PURPOSE

- To establish a Job Description that outlines the reporting relationships, prerequisites, responsibilities, and general job requirements for the Sr. Manager, Ethics & Compliance role within Jabil's Global Ethics & Compliance Team (GECT).

SCOPE

- This Job Description shall apply to the Sr. Manager, Ethics & Compliance position within the Global Ethics & Compliance Team, reporting to the Sr. Associate General Counsel at Jabil Inc., St. Petersburg, FL. This position has global scope, spanning all Jabil sites, sectors, and business units.

Job Summary

The Sr. Manager, Ethics & Compliance is a program owner and operational leader within the Global Ethics & Compliance Team, operating under the oversight of, the Sr. Associate General Counsel. The Sr. Manager has primary responsibility for remediation lifecycle for new controls arising from investigations, including attending investigation readouts, triaging remediation plans, and managing Corrective Measures Action Plans (CMAPs) from initiation through closure and effectiveness review, with direction and oversight from the Sr. Associate General Counsel. This role has responsibility for managing Jabil's global Conflicts of Interest process and assessment end-to-end — from disclosure intake and triage through research, mitigation, and closure. The role also serves as a primary drafter and steward of global ethics and compliance policies, ensuring consistency, clarity, and alignment with program objectives and industry best practices, with oversight and approval from Sr. Associate General Counsel. Additional compliance program projects are assigned as needed, including training campaigns, executive reporting, risk assessments, and integrity initiatives.

Essential Duties And Responsibilities

Investigation Remediations & Corrective Measures Action Plans (CMAPs)

- Attend investigation readouts to fully understand findings, root causes, and control environment gaps, and to identify remediation needs arising from substantiated investigations.
- Triage remediation plans by assessing scope, complexity, priority, business risk, and resource requirements to determine appropriate corrective action pathways, in consultation with the Sr. Associate General Counsel.
- Manage the full CMAP lifecycle from initiation through closure, under the oversight of the Sr. Associate General Counsel, including drafting remediation plans, assigning ownership, setting milestones, tracking progress, and conducting effectiveness reviews.
- Draft and review remediation plans to ensure corrective actions are clearly defined, appropriately scoped, and directly address the identified root causes.
- Evaluate whether proposed remediation actions are proportionate, sustainable, and verifiable, recommending adjustments where corrective actions do not adequately address underlying control failures, and escalating recommendations to the Sr. Associate General Counsel for review and approval.
- Partner with process owners, site leadership, HR, Procurement, Internal Audit, and functional stakeholders to define and implement corrective actions addressing control failures — including policy failures (missing, incomplete, unclear, or outdated guidance; undefined exception criteria), process failures (undocumented procedures, immature processes, omissions, workarounds, bypassed controls, ineffective reviews), and people/training failures (change management gaps, turnover-related breakdowns).
- Build and maintain the CMAP reporting framework and taxonomy, including categorization of findings by control failure type, remediation status, aging, and risk rating.
- Track all remediation milestones and ensure timely completion of corrective actions, proactively escalating delays,



resource constraints, or emerging risks to leadership.
- Conduct post-remediation effectiveness reviews to validate that corrective actions have been fully implemented, are operating as intended, and have effectively addressed the underlying control failures.
- Provide regular CMAP status reporting for inclusion in Ethics & Compliance Board reports, Audit Committee updates, and executive presentations.
- Identify systemic remediation themes and trends across investigations and recommend enterprise-wide control enhancements to prevent recurrence, in collaboration with the Sr. Associate General Counsel.
- Maintain detailed remediation records and documentation to support program effectiveness assessments and audit requests.

