Posted on: July 23, 2021 | Job#: 370676

Counsel, Global Integrity and Compliance

Full-time | Two Folsom, San Francisco, CA, US 94105


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About Gap Inc.

Our brands bridge the gaps we see in the world. Old Navy democratizes style to ensure everyone has access to quality fashion at every price point. Athleta unleashes the potential of every woman, regardless of body size, age or ethnicity. Banana Republic believes in sustainable luxury for all. And Gap inspires the world to bring individuality to modern, responsibly made essentials.     

This simple idea—that we all deserve to belong, and on our own terms—is core to who we are as a company and how we make decisions. Our team is made up of thousands of people across the globe who take risks, think big, and do good for our customers, communities, and the planet. Ready to  learn fast, create with audacity and lead boldly? Join our team.

About the role

We are looking for an experienced Counsel, Global Integrity and Compliance to join our team – which is focused on enhancing and promoting Gap Inc.’s commitment to operate with integrity and on preventing, detecting and responding to unethical or illegal conduct. You will be responsible for overseeing our global Anti-Corruption Program, designing and implementing compliance risk mitigation plans, and enforcing our Code of Business Conduct (COBC), including participating in the investigation of alleged compliance concerns.
Oversee the global Anti-Corruption Program, with support from compliance directors in our international markets – ensure the program is updated based on developments in global laws and external trends in the marketplace, includes conducting benchmarking and maintaining a pulse of DOJ, SEC and other global government agencies’ expectations and guidelines

What you'll do

  • Oversee the anti-corruption due diligence process:
  • Assess and evolve our third-party compliance program and due diligence processes as necessary to ensure appropriate identification and mitigation of risk;
  • Review escalated due diligence reports for key international markets (e.g., China, Mexico and Italy) and advise colleagues and business partners on appropriate next steps;
  • Ensure appropriate training for the process is delivered to target audiences; - Conduct periodic review and audits of the process, including developing and implementing action plans for process improvements as necessary
  • Serve as subject matter expert on US and international anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, to advise the business on new or evolving initiatives and inform the COBC Program on communications and training, includes helping develop content for training or communications to target audiences, and developing policy changes related to changes in laws or best practices; also includes advising on challenges to standard anti-corruption contractual provisions, as needed
  • Demonstrated ability to understand and apply OFAC and other sanctions regulations to complex transactions, products and services. In depth understanding of OFAC's reporting requirements with an ability to manage preparation and submission of required regulatory reports. Proven experience working with senior management and influencing different stakeholders in a dynamic environment.
  • Evaluate the effectiveness of and improve upon controls in place to prevent or detect unethical/illegal conduct - Prepare periodic reports on the program’s progress for the Audit & Finance Committee of the Board of Directors and the Global Integrity Committee
  • Lead COBC investigations – develop investigation strategy, lead investigators, conduct interviews, as needed, and ensure proper corrective action and documentation –
  • Assist with COBC Compliance Audits – conducting audits as directed by Global Integrity

Who you are

  • JD Required; Licensed to practice law in the US with 7+ years of experience
  • Proven track record of success partnering with business leaders on providing strategic guidance; Practical mindset with ability to balance legal risk with business impact
  • Prior relevant work experience managing a corporate compliance program
  • Experience working with international markets - Expert in anti-corruption laws, including FCPA and UK Bribery Act
  • Well-versed in legal guidelines (e.g., the US Federal Sentencing Guidelines) and corporate governance best practices
  • Certified compliance professional is a plus
  • Franchise and privacy-related compliance experience a plus

Notice to applicants in San Francisco: Gap Inc. and its related brands will consider for employment, qualified applicants with criminal histories in a manner consistent with the San Francisco Fair Chance Ordinance. The Fair Chance Ordinance is provided here: English Spanish Chinese Tagalog

Benefits at Gap Inc.

  • Merchandise discount for our brands: 50% off regular-priced merchandise at Old Navy, Gap, Banana Republic and Athleta, and 30% off at Outlet for all employees.
  • One of the most competitive Paid Time Off plans in the industry.*
  • Employees can take up to five “on the clock” hours each month to volunteer at a charity of their choice.*
  • Extensive 401(k) plan with company matching for contributions up to four percent of an employee’s base pay.*
  • Employee stock purchase plan.*
  • Medical, dental, vision and life insurance.*
  • See more of the benefits we offer.

*For eligible employees

Gap Inc. is an equal-opportunity employer and is committed to providing a workplace free from harassment and discrimination. We are committed to recruiting, hiring, training and promoting qualified people of all backgrounds, and make all employment decisions without regard to any protected status. We have received numerous awards for our long-held commitment to equality and will continue to foster a diverse and inclusive environment of belonging. This year, we’ve been named as one of the Best Places to Work by the Humans Rights Campaign for the fourteenth consecutive year and have been included in the 2019 Bloomberg Gender-Equality Index for the second year in a row.


We’ll send you to our application portal to get started.

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