verification of historical services provided in a relevant industry

  • Verification of relationships with other companies represented

  • Review of the business justification for proposing the third party

  • Actively support channel partner development by analyzing and providing substantive feedback on legal agreements with prospective and existing channel partners

  • Provide advice to relevant stakeholders on the interpretation and application of laws, regulations, best practices, and policies and procedures related to anti-corruption risk at Flowserve, including the application of Flowserve Global Antibribery Gift, Meal, Entertainment & Travel Policy for Government Officials.

  • Develop and implement strategies to support management in advancing an ethical and compliant culture within the Americas region by promoting employee awareness of, understanding and compliance with, the COBC

  • Assist in developing and maintaining training tools relating to the Company’s COBC to promote the importance of a strong ethical culture and awareness of Flowserve’s ethic and compliance program

  • Up to 40-50% travel may be required.

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Position Requirements:

  • Legal degree from an accredited law school and licensed to practice law in at least one U.S. jurisdiction

  • A minimum of three years of relevant professional experience, including experience in leading/conducting fraud, corruption, and ethics investigations, experience in anti-corruption compliance with an in-depth understanding of applicable anti-bribery laws and regulations, including the FCPA and U.K. Bribery Act.

  • Fluency in spoken and written Spanish is preferred, but not required

  • Possess strong and effective verbal and written communication skills, including active listening skills and skills in presenting findings and recommendations.

  • Ability to establish and maintain appropriate working relationships with co-workers, staff and external contacts, and to work effectively in a professional team environment

  • Demonstrated ability to use sound judgment and proven ability to influence without control at all levels within the organization, including the most senior levels of an organization

  • Advanced skills in collecting and analyzing complex data, analyzing and evaluating information, and drawing logical conclusions.



Job Posting/Business Card Title: Anti-Corruption Counsel

Job Posting Category: Legal/Environmental/Safety

Percentage of Approximate Travel Required: 50%

Primary Posting Location: Irving, Texas US

Employment Type: Full time

Country: United States

Auto req ID: 46207BR

Flowserve is an equal opportunity employer and makes employment decisions without regard to race, gender, disability or protected veteran status. Click here to learn more. Flowserve will also not discriminate against an applicant or employee for inquiring about, discussing or disclosing their pay or, in certain circumstances, the pay of their co-workers Click here to learn more.

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