Job Title : Compliance Manager
Seniority Level : Mid-Senior level
Employment Type : Permanent
Responsible for ensuring that all internal policies, procedures and operating standards are adhered to as well as any external operating requirements, and ensure that BAT's best interests are upheld in order to protect the external perception of the organisation
Onboarding SOBC training for new employees.
Annual SOBC training for all employees.
Reporting of all SOBC cases (refer to SOBC Assurance procedure).
Dealing with Area / Regional requests (ABAC, third party service provider questionnaires etc.).
Quarterly SOBC updates to the Area.
Complete / review compliance / SOBC related reports.
Ensure compliance with local laws and regulations and BAT policies and procedures including International Marketing Principles
Training to employees as needed.
Responding to Area / Regional requests.
Ensuring the procedure is being followed and implemented (i.e. packages).
Records management of all ABAC queries, and documents.
Managing, recoding and monitoring ongoing COI declarations
Obtaining line manager / business approval as needed.
Clearing COI declarations post annual SoBC sign off.
Approving entertainment and gifts to be offered or received as per Group SOBC / local policies / local laws
Maintaining an entertainment and gifts log
Approving and recording all political and charitable contributions as per Group SOBC / local policies / local laws.
Sanctions training as needed.
Annual training for the whole company (included in SOBC training).
Identifying potential areas of vulnerability.
Providing general sanctions guidance under US sanctions, EU sanctions, UK sanctions and other applicable trade restrictions laws and internal BAT sanctions policies and guidelines
Regular updates on new / amended / deleted SDNs to the business.
Sanctions Committee Meetings (biannually).
Keeping abreast of the nationalities of BAT employees and whether they are impacted by sanctions (particularly for US / EU and Canadian citizens).
Approvals and management of Sanc Vendors creations
Managing travels to sanctioned countries
NC sanctions compliance (items in the products).
Conducting Third Party Screening on World Check One Tool.
Review and approve creation of vendors.
Assisting with large scale screening projects such as Group annual screening exercise
Keep abreast of all new legal updates that could / would affect records management (e.g. Data Protection Laws).
Providing risk and control measures to Finance (usually number of all whistleblowing cases).
Ensure implementation of Group and MESA SOBC Assurance Policy.
Reporting Allegations as per MESA SOBC Assurance Policy
Supporting the Case Owners and Key Contact Persons as needed
If appointed as Case Owners / Moderators, manage the investigation, appoint the Key Contact Person, close the case on the SOBC portal (refer to the Case Owner Manuel for more details on their role and responsibilities of Case Owner)
Provide support for implementing the Know Your Customer requirement under the SCCP
Provide support to local SCCP SPOC as needed
Bachelor of Law (LLB) or Master of Laws) LLM
Experience / Skills
5 to 7 years of experience in prestigious law firm, FMCG or multi national company
Good analytical skills
Excellent leadership capabilities
Ability to work well independently and in a team setting
If you have the talent and motivation to help us succeed you’ll find we are equally committed to helping you reach your full potential too.
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