Job description:
Title: Officer - Ethics & Business Integrity
Legal, Ethics & Business Integrity
JOB PURPOSE
Provides analytical and coordination support to assist in the development and implementation of Emirates Global Aluminium's (EGA's) ethics & compliance program in line with leading practices and applicable laws, regulations, policies and standards in order to promote ethical decision-making and support business functions across the Group on all matters related to ethics & compliance policies, programs and issues In line with defined protocols and quality standards.
KEY ACCOUNTABILITY
Policies, Systems, Processes & Procedures
- Follows all relevant departmental policies, processes, standard operating procedures, and instructions so that work is carried out in a controlled and consistent manner.
- Demonstrates compliance to organization's values and ethics at all times to support the establishment of a values driven culture within the organization.
- Contribute ideas to enhance EGA's ethics & compliance program.
- Publishes ethics & compliance policies and procedures on the intranet.
- Provides accurate and helpful advice to employees on the Code of Conduct and other ethics & compliance policies, procedures, processes, and standards.
- Implements the gifts & entertainment process, seeking advice and escalating issues as appropriate:
- Reviewing and updating the policy/procedure, as necessary.
- Reviewing and advising on gifts & entertainment declarations.
- Maintaining the Gifts & Entertainment Register.
- Promoting awareness and understanding of requirements and expectations to ensure ethical decision-making and compliance with the procedure.
- Providing analysis and data to the Ethics & Compliance Associate Manager.
- Implements the conflicts of interests process, seeking advice and escalating issues as appropriate:
- Reviewing and updating the policy/procedure, as necessary.
- Reviewing and advising on conflict-of-interest declarations in accordance with guidelines.
- Maintaining a record of positive conflict of interest declarations, and mitigation steps.
- Promoting awareness and understanding of requirements and expectations to ensure ethical decision-making and compliance with the procedure.
- Providing analysis and data to the Ethics & Compliance Associate Manager.
- Assists with third party due diligence screening, explaining requirements to business areas, ensuring a good level of user understanding of screening requirements, conducting searches, and reviewing search results.
Issues and risks
- Looks out for emerging ethics & compliance issues and risks, updating the Ethics & Compliance Associate Manager, and suggesting ways to enhance the EGA ethics & compliance program.
Training and Awareness Implementation
- Maintains an annual training calendar.
- Co-ordinates with different areas of the business to understand and respond to their training needs, identifying and suggesting opportunities for training and awareness.
- Develops, in consultation with the Ethics & Compliance team, training and awareness content on the Code of Conduct and other related ethics and compliance issues. This may include:
- Preparing content for e-learning delivered via the LMS, Axonify or other platforms.
- Preparing PowerPoint presentations.
- Arranging supporting materials (quiz, case studies, posters, prizes etc.)
- Liaising with relevant internal teams and external service providers.
- Delivers training as per defined standards:
- Liaising with relevant internal teams to arrange the training.
- Identifying and arranging an appropriate venue / virtual meeting.
- Arranging invites / enrolments.
- Promoting awareness via emails / text messages / intranet banners etc.
- Communicating expectations on completion requirements.
- Presenting the training as required, including induction training.
- Maintaining records of course attendance.
- Responding to queries.
- Maintains a record of completion statistics, providing analysis and data to the Ethics & Compliance Associate Manager.
Capability Building
- Supports and delivers training and awareness to:
- Ethics & Champions (train the trainer), enabling them to deliver training and awareness within their areas.
- Supervisors (train the trainer), enabling them to deliver ethics & compliance awareness within their areas.
- EGA Group's legal team, enabling them to identify ethics & compliance risks and promote ethics & compliance awareness.
Fostering a Speak-Up Culture and Conducting Investigations.
- Participates in fostering an open speak-up culture, by maintaining good relationships with employees, an open door and listening empathetically to employee questions and concerns.
- Takes a contemporaneous written record of concerns raised in person or via the phone.
- Understands EGA's investigation principles and guidelines, and assists in the conducting of investigations:
- Acknowledging new cases received on Your Voice and opening a new case in Your Voice for all cases received in person, by phone or email (including [Confidential Information]).
- Preparing an investigation plan for assigned cases.
- Working with other departments to collate information and evidence, and arrange interviews, while respecting confidentiality.
- Interviewing witnesses, explaining the importance of confidentiality and no retaliation, and taking contemporaneous notes.
- Preparing investigation reports.
- Arranging follow-up meetings with relevant management to agree corrective actions.
- Updating Your Voice and internal records to record outcomes and actions.
- Monitoring the timely completion of follow-up actions.
- Collating and analysing investigations data, providing timely analysis and data to the Ethics & Compliance Associate Manager.
Relationship Management
- Develops and maintains effective working relationships with business areas and all relevant external service providers.
Continuous Improvement
- Contributes to the identification of opportunities for continuous improvement and sustainability of systems, processes and practices considering global standards, productivity improvement and cost reduction.
Reporting
- Prepares timely and accurate statements and reports to meet department requirements, policies, and quality standards.
Other Accountabilities
Performs other duties or assignments as required.
AUTHORITY / DECISION MAKING
- Identify issues and escalate as appropriate, with day-to-day authority to take decisions on:
- Conflicts of interest declarations in accordance with applicable policies and process.
- Gifts & entertainment declarations in accordance with applicable policies and process.
- Answering queries on the Code of Conduct and related ethics and compliance issues.
- Organising training & awareness.
- Subject to Ethics & Compliance Associate Manager oversight and approval
Minimum Qualifications:
- Bachelor's degree (preferably in law or a relevant field to the business) from an internationally recognized university.
- Ethics & compliance certification (e.g., Ethics & Compliance Initiative's Leading Professional in Ethics & Compliance, Society of Corporate Compliance and Ethics Certified Compliance and Ethics Professional, or International Compliance Associations Diploma in Compliance) desirable.
Minimum Experience:
- 3 years relevant experience in ethics and compliance, preferably in a large international company in manufacturing/industry.
- Experience of delivering training and conducting internal investigations, desirable.
Knowledge and skills:
- Good knowledge of UAE laws and regulations or and/or key international laws and regulations, including the UK Bribery Act and US Foreign and Corrupt Practices Act.
- Good knowledge and understanding of ethics & compliance issues.
- Excellent verbal/written English. Arabic and/or French desirable.
- Effective research skills.
- Effective planning, organising and time management skills, with a proven ability to liaise effectively internally and externally (with vendors and service providers).
