Compliance Sr Consultant

Field Compliance Officer, Nordics

Position Title: Field Compliance Officer, Nordics

Reporting to : EMEA Compliance Director

Territory of this Role: Denmark, Finland, Norway and Sweden, and Estonia

Location : Oslo, Norway.

Travel Requirements : Occasional travel will be required to support country/regional initiatives

Language Requirements : fluent in Norwegian and English, written and spoken.

Line Management responsibilities : None.

The Field Compliance Officer (FCO), Nordics is a member of the Global, Risk Ethics & Compliance Field Compliance Officer organization and represents the Ethics & Compliance Program across multiple countries and business segments (“the Territory”), assigned on the basis of inherent risk and CBRE’s scope of operations and services therein.

The FCO is independent of the business, reporting through the Global, Risk, Ethics & Compliance organization to the EMEA Compliance Director, and ultimately accountable to the Global Chief Ethics & Compliance Officer. The establishment of the FCO organization is part of the Global Risk, Ethics & Compliance transformation and reorganization process, which commenced in 2023. The compliance reorganization process involves transitioning previous Country Compliance Officer (“CCO”) roles – with responsibility for a single country and segment – to the FCO role which works across countries and segments.

Where FCOs are making internal transitions from CCO positions, the realization of duties presented in this job description will depend on the successful transfer of current CCO responsibilities per the Ethics & Compliance Transition plan, and additional professional and administrative support.

Role Purpose

The FCO role exists to foster and strengthen "Tone at the Top" with country and business leadership, and to support the development of "Tone in the Middle", empowering managers to lead on Ethics & Compliance risks and in alignment with CBRE’s culture and RISE values.

Acting as an independent business partner across CBRE’s Advisory Services and Building Operations & Experience business segments in the assigned Territory, the FCO will proactively support and advise Management and staff to ensure the business fulfils its duty to comply with outside regulatory and legal requirements, and with internal policies and standards.

The FCO provides independent feedback to the EMEA Compliance Director and Global Deputy Chief Compliance Officer on the operation of CBRE’s global Ethics & Compliance program in the Territory, broken down by region and business segment. The FCO is responsible for identifying material gaps in the local Ethics & Compliance program and prompting appropriate action to these gaps by working with local management and the global Ethics & Compliance Centers of Excellence as needed.

K e y Responsibilities

The Field Compliance Officer:

1. Acts as the key point of contact between CBRE’s business leaders in the Territory, and the Global Risk, Ethics & Compliance Team. The FCO has access to the various subject matter expertise, tools, technologies and procedures within the Global Risk, Ethics & Compliance Centers of Excellence, and will make these available to the business in order to proactively and pragmatically address current and emerging compliance issues and risks in the business.

2. Works with local Management and staff to help the business identify compliance risks. The FCO advises business leadership on proposed mitigation actions and recommends potential mitigation strategies and actions where necessary.

3. Ensures the required CBRE Global Risk, Ethics & Compliance program deliverables are implemented across the Territory and executed in a manner consistent with CBRE standards and corporate requirements. Including, but not limited to:

Periodic Ethics & Compliance Risk Assessment.

Annual Standards of Business Conduct Certifications and follow up of employee Disclosures.

Facilitate governance and management of CBRE global corporate policies in the Territory (incl. approvals of local policy addendums to global policies) in line with CBRE’s global policy governance policy and procedures. Ensure up-to-date versions of applicable global policies are available to all staff in the Territory via CBRE’s corporate platforms.

Train and inform the business on specific local risks or on new global Ethics & Compliance initiatives, as identified through the Risk Assessment. In cooperation with CBRE’s Global Learning & Development department, ensure local Management is aware of all global Ethics & Compliance mandatory training requirements, and that Management is tracking progress against completion targets and following-up incomplete training appropriately.

Facilitate the establishment of appropriate risk-based monitoring, auditing and/or other initiatives in the Territory, including - in cooperation with CBRE’s Financial Integrity Team - CBRE’s anti-corruption, anti-money laundering and counter-terrorist financing (“AML/CFT”) and sanction compliance program. These activities include: -Securing leadership engagement.

• Facilitating the update and implementation of the appropriate company policies and procedures
• Supporting the provision of adequate training to key employees. Providing timely compliance advice to the business.
• Supporting Management in understanding and resolving monitoring and audit findings and red flags within the territory.
• Escalate, as required by global policy, and follow up with the business of any red flags and/or exceptions identified, develop appropriate remedial actions.

Provide logistical, informational and practical support where requested for internal investigations carried out by the Ethics & Compliance Trust Team in the Territory. Act as a key point of contact, coordinate with support functions, and provide feedback to business leadership as required. Monitor and provide feedback to business leadership and to Global Risk, Ethics & Compliance on remediation actions arising from Trust Team investigations.

4. Empower business leaders and Management teams across the Territory to promote the RISE values and foster a positive Speak-Up culture. This includes the proactive roll-out of resources such as CBRE’s “Do the Right Thing” Speak-up materials, and ensuring broad awareness of the Ethics Helpline and Non-Retaliation Policy across the Territory.

