Director, Group Anti-bribery and Corruption

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Working with Group functions (Group Compliance, Group-wide Internal Audit, Group Risk, Group Legal) and Business Units (Bus / LBUs), the Group ABC Director will contribute to the development of the Group’s ABC risk management framework (including risk appetite statements / tolerances), policies (containing key controls) and underlying standards (containing control activities). The Group ABC Director plays a strategic role in addressing all aspects of bribery and corruption prevention including (but not limited to) the prevention, detection, investigation and reporting of bribery risk. The role is also responsible for development, execution and reporting of Group-wide annual risk assessments, management of significant ABC incidents, oversight of and reporting on the condition of key controls.

Principal Accountabilities :

• Implements the Group’s ABC compliance program across all markets and regions ensuring appropriate compliance due diligence, governance, and monitoring processes are established.
• Serves as an interface between RCS and BU / LBU ABC leads, building relationships and working closely with internal stakeholders
• Reviews, enhances and oversees compliance with the Group’s ABC policies and standards, Risk Appetite Statements, Tolerances, Group-wide Operational Standards (GwOS), key controls and aligned control activities.
• Proactively contributes to the enhancement of the Group’s ABC program.
• Produces Management Information (MI) and reporting for executive and board-level Risk and Audit Committees.
• Performs annual ABC Risk Assessments, prepares and delivers resulting reports to GERC and GRC.
• Assists in the management of key audits. Maintains a strong relationship with Group Internal Audit. Ensures and reports on any internal and external review / audit recommendations are fully implemented.
• Develops Bribery and Corruption prevention plans, concurrently conducting reviews and analysis of associated risks, trends and the effectiveness of bribery prevention, detection, monitoring and control activities across the Group and Business Units.
• Oversees, provides input to and reports on the effectiveness of ABC Monitoring (detection) activity
• Leads, manages, and coordinates ad-hoc ABC projects, initiatives where required.
• Responsible for the implementation and management of LBU / BU ABC assurance ‘deep dives.’
• Coordinates the gathering of ABC related management information and intelligence from within and outside the Group, to create risk assessments and drive current and future bribery prevention methodology.
• Develops and maintains a strong network of contacts with industry, regulatory and law enforcement personnel in the ABC prevention arena.
• Benchmarks the Group’s ABC compliance program to peer programs including participation in various industry network and benchmarking group.
• Prepares, reviews and if required delivers training to BU / LBUs and RCS team.
• Identifies, assesses and where appropriate, manages the implementation of market-leading technology solutions for ABC monitoring, analysis and reporting.
• Establishes and maintains close working relationships and formal lines of communication across the Group, on ABC prevention related matters
• Represents the Group in appropriate professional networks and forums.
• Supports the wider Group Risk and Compliance function as necessary.

Contact with Others :

Knowledge and Experience

Core Competencies Required

Additional desirable competencies :