Compliance Supervisor, Code of Ethics

About Sands Capital:

We are an active, long-term investor in leading innovative businesses globally. Our approach combines analytical rigor and creative thinking to identify high-quality growth businesses that are creating the future. Through an integrated investment platform spanning venture capital, growth equity and public equity, we provide growth capital solutions to institutions and fund sponsors in more than 40 countries (detailed on our website www.sandscapital.com).

Position Summary:

Sands Capital is seeking a Compliance Supervisor who will manage, administer, and facilitate the organization’s Code of Ethics program and work collaboratively with Sands Capital’s Compliance team to build and manage other aspects of Sands Capital’s compliance program with respect to the three investment advisers that comprise Sands Capital – Sands Capital Management, Sands Capital Alternatives, and Sands Capital Horizons.   

The individual will work in conjunction with staff members firmwide to mitigate risks to Sands Capital and seek to enhance compliance program processes and related books and records requirements.

Work Expectations:  

The work location for this role is Sands Capital’s headquarters in Arlington, Virginia on a hybrid schedule of three days per week in-office (including Tuesdays and Wednesdays), or more as directed by your manager. The hybrid schedule is subject to change at any time.

Position Responsibilities:

• Code of Ethics Program:
  • Primarily responsible for the design and development of the Code of Ethics program, including: advising on Code of Ethics policy changes, managing the Code of Ethics management system used by the firm, leading the creation of related monitoring and testing activities, acting as the primary point of contact for staff members on Code of Ethics matters, and building and administering training related to the Code of Ethics.
  • Managing and executing the day-to-day activities in connection with the Code of Ethics policy, including: staff members’ personal trading, gifts and entertainment, political contributions, outside business activities, initial, quarterly and annual compliance certifications and questionnaires and other staff member reporting requirements; as well as conducting internal reviews of the Code of Ethics program in accordance with the firm’s compliance policies and procedures.
  • Maintaining and ensuring that all staff member and firm information is kept up to date in the Code of Ethics management system (e.g., users, groups, rules, access permissions etc.).
  • Overseeing proper functionality and effectiveness of Code of Ethics systems (e.g., automated trade pre-clearance, broker feed connections, automated population of staff member portfolios, etc.), monitoring and seeking to prevent systems failures, and managing day-to-day relationships with third party compliance software service providers.
  • Organizing, maintaining, and enhancing the compliance program’s books and records, drafting and updating written desktop procedures, and developing other related compliance logs and inventories.
  • Drafting and revising periodic updates of Sands Capital’s Code of Ethics program.
  • Improving the quality and efficiency of the Code of Ethics program, including following regulatory and technological developments, industry best practices, and implementing corresponding updates to the program.
  • Conducting new staff member training on the firm’s Code of Ethics policies and procedures and participating in the drafting of any related training materials to be used in initial or periodic training sessions.
  • Addressing questions and requests from Sands Capital staff members regarding personal securities transactions, political contributions, outside business activities, etc.; and
  • Preparing and evaluating certain Compliance metrics and data analytics with respect to the firm’s Code of Ethics program for presentation to Sands Capital’s Executive Management Committee.
• General Responsibilities:
  • Identifying and documenting conflicts of interest, including by monitoring of staff member disclosures, Sands Capital strategy portfolio holdings, conflicts disclosures of Sands Capital’s clients, vendors and other service providers to Sands Capital, and assessments of client relationships and allocations.
  • Assisting in the review of investor-facing disclosures for Sands Capital-advised investment vehicles.
  • Organizing and maintaining records of LPAC-related documentation.
  • Assisting with maintenance of the Restricted List and wall crosses.
  • Conducting certain forensic testing activities for Code of Ethics as part of each Sands Capital adviser’s required 206(4)-7 annual review.
  • Assisting with responding to regulatory inquiries, examinations, external audits, and prospective clients’ due diligence questions.
  • Contributing to general compliance trainings.
  • Working cross-functionally with other Sands Capital teams in seeking to increase efficiency of data flows of necessary information for Sands Capital’s Compliance program through increased automation and use of AI-enabled tools.
• Researching novel or complex compliance issues.
• Participating in the implementation and completion of strategic projects that enhance Sands Capital’s compliance program.
• Providing strong hands-on support and execution with respect to all critical ad-hoc compliance projects.
• Executing other administrative or professional responsibilities, as needed; and
• Exhibiting behaviors consistent with Sands Capital’s Mission, Values, and culture.