5. Provide a visible and trusted contact point for the global Risk, Ethics & Compliance program in the Territory for all staff. Support the recruitment and coordination of the global Ethics & Compliance Ambassador network in the Territory, providing a source of guidance to Ambassadors, and receiving and escalating concerns as needed.

6. Regularly attend and contribute to management meetings and leadership and support function forums and events across the business in the assigned Territory. Provide a visible Ethics & Compliance presence in these forums and offer the global Ethics & Compliance perspective as appropriate.

7. Establish and chair periodic (at minimum, six monthly) Compliance Review Boards in each relevant business to ensure documented and consistent reporting of compliance metrics, and an independent record of Management actions taken as a result. The output of this process will be shared with global Risk, Ethics & Compliance leadership and will be aggregated as needed for regional / global reporting purposes. Compliance Review Board agendas will include (but is not limited to):

Analysis and presentation of Territory Ethics & Compliance dashboard data Update of Compliance program data and Compliance metrics and KPIs to business leadership

Overview of Ethics & Compliance Ambassador program health and activity in the Territory

Discussion of potential upcoming regulatory risks and challenges for the business in the Territory

Reviewing business progress with action plans to address the Risk Assessment and open remediation actions.

Presenting the FCO’s assessment of current status of the Ethics & Compliance program in the Territory, along with recommendations for further actions and resources needed to enhance the local program.

8. Enable business leadership to demonstrate its commitment to compliance, by making them aware of the responsibility to adequately resource key compliance processes and risks in-country.

9. Coordinate with Support Function leads in Territory to confirm efficient delivery of the Ethics & Compliance program with no duplication / cross-over, assisting Support Functions to demonstrate their commitment to Compliance. Key Support Function partners are Legal, People, Finance, Controllership and Supply Chain.

10.Represent the needs and concerns of Management and Support Functions in the Territory back to the global Compliance Program (including assistance with specific regulatory needs, emerging risks and issues, or unclear and/or inefficient compliance processes or workflows).

Special Projects

As needed, the FCO will support additional corporate or global Ethics & Compliance projects in the Territory. In particular, the FCO will support relevant M&A Due Diligence and Integration processes in the Territory:

Working within CBRE’s global M&A project structure, support the execution of Compliance Due Diligence processes.

Review questionnaires and data room materials, and carry out analysis of M&A Targets within Territory. Interview Sellers and key management of M&A Targets as appropriate.

Lead on the production of an Ethics & Compliance Due Diligence Report, identifying key risks, providing recommendations, and drafting a high-level integration plan (including budget) for submission to the Chief Ethics & Compliance Officer.

Contribute to the detailed development of M&A integration plans in coordination with Support Function leads in the Territory.

Monitor and contribute to integration processes, post-acquisition, to ensure compliance risks are tracked and addressed by the business

Assist and Collaborate as Required

The FCO will assist and collaborate with stakeholders as required in the following areas:

Work with global COEs and local market contacts when potential new regulatory requirements are identified. Including requesting Legal Team support in obtaining guidance on regulatory and business licensing changes in the Territory, monitor progress and keep business stakeholders appraised of change management processes related to relevant regulatory changes.

Support the business with th assessment of potential personal Conflicts of Interest.

Provide / facilitate guidance to the business on completion of client RFP questionnaires and other compliance related enquiries, on an exceptions basis where standard responses are not sufficient to answer client questions. Assist with Data Privacy risks and issues that arise, ensuring the Ethics & Compliance Global Data Privacy Office and Legal Team are engaged as required.

Contribute segment and/or subject matter expertise to the Global Ethics Program Office Team and the Global Financial Integrity Team, collaborating with colleagues and supporting the continuous improvement of CBRE’s global Ethics & Compliance team.

Proactively contribute to the development of other global Ethics & Compliance Team members.

Person Specification/Requirements

Multiple years of proven experience in an international compliance role.

Academic and/or professional qualification in a related field.

Track-record of success in managing multiple stakeholders and successfully delivering compliance initiatives in a complex global business.

The ability to work well under pressure, and to thrive in an environment with high levels of change, innovation and uncertainty.

Ability to motivate and negotiate effectively with key employees, top management, and client groups to take desired action. Has a proactive and pragmatic approach to resolving routine and non-routine occurrences.

Effective communication skills (written and verbal) and experience in connecting to a diverse audience at multiple levels of seniority through various formats, i.e. policies, procedures, leading meetings, face to face dialogue etc. Experienced and impactful presenter (both in-person and virtual) to deliver compliance messaging and training content tailored to the business.

Strong analytical and organizational skills, sound problem identification/solving skills.

Requires in-depth knowledge of financial terms, principles and compliance. Ability to review complex financial/business analysis and reports, Expert level knowledge of global real estate accounting practices.

Academic Background

Four-year and advanced degrees with a preference in Law, Accounting, Finance, Business Administration, or related field plus a minimum of 5 years professional level compliance experience.

Professional Certification in Compliance, Internal Audit, Anti-corruption / Anti-fraud or related field preferred. For questions: Brian Casimir Ethics and Compliance Director [email protected]