The Ethics and Compliance Function for the Vail Resorts organization reports through the Legal Department with the Company’s General Counsel also serving as the Company’s Chief Compliance Officer (CCO). There are two advisory committees to the CCO, the Risk Management Committee (RMC) and the Ethics Committee, whose members are largely senior executives of the Company. The Compliance Department is the administrative manager for both committees. A Vice President and Assistant General Counsel sits on both committees and oversees the day to day functioning of the Compliance Department. To successfully serve as the administrative manager for both committees, the Director of Ethics and Compliance must develop and maintain a thorough understanding of 1) the organization’s various companies, lines of business, and operations, worldwide, and 2) develop strong and effective working relationships with employees at all levels, throughout the organization.
As the administrative manager for the RMC, the Director of Ethics and Compliance is expected to:
- Lead an effective and regular company-wide risk identification and assessment process
- Prepare a proposed, prioritized list of compliance initiatives for each fiscal year
- Develop capital and expense budgets needed for the compliance initiatives, both for completion of the initiative and any ongoing budget needed as a result of the initiatives
- Prepare recommendations to the RMC regarding the risks and initiatives, take direction and feedback from the RMC, and incorporating same into actions and plans
- Oversee planning and implementation of initiatives working with compliance leads in operational units to ensure timely and on budget completion
- Where no compliance lead exists or for cross-operational projects, lead project teams in planning and implementing initiatives, on time and on budget
- Proactively build and lead effective and practical tracking of compliance initiatives, completed compliance plans, and ongoing compliance through the GRC tool or other appropriate means, in part through appropriate supervision and leadership to the Compliance Coordinator
As the administrative manager for the Ethics Committee, the Director of Ethics and Compliance is expected to:
- Support the Ethics Committee by 1) building an effective and innovative Ethics program that focuses on maintaining and improving a culture of integrity 2) raising and reporting on ethics issues and questions as needed
- Working with a cross-functional team, develop an effective training program (live and online) in support of the Code of Ethics & Business Conduct and a culture of integrity
- Manage and respond to ethics questions from employees and management, ensuring that issues are appropriately handled, assigned for investigation, discussed with the Ethics Committee, and resolved in compliance with feedback from the committee and internal policies and procedures
In support of the Ethics and Compliance Program as a whole, the Director of Ethics and Compliance is expected to:
- Lead & coordinate an effective mechanism for tracking of changes in the ethics & compliance environment (including to the Federal Sentencing Guidelines), assign ownership for evaluation of impact of any change, assisting as needed with interpretation, and, if changes are needed, oversee planning and implementation
- Proactively build and lead an effective and practical records management program, including electronic records, and supervise records administrator
- Create reports and/or dashboards for Senior Management and the Board of Directors concerning the Compliance and Ethics Program and various initiatives, including preparation of reports to the Audit Committee
- Working with a cross-functional team, build & maintain an effective mechanism for policy and code development, updating, distribution and training, including through ownership and refinement of the online Policy Portal
- Working with a cross-functional team, build and oversee an effective investigations policy, process and protocol for investigations ensuring investigations are handled effectively and in a timely manner by the appropriate internal or external group, issues are escalated as appropriate, and resolved
- Maintain memberships in and participate in appropriate compliance and ethics organizations, monitor developments in ethics and compliance, update team including Chief Compliance Officer, and identify and champion best practices as appropriate
Desired Skills & Experience
- JD from an ABA accredited institution
- At least six years in a combination of legal and compliance roles required, with at least some portion of the time spent in an ethics, compliance and/or corporate legal department
- Experience leading multi-functional teams with members that are not direct reports
- At least three years of strong program and project management experience including experience with change management and translation and incorporation of business needs and practical realities into systems and process
- 2 years experience in supervising and motivating other professional staff
- Active state bar admission, preferably Colorado, not required but a plus
- Proficient in MS Word, Excel, PowerPoint, and Outlook
- Proficiency in Visio a plus
- Experience with a Governance Risk Compliance software solution a plus
- Clear and concise, superior oral and written English language communication skills
- Excellent ability to communicate and influence effectively at all levels of the organization.
- Excellent judgment and the capacity to make decisions and give advice which demonstrates an understanding of the risk/rewards of each situation.
- Practical and creative problem analysis and resolution skills.
- Maturity and strong leadership skills with the capacity to articulate positions and provide direction.
- Excellent organizational skills.
- Strong executive “presence” and the ability to quickly gain the confidence of clients, enhanced by a strong sense of team and outstanding people skills.
- Flexibility of style as a member of multi-disciplinary teams and as a business person.
- Integrity and commitment to the highest ethical standards and personal values, including proven ability to maintain confidentiality
- Ability to simultaneously handle multiple assignments and prioritize work assignments as needed to meet client needs.
- Ability to see the big picture along with strong attention to detail
- A high level of passion and self motivation
Vail Resorts, Inc., through its subsidiaries, is the leading mountain resort operator in the United States. The Company’s subsidiaries operate the mountain resort properties of Vail, Beaver Creek, Breckenridge and Keystone mountain resorts in Colorado, and the Heavenly Ski Resort and Northstar-at-Tahoe Resort in the Lake Tahoe area of California and Nevada, and the Grand Teton Lodge Company in Jackson Hole, Wyoming. The Company’s subsidiary, RockResorts, a luxury resort property and hotel company, manages casually elegant properties across the United States and in the Caribbean. Vail Resorts Development Company is the real estate planning, development and construction subsidiary of Vail Resorts, Inc. Vail Resorts is a publicly held company traded on the New York Stock Exchange (NYSE: MTN). The Vail Resorts company website is www.vailresorts.com and consumer website is www.snow.com.