Title: Director, Compliance and Ethics Organization - Commercial, CV Location: Princeton United States Job Description: Working with Us Challenging. Meaningful. Life-changing. Those aren't words that are usually associated with a job. But working at Bristol Myers Squibb is anything but usual. Here, uniquely interesting work happens every day, in every department. From optimizing a production line to the latest breakthroughs in cell therapy, this is work that transforms the lives of patients, and the careers of those who do it. You'll get the chance to grow and thrive through opportunities uncommon in scale and scope, alongside high-achieving teams. Take your career farther than you thought possible. Bristol Myers Squibb recognizes the importance of balance and flexibility in our work environment. We offer a wide variety of competitive benefits, services and programs that provide our employees with the resources to pursue their goals, both at work and in their personal lives. Read more: careers.bms.com/working-with-us. Position Summary: Reporting to the Head of US and Above Market Compliance and Ethics Organization, this role partners with senior leaders across Legal, Commercial, Medical, R&D, Global Drug Development, Regulatory, IT, Audit, Finance and HR to build and integrate one global compliance program into the US and Worldwide Commercialization Organizations. In this role, you will combine your knowledge about risk mitigation strategies, such as education and monitoring, with data analytics about executional risk to help the business make well-informed, risk-based decisions. You will help operationalize those decisions by crafting simple, clear, principle-based policies. You will educate the business about those policies - and why they exist - leveraging adult-learning techniques that aid retention. And you will use a combination of live monitoring, transactional monitoring, and data analytics to monitor the business's adherence to those policies, helping the business remediate deviations from policies by identifying and addressing the root causes of those deviations. The ideal candidate will be able to execute these tasks with a mindset that believes business functions and Compliance and Ethics are equally accountable for both company success and ethical behavior and will be recognized internally and externally as an expert in mitigating healthcare compliance risk through providing advice, drafting policy, providing education and monitoring execution of high-risk activities. Responsibilities Include: - Develop and conduct risk assessments utilizing a combination of data analytics, external and internal benchmarking, and review of enforcement trends, to proactively identify the most pressing areas of risk. - Foster trusting relationship with business leaders that enable you to learn of - and advise on - executional risk associated with new initiatives and counsel business leaders about educational initiatives, new policies or monitoring capabilities that can help mitigate risk associated with their decisions. - Analyze data regarding execution of analogous activities to better inform business leaders of the risk associated with their decisions. - Draft simple, easy to understand policies that empower the business to execute activities in an ethical and efficient way. - Develop and provide training that utilizes adult-learning principles, such as gaming, microlearning, and experiential learning, to enhance retention of compliance messages. - Establish a network of Compliance Champions in the respective business unit to integrate compliance messaging and concepts into established business training cycles. - Determine and allocate budget for training and culture initiatives for specific therapeutic areas. - Identify and leverage key stakeholders and cross-functional resources to create buy-in for training and cultural initiatives for specific therapeutic areas. - Conduct live and transactional monitoring of business activities. - Review data to identify outliers and implement preventive education or additional monitoring in response. - Perform other compliance-related activities as directed by the Global Compliance & Ethics team and/or the Head of US and Above Market Compliance. Qualifications: - Bachelor's degree. - Advanced degree (MBA, CPA, JD) appreciated but not required. - 12-15 years pharmaceutical or healthcare related compliance or legal experience, with at least 5 years experience counseling clients. - Working knowledge of relevant US pharmaceutical compliance guidelines, regulations (AKS, FCA, FDCA, HIPAA, FCPA) and PhRMA Code principles. - Familiarity with practices of and intersections between commercial sales, marketing, medical affairs, and market access organizations in the pharmaceutical industry. - Ability to work and communicate with senior level executives with an enterprise mindset focused on achieving company goals in a compliant and ethical manner. - Demonstrated ability to influence business decisions. - Comfort with using data to tell stories particularly around risk and effectiveness of risk mitigation strategies. - Entrepreneurial spirit, taking ownership over the risks and processes you identify and searching for creative solutions. - Proven experience drafting principle-based policies. - Experience utilizing adult-learning concepts in corporate educational and training materials. - Experience conducting live monitoring of speaker programs and advisory boards, and transactional monitoring of engagements with health care providers. - Commitment to a diverse and inclusive workplace. If you come across a role that intrigues you but doesn't perfectly line up with your resume, we encourage you to apply anyway. You could be one step away from work that will transform your life and career. Compensation Overview: Princeton - NJ - US: $200,430 - $242,874 The starting compensation range(s) for this role are listed above for a full-time employee (FTE) basis. Additional incentive cash and stock opportunities (based on eligibility) may be available. The starting pay rate takes into account characteristics of the job, such as required skills, where the job is performed, the employee's work schedule, job-related knowledge, and experience. Final, individual compensation will be decided based on demonstrated experience. Eligibility for specific benefits listed on our careers site may vary based on the job and location. For more on benefits, please visit https://careers.bms.com/life-at-bms/. Benefit offerings are subject to the terms and conditions of the applicable plans in effect at the time and may require enrollment. Our benefits include: - Health Coverage: Medical, pharmacy, dental, and vision care. - Wellbeing Support: Programs such as BMS Well-Being Account, BMS Living Life Better, and Employee Assistance Programs (EAP). - Financial Well-being and Protection: 401(k) plan, short- and long-term disability, life insurance, accident insurance, supplemental health insurance, business travel protection, personal liability protection, identity theft benefit, legal support, and survivor support. Work-life benefits include: Paid Time Off - US Exempt Employees: flexible time off (unlimited, with manager approval, 11 paid national holidays (not applicable to employees in Phoenix, AZ, Puerto Rico or Rayzebio employees) - Phoenix, AZ, Puerto Rico and Rayzebio Exempt, Non-Exempt, Hourly Employees: 160 hours annual paid vacation for new hires with manager approval, 11 national holidays, and 3 optional holidays Based on eligibility*, additional time off for employees may include unlimited paid sick time, up to 2 paid volunteer days per year, summer hours flexibility, leaves of absence for medical, personal, parental, caregiver, bereavement, and military needs and an annual Global Shutdown between Christmas and New Years Day. All global employees full and part-time who are actively employed at and paid directly by BMS at the end of the calendar year are eligible to take advantage of the Global Shutdown. - Eligibility Disclosure: The summer hours program is for United States (U.S.) office-based employees due to the unique nature of their work. Summer hours are generally not available for field sales and manufacturing operations and may also be limited for the capability centers. Employees in remote-by-design or lab-based roles may be eligible for summer hours, depending on the nature of their work, and should discuss eligibility with their manager. Employees covered under a collective bargaining agreement should consult that document to determine if they are eligible. Contractors, leased workers and other service providers are not eligible to participate in the program. Uniquely Interesting Work, Life-changing Careers With a single vision as inspiring as "Transforming patients' lives through science ", every BMS employee plays an integral role in work that goes far beyond ordinary. Each of us is empowered to apply our individual talents and unique perspectives in a supportive culture, promoting global participation in clinical trials, while our shared values of passion, innovation, urgency, accountability, inclusion and integrity bring out the highest potential of each of our colleagues. On-site Protocol BMS has an occupancy structure that determines where an employee is required to conduct their work. This structure includes site-essential, site-by-design, field-based and remote-by-design jobs. The occupancy type that you are assigned is determined by the nature and responsibilities of your role: Site-essential roles require 100% of shifts onsite at your assigned facility. Site-by-design roles may be eligible for a hybrid work model with at least 50% onsite at your assigned facility. For these roles, onsite presence is considered an essential job function and is critical to collaboration, innovation, productivity, and a positive Company culture. For field-based and remote-by-design roles the ability to physically travel to visit customers, patients or business partners and to attend meetings on behalf of BMS as directed is an essential job function.