Conflicts of Interest (COI) Process & Assessment Management

- Own and manage the full lifecycle of global Conflicts of Interest disclosures, including oversight of intake, and triage process. Manage the research, assessment, mitigation design, implementation monitoring, and closure, escalating as necessary to the Sr. Associate General Counsel.
- Administer and oversee COI disclosures within the Resolver platform, ensuring timely processing, thorough documentation, and consistent application of the Global Conflicts of Interest Policy.
- Conduct research and due diligence on disclosed conflicts — including personal relationships (spouse/romantic, familial, close personal friends), outside employment, and financial interests — to assess the nature, scope, and potential impact on Jabil's business interests.
- Develop and recommend appropriate mitigation and remediation measures for substantiated conflicts, in consultation with the Sr. Associate General Counsel as necessary, coordinating with HR, management, and business leaders to implement controls such as organizational changes, recusals, enhanced oversight, and ongoing monitoring.
- Design and continuously refine the COI assessment framework, in partnership with the Sr. Associate General Counsel, to reflect program maturity, evolving business needs, and industry best practices.
- Present COI trends, risk themes, and program metrics to senior leadership, in coordination with the Sr. Associate General Counsel, to be presented to the Audit Committee and the Board of Directors as part of recurring Ethics & Compliance reporting.
- Coordinate with the investigations team and the Sr. Associate General Counsel on COI-related referrals and ensure appropriate escalation of disclosures that indicate potential policy violations or heightened risk.
- Manage the biennial General COI Training campaign, including content review, stakeholder coordination, completion tracking, and analysis of training-related disclosures for program improvement opportunities.

Policy Writing & Management

- Serve as a primary drafter and reviewer of global ethics and compliance policies, under the direction and oversight of the Sr. Associate General Counsel, ensuring clarity, consistency, and alignment with program objectives and industry best practices.
- Manage the policy lifecycle, including version control, periodic review scheduling, stakeholder consultation, executive approvals, and publication on Jabil's internal platforms (e.g., JabilWeb Policies page).




- Coordinate the translation of policies into all Jabil-supported languages and ensure accuracy and consistency across all language versions.
- Conduct gap analyses to identify areas where new policies, policy revisions, or supplemental guidance are needed based on investigation findings, risk assessments, benchmarking, or program enhancements, in collaboration with the Sr. Associate General Counsel.
- Benchmark Jabil's compliance policies against industry standards, peer company practices, and recognized compliance program frameworks to identify areas for improvement.
- Lead policy harmonization efforts across acquired entities, in coordination with the Sr. Associate General Counsel, ensuring integration of compliance standards during mergers, acquisitions, and divestitures.
- Draft interpretive guidance, FAQs, and implementation toolkits to support consistent policy application across global sites and functions.
- Partner with subject matter experts across HR, Procurement, IT, EHS, and business units to gather input, validate policy content, and ensure cross-functional alignment.
- Maintain a centralized policy inventory and lifecycle tracker for the Integral Ethics & Compliance Team, ensuring all policies are current, accessible, and reviewed on schedule.

Additional Compliance Program Projects

- Support compliance program design and effectiveness initiatives, in collaboration with the Sr. Associate General Counsel, contributing to program maturity evaluations and identifying opportunities to strengthen the overall compliance framework.
- Contribute to enterprise risk assessments by identifying emerging risks, evaluating control adequacy, and recommending program enhancements.
- Support the development and delivery of compliance training campaigns, including content development, reviewing eLearning materials, contributing to live training sessions (e.g., Compliance Quality Cohort Training, Manager and HR COI Training), and advising on direct labor training content.
- Contribute to the preparation of Ethics & Compliance Board reports, Audit Committee reports, and executive presentations with data analysis, program metrics, narrative drafting, and strategic recommendations.
- Support integrity and culture initiatives such as Integrity Festivals and regional engagement events across global Jabil sites.
- Partner with the Sr. Associate General Counsel to represent the Global Ethics & Compliance Team in cross-functional working groups, steering committees, and enterprise initiatives where compliance program expertise is required.
- Support benchmarking and analysis of speak-up culture metrics, reporting channel distribution, and cross-industry comparisons to assess program health and identify improvement opportunities.
- Support third-party integrity program processes, including risk-based assessment frameworks and due diligence workflows for suppliers, vendors, and business partners.
- Support the compliance program's use of technology platforms, including Resolver for case management, and contribute to process automation and reporting enhancements.
- May perform other duties and responsibilities as assigned.

Management & Supervisory Responsibilities

This role has at least one direct report, and may supervise or provide work direction to compliance specialists, program coordinators, interns, or other support staff as the program evolves. The Sr. Manager reports to the Sr. Associate General Counsel and operates with significant autonomy exercising independent judgment within the scope of this role. The position requires the ability to lead cross-functional workstreams, manage complex projects with minimal supervision, and influence stakeholders at all levels of the organization, including senior executives.

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