DIRECTOR or SENIOR DIRECTOR OF COMPLIANCE

Compliance Director

This position may have director level oversight for the design, implementation and management of Seminole's NERC Regulatory compliance, information governance, ethics, corporate health and safety, corporate training and related programs. Includes responsibility for programs to monitor, implement, and achieve compliance with federal and regional electric system reliability standards, including Federal Energy Regulatory Commission (FERC), North American Electric Reliability Council (NERC), and Florida Reliability Coordinating Council (FRCC). This position will report to the Executive VP Chief Legal Officer and Chief Compliance Officer.

Essential Functions

General

• Coordinates daily activities related to information governance, corporate training and reliability standards compliance, including supervision of information governance and compliance teams.
• Provides a safe and productive work environment for team members congruent with Seminole's desired culture and in full support of Seminole's purpose, core values, core competencies and organizational goals.
• Monitors industry best practices and identifies changes that affect information governance, corporate training and regulatory compliance.
• Prepares and presents department capital and operating budget.
• Performs other duties as applicable to the position or as assigned.

Regulatory Compliance

• Communicates with the NERC Compliance internal team, subject matter experts and outside consultants regarding NERC Reliability Standards.
• Coordinates and submits mandatory filings for federal, state, and local regulatory agencies.
• Coordinates established balloting process for new and revised NERC Reliability Standards.
• Coordinates regulatory audit preparation activities to include preparation, critique, and validation of relevant reliability standard audit worksheets (RSAW's) and periodic updates.
• Coordinates the storage of required NERC compliance documentation and evidence to ensure the material is available and follows BES Cyber System Information requirements.
• Develops and maintains Seminole's Vulnerability Risk Assessments (VRA) and Emergency Recovery Plan (ERP) as required by the Rural Utilities Service (RUS).
• Develops effective action plans and coordinates multiple activities in a timely and efficient manner.
• Develops internal processes and controls to achieve and sustain compliance with applicable NERC Reliability Standards (CIP-004 and CIP-011).
• Maintains knowledge of current and future regulatory requirements and assesses their impact on Seminole.
• Interprets new and existing regulations in consultation with legal and other subject matter experts to determine applicability
• Leads a centralized Reliability Standards Compliance monitoring and reporting program to assure Seminole's auditable compliance with FERC, NERC & FRCC standards as well as FERC Standards of Conduct.
• Manages complex compliance assessments, documents compliance status, and makes recommendations on corrective action required to achieve compliance with NERC Reliability Standards.
• Manages corporate activities during all NERC reliability standards compliance monitoring functions including on-site audits, spot checks, and self-certifications.
• Participates in industry forums and committees to improve overall compliance with NERC and FERC requirements
• Ensures Seminole is complying with all compliance guidelines and regulations set forth by regulatory agencies.

Information Governance and Corporate Training

• Advises various departments on records retention issues related to federal, state, and local laws and regulations.
• Archives historical data/records or ensures their destruction, as necessary.
• Assists in the development and maintenance of relevant training materials for the Internal Compliance Program.
• Assists with the evaluation & preparation of procedural documentation, ongoing monitoring, testing, and remediation.
• Coordinates with management to address potential areas of non-compliance and anticipate future compliance requirements.
• Develops, enhances, and operationalizes enterprise-level privacy policies, processes and controls to mitigate risk and comply with applicable laws and regulations.
• Drafts information governance and compliance related plans, procedures, policies, and practices.
• Ensures compliance with financial, legal or administrative requirements and regulations.
• Ensures data integrity by performing data analysis and identification of anomalies.
• Ensures the regulatory training of all employees and contractors (including HIPAA training).
• Establishes and maintains effective relationships with local industry, regional entities, and internal stakeholders to allow for effective achievement of business goals and compliance with program requirements.
• Evaluates & prepares procedural documentation, ongoing monitoring, testing, and remediation related to compliance
• Implements and monitors access controls, security controls for records management, and ensures data controls for confidential or protected information (including information protected by CAs/NDAs).
• Implements systematic continuous improvements of compliance policies, procedures, training materials, and asset lists.
• Leads the design, development, implementation, and maintenance of the information governance program.
• Leads the development and ongoing management of privacy programs across the company to ensure compliance with data privacy requirements.
• Organizes, classifies and indexes records so that records are easily accessible when needed.
• Oversees migration and onboarding of paper to electronic record-keeping.
• Oversees the review, update, and approval of corporate procedures.
• Participates in addressing requests with regional regulatory agencies and internal departments to ensure that compliance issues are addressed in a timely manner.
• Participates in compliance monitoring activities such as audits, spot checks, compliance self- assessments and self-certification.
• Participates in coordination of mandatory filings for federal, state, and local regulatory agencies.
• Participates in meetings with senior staff and management to identify and address potential areas of non-compliance and anticipate future compliance requirements.
• Participates in the coordination of daily activities in the compliance department, including addressing incoming calls and requests for information
• Participates in the coordination of requests with regional regulatory agencies and internal departments to ensure compliance issues are addressed in a timely manner.
• Participates with team of personnel in the performance of audits, surveillances, and assessments.
• Provides corporate governance for Shady Hills Combined Cycle Facility (SHCCF) including delegations of authority, required documentation, and storage locations.
• Provides leadership and direction in the planning, development, organization, coordination, implementation, and review of corporate Internal Compliance Program.
• Provides litigation support for legal holds and discovery production pursuant to direction from counsel.
• Provides training to staff who require access or have responsibility for maintaining records.
• Represents organization at external meetings at the regional and federal level.
• Upgrades and implements new methods, procedures, and equipment to assure maximum user satisfaction for records management.

NERC Compliance: Performs NERC Compliance Program roles if/as designated in Seminole's Standard Ownership Matrix (SOM) including ongoing evidence retention in "audit-ready" form. You should also be familiar with Seminole's Enterprise Internal Compliance Program (ENT-GCD-RGC-EP-054) to further your understanding of Seminole's compliance program and your duties and responsibilities in the SOM.

Qualifications and Education Requirements

Bachelor's degree in accounting, business, engineering, management or related field required. MBA, law, or advanced degree desired and a minimum of ten (10) years progressively responsible experience in records and data governance/management, risk management, compliance, accounting, or finance with at least five (5) years in regulatory compliance, specific subject matter experience required. Supervisory experience is required. Electric utility experience is desirable. Knowledge of regulatory framework governing records and data governance. Knowledge of records management workflow and content management. Knowledge of data privacy regulations (e.g., HIPAA). Must have knowledge of NERC Reliability Standards and be familiar with the NERC Rules of Procedure associated with Reliability Standards development, compliance, and enforcement. Must remain current with all NERC, FERC, and FRCC compliance requirements. Must acquire and maintain knowledge with the technical terminology used in reliability standards. Knowledge of Governance, Risk, and Compliance (GRC) solutions and common control frameworks for data regulations. Technical knowledge is required (but not developer level skills).

Core Competencies : Adaptable, Collaborative, Conscientious, Critical-Thinking, Outcome-Driven, and Professional

Technical Competencies/Skills :

• Knowledge of internal controls
• Project management software
• Records retention requirements/regulations
• Policies and procedures
• Contracts
• Corporate training to include Legal, ethical and compliance programs and training
• Budgeting
• Filing and retention guidelines
• NERC/FERC, CEII, CUI, PII, PHI, and other protected information
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