Position Qualifications:

• Undergraduate degree from an accredited university (JD preferred);
• 8-10+ years of relevant compliance experience at an investment management firm or prior regulatory advisory consulting experience.
• Direct experience addressing or managing an investment adviser’s code of ethics program.
• Working knowledge of the Investment Adviser’s Act of 1940 preferred.
• Highly organized and detail-oriented.
• Ability to develop expertise in new technological systems.
• Excellent drafting, reasoning and analytical capabilities.
• Ability to quickly learn new subject areas and processes.
• Strong work ethic, time management skills, and the ability to work independently to produce deliverables on tight deadlines.
• Strong verbal and written communication skills; and
• Excellent knowledge of Microsoft Office (specifically, Excel, Word, and PowerPoint).

Required Behavioral Characteristics:

The following are behavioral characteristics that the firm holds in high regard and believes are critical for high performing individuals and teams at Sands Capital: 

• Having impeccable integrity.
• Exhibiting superior client service skills (both internally and externally).
• Exhibiting strong interpersonal skills.
• Demonstrating a strong work ethic in a fast-paced, professional environment.
• Operating with a high degree of initiative, self-discipline, and motivation.
• Being able to collaborate and work effectively as part of a team, while also being able to work independently with a high degree of efficiency and accuracy.
• Assuming the best of others.
• Being motivated by a job well-done.

Sands Capital’s Values:

The following are values that the firm holds in high regard and believes are critical for high-performing individuals and teams at Sands Capital:

• Integrity & Trust: Do what is right, not what is popular. Deliver on commitments.
• Client-Centered: Always act in the best interest of our clients.
• Commitment to Excellence: Strive to learn and improve. Implement best practices.
• Focus: Identify and concentrate on “what matters”.
• Long-Term Perspective: Appreciate that time allows sound decisions to demonstrate their worth. Avoid short-term thinking.
• Independent Thinking: Have the courage to develop and articulate your own convictions. Debate others openly and honestly.
• Teamwork: Collaborate to gather facts, develop perspective, build conviction, and support timely decision-making.
• Positive “Can-Do” Attitude: Demonstrate a willingness to tackle any task.
• Graciousness: Reflect kindness and courtesy at all times.
• Balance: Enjoy your work while balancing professional activities with interests beyond the firm.
• Meritocracy: Know that talent and achievement will drive your success at Sands Capital.

How to Apply:

To be considered, you must submit a resume that specifically outlines your qualifications for the position. If you wish to apply for this position, please do so via Sands Capital’s Careers page under “Professional Opportunities”. You may also scroll to “FAQs” to learn more about what you can expect before applying, to include information regarding length of process and any skills assessments that may be required. 

Apply here: https://www.sandscapital.com/careers-and-staff-benefits/

Salary and Benefits:

The compensation for this role includes a base salary range of $160,000 - $185,000 (as determined by the candidate’s professional experience and relevant knowledge, skills, and abilities), as well as a discretionary, performance-based bonus. Bonus targets may vary by position and are based on both individual achievement as well as broader firm performance.

Sands Capital offers a generous benefits package, including medical insurance (which includes a discount vision program), dental insurance, life and personal accident insurance, short- and long-term disability insurance, flexible spending accounts (medical and dependent) as well as paid stock market (NYSE) holidays and vacation, sick, and parental leave. We also have a variety of generous miscellaneous benefits, such as a medical concierge service, health and wellness coaches, personal finance support, onsite massage therapy, and more.

Sands Capital is proud to be an Equal Opportunity Employer. We are committed to providing equal employment opportunities to all applicants and staff members. For our staff members, equal opportunity includes access to the benefits and privileges that the firm provides to staff members generally. We appreciate the value diversity brings to Sands Capital and are committed to creating an inclusive environment for all staff members.

We evaluate and select qualified applicants without regard to race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information, marital status, veteran status, or any other characteristics protected by applicable federal, state, or local laws. Discrimination of this kind is also strictly prohibited by a variety of federal, state, and local laws, including Title VII of the Civil Rights Act 1964, the Age Discrimination in Employment Act of 1967, and the Americans with Disabilities Act of 1990.

Read more about equal employment opportunity on the EEOC’s website, found here.

We are committed to working with and providing reasonable accommodations to pregnant individuals, individuals with disabilities, and/or individuals needing accommodation for sincerely held religious beliefs. If you need a reasonable accommodation, please send an e-mail to emiller@sandscap.com and let us know the nature of your request and your contact information.