• Handle and review all forms of global law enforcement inquiries • Perform blockchain tracing and preliminary investigations into unusual activities • Assist with pre-SAR filing mitigating controls and client offboarding • Participate in internal and external training programs related to AML/CFT and other subjects that may form part of the day to day work requirements • Liaise with stakeholders to facilitate knowledge sharing • Any general administration and related activities as may be required and related to the above functions in accordance with the business requirements of the Company

• Handle and review all forms of global law enforcement inquiries • Perform blockchain tracing and preliminary investigations into unusual activities • Assist with pre-SAR filing mitigating controls and client offboarding • Participate in internal and external training programs related to AML/CFT and other subjects that may form part of the day to day work requirements • Liaise with stakeholders to facilitate knowledge sharing • Any general administration and related activities as may be required and related to the above functions in accordance with the business requirements of the Company

• Design and operationalize scalable compliance frameworks, including policies, procedures, and controls aligned with federal, state, and local requirements • Build escalation workflows so complaints requiring additional oversight are quickly identified and handled consistently • Review training materials, scripts, and workflows to ensure regulatory compliance, and collaborate on enhancements where needed • Assist in developing reporting and dashboards that translate customer service data into actionable insights for leadership • Lead risk identification, assessment, and mitigation processes across business • Maintain risk registers and control frameworks • Establish escalation and reporting structures for key risks • Design risk-based monitoring and testing programs • Define KPIs and develop reporting dashboard for leadership • Identify trends and areas for improvement across compliance and risk