Ethics & Business Integrity Officer

About Emirates Global Aluminium

Emirates Global Aluminium is the world’s biggest ‘premium aluminium’ producer and the largest industrial company in the United Arab Emirates outside the oil and gas industry. EGA is an integrated aluminium producer, with operations on four continents from bauxite mining to the production of cast primary aluminium and recycling. EGA employs over 7,000 of these people including more than 1,200 UAE Nationals. EGA operates aluminium smelters in Jebel Ali and Al Taweelah in the United Arab Emirates, an alumina refinery in Al Taweelah, a bauxite mine and associated export facilities in the Republic of Guinea, a speciality foundry in high strength recycled aluminium in Germany, and a recycling plant in the United States.

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 ACCOUNTABILITIES

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 [email protected]).
  • 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

QUALIFICATIONS & SKILLS

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).