Director – Conduct Office

Serves as a subject matter expert and leads a team of analysts responsible for the implementation and administration of Vanguard's Code of Ethical Conduct and associated compliance processes. Drives the direction and develops policies and procedures to ensure compliance with regulatory requirements and ethical standards. Contributes to the development and oversees the implementation of monitoring programs and procedures to ensure regulatory compliance and protect shareholder assets. Serves as a trusted advisor to the business and partners with leaders to deliver solutions to complex and elevated issues.

Director Conduct Office

25 Walbrook, London

Director, Regulatory Engagement and Conduct Office

Vanguard’s purpose is to take a stand for all investors, to treat them fairly and to give them the best chance of investment success.  With a rapidly growing business in Europe and against the backdrop of ever evolving regulatory requirements, we are seeking a highly experienced regulatory compliance professional to lead our European Conduct office, drive and own our Conduct Risk Framework, manage the Individual Accountability Regimes in Europe SMCR at Vanguard (currently SMCR in the UK and IAF in Ireland), together with oversight of Vanguard’s Code of Ethical Conduct.

Summary of Role

This position will report directly into the Global Head of Ethics and Conduct Compliance, and complement an existing team of expert and diverse compliance professionals supporting our Global Conduct Team, as well as our European business.  

An in-depth understanding of the FCA’s regulatory requirements and regulatory posture is required to guide proactive, open and transparent engagement, to ensure the SMCR regime is implemented and administered as required, and interpretation of FCA’s requirements appropriate.

Vanguard’s Code of Ethical Conduct is central to our ways of working.  Ensuring that the policies underpinning the Code are appropriately understood and embedded, through proactive, thoughtful and innovative programmes of engagement and training is critical.

Close collaboration and engagement with Vanguard’s Human Resources function is required, as such the role holder will lead on broader Compliance engagement with HR, as required, including providing technical advice on regulations relating to remuneration.

The role holder will work closely with the Global Head of Ethics and Conduct Compliance, Chief Compliance Officer, Europe and other stakeholders on the thoughtful use of the Conduct Panel which is responsible for considering conduct matters, including UK conduct rule and Ireland conduct standard breaches. 

Our second line of defense Compliance team are trusted advisers, commercially minded and proactive in their understanding of Vanguard’s mission, vison & strategy, and objectives. The role is necessarily broad, fast paced and demanding, and should prove a fulfilling role for the right candidate.

The successful candidate will collaborate and support colleagues in all relevant geographies, particularly within Compliance, Risk, the wider Office of the General Counsel (Legal, Investment Stewardship and Public Policy).   

Core Responsibilities:

• Acts as a senior culture champion and the voice of good conduct at Vanguard Europe. Alongside other senior managers, champions a business led conduct culture and a compliance mindset within Vanguard Europe.
• Drives the process to evidence that good conduct is fully embedded throughout Vanguard Europe, including implementing and owning our Conduct Risk Framework, aligned with regulatory expectation and Vanguard’s mission and values. Provides leadership, advice, guidance and support, in respect of conduct items, for business changes and strategic initiatives.
• Builds a conduct programme that engages all crew with a sense of personal accountability as stewards of the duty of care we owe customers, including ownership of the training programme in respect of conduct risk items.
• Receives, reviews and analyses management information in relation to the assessment of conduct risk including providing support to business lines and Senior Executives. Leads the definition and monitoring of Conduct Key Performance Indicators, supports the Conduct Risk Assessment process and undertakes, or sponsors thematic reviews of key areas of concern.
• Responsible for oversight and deliberation (including through the Conduct Panel) of crew conduct issues, including by way of example:  conduct rule breaches, non-financial misconduct, Code breaches policy breaches, incidents and complaints and near-misses relating to crew activity, and conflicts of interest, as appropriate.
• Presentation and engagement with Senior Management, Boards and relevant Committees in relation to conduct at Vanguard Europe, including reporting on the Conduct Risk Framework, risk metrics, conduct management information, trends and trajectories.
• Provide technical regulatory advice and interpretation of regulatory expectations to the wider Compliance team and management.
• Management of the SMCR regime at Vanguard, ensuring it is appropriately embedded and managed across the UK business, Senior Manager, Certified and Conduct Rule populations.  
• Management of the IAF regime at Vanguard, ensuring it is appropriately embedded and managed across the Irish business and impacted crew.
• Management of the Code of Ethical Conduct for Vanguard Europe, providing risk-based monitoring, oversight and reporting.
• Providing advice and guidance, and operating appropriate governance with HR, on Remuneration considerations.
• Leading policy governance for Vanguard Europe, including good policy management practices within the Europe Compliance function.
• Supporting the Chief Compliance Officer, Europe, meet local governance reporting requirements.
• Maintain expert knowledge and awareness of the investment industry. Stays abreast of current market, regulatory and industry relevant news. Serve as an expert, trusted advisor and provide guidance to the team on compliance related issues.
• Participate in special projects and performs other duties as assigned.
• Line management responsibilities

What it takes

• Minimum ten years related experience, including regulatory supervisory experience or regulatory relationship management experience.
• Experienced leader with proven track records of developing and leading effective and efficient teams, and excellent communication skills, confident engaging with senior leaders.
• A curious mindset, commercial, tenacious, lateral thinking, proactive and relationship orientated.
• Ability to assess business risk priorities associated with compliance risks and ability to make risk-based decisions, using sound judgement to escalate appropriately.
• Confidence in influencing decisions and engaging with cross functional stakeholders at all levels and across geographies.
• Strong regulatory technical knowledge of FCA and European requirements, including SMCR and Remuneration.
  • Understanding and awareness of the importance of ethical standards in the investment management industry, with an ability to generate awareness, understanding and engagement on this important responsibility.
  • Maintain a deep knowledge and awareness of the investment industry. Stay abreast of current market, regulatory and industry relevant news, and represent Vanguard at industry forums.

• Undergraduate degree or equivalent combination of training and experience.  Graduate degree preferred.

Special Factors

• Vanguard is not offering visa sponsorship for this position.
• This position is hybrid and would require you to work in the office location Tuesday, Wednesday and Thursday.

About Vanguard

Vanguard is an investment company unlike any other. It was founded by Jack Bogle in the US in 1975 on a simple but revolutionary idea: that an investment company should manage its funds solely in the interests of its clients. Jack helped bring investing to the masses with the index fund. Index funds do not pick individual shares or bonds to beat the market. They supervise the performance of the entire market. Or as Jack put it, "Don't look for the needle in the haystack. Just buy the haystack!”. We have stood for low-cost, uncomplicated investing ever since. Over the last 45 years people have come round to our way of thinking and more than 30 million investors worldwide now trust us with their money.

Inclusion Statement

Vanguard’s continued dedication to diversity and inclusion is firmly rooted in our culture. Every decision we make to best serve our clients, crew (internally employees are referred to as crew), and communities is guided by one simple statement: “Do the right thing.”

We believe that a critical aspect of doing the right thing requires building diverse, inclusive, and highly effective teams of individuals who are as unique as the clients they serve. We empower our crew to contribute their distinct strengths to achieving Vanguard’s core purpose through our values.

When all crew members feel valued and included, our ability to collaborate and innovate is amplified, and we are united in delivering on Vanguard's core purpose.

Our core purpose: To take a stand for all investors, to treat them fairly, and to give them the best chance for investment success.

How We Work

Vanguard has implemented a hybrid working model for the majority of our crew members, designed to capture the benefits of enhanced flexibility while enabling in-person learning, collaboration, and connection. We believe our mission-driven and highly collaborative culture is a critical enabler to support long-term client outcomes and enrich the employee experience.