Senior Ethical Compliance Specialist (ENEC)

Job Purpose

Independently perform day-to-day activities relating to the Enterprise’s Anti-Fraud and Misconduct Program and Enterprise Code of General Business Principles and Ethics. In addition, support Enterprise Compliance activities as required. Handle fact finding reviews related to Fraud, misconduct, or Data Leakage incidents reported, support fraud risk prevention activities within the Enterprise, and support activities related to implementation and maintenance of the code of ethics.

Key Activities, Responsibility & Accountability

• Support in maintaining an effective framework of the Enterprise Anti-Fraud and Misconduct Program (AFMP), including developing policies and procedures for prevention, detection, and response to fraud or misconduct, including establishing a whistleblowing hotline.
• Independently plan and carry out pre-screening, investigation, and draft reports for assigned cases in line with the Enterprise AFMP procedure
• Supervise work assigned to external consultants and provide support related to procurement activities.
• Conduct suspect interviews and maintain evidence with adequate chain of custody. Support legal proceedings where required.
• Discuss findings and recommendations with process owners and line management for identified process improvements and agree on a corrective action plan.
• Conduct periodical follow-up with relevant stakeholders to review the status of agreed actions.
• Obtain background information, knowledge, and understanding of overall business process for identification of key risks.
• Propose and, after adequate approval, execute appropriate qualitative/quantitative tests and evaluate internal controls during investigations to achieve investigation scope.
• Maintain proper documentation and filing for working papers and record notes to report and document investigation results.
• Prepare presentations on a timely basis for submission to management committees, senior management, and the Audit Risk and Compliance Committee.
• Prepare reports on a timely basis for submissions to external stakeholders such as the Abu Dhabi Accountability Authority (Regulator) and ADQ (parent company).
• Maintain the Case Management tool/software and liaise with the ICT team and vendor as required.
• Deliver training/awareness sessions to Enterprise employees on AFMP. Ensure the e-learning module on Enterprise’s AFMP is up to date.
• Train and develop new consultants as required, including UAE nationals.
• Carry out any other activities as requested such as reviewing new/amended policies, procedures, and supporting other management initiatives.
• Maintain the Conflict of Interest and Gifts and Entertainment Registers and report status periodically.
• Operate the automated Enterprise Compliance Disclosure Management System with various declarations to comply with COE requirements. Coordinate with Enterprise ICT to enhance features, remove bugs, and manage the Disclosure Management System.
• Ensure that COE-related declarations such as the annual acknowledgment & disclaimer and conflict of interest are obtained from all employees and maintained.
• Train employees and conduct COE awareness sessions for all staff, including new joiners, to promote an ethical and compliance culture.
• Identify and report conflict of interest situations and support the Senior Enterprise Ethics and Compliance Manager in managing reported conflict of interest cases.
• Assess gifts surrendered by employees who received gifts above acceptable values and seek approval for disposal per agreed practice.
• Review and update the Code of General Business Principles and Ethics and the Supplier Code of Conduct as necessary to ensure they are current.
• Analyze reported noncompliance issues, identify trends for appropriate actions by the department.
• Conduct exit interviews with departing employees to identify noncompliance issues that were not reported and analyze data to identify and escalate potential issues of noncompliance.
• Prepare periodic reports on the Ethical Compliance Program as required to report progress to management and maintain records.
• Support managing reported noncompliance issues with the COE.
• Coordinate activities such as campaigns, events, and surveys conducted to promote a culture of ethics and compliance at the Enterprise.

Responsibilities & Accountabilities (contd.)

• Coordinate and support the implementation of the Fraud Risk Management Framework aimed at preventing, detecting, and managing fraud and misconduct at the Enterprise.
• Perform fraud risk assessments on a periodic basis, establish Fraud Risk Registers, monitor fraud risks, and propose for escalation as necessary.
• Carry out integrity due diligence activities as defined in the due diligence process for checking the antecedents of new and existing employees, contractors, service providers, and agents to ensure compliance with the Supplier Code of Ethics and that they are not named on any recognized sanction lists.
• Monitor third parties using screening tools and programs and ensure appropriate actions are taken on potential red flags and risks.
• Prepare periodic reports using tools implemented to monitor risks related to third parties concerning sanctions and integrity.
• Develop and maintain ongoing reporting to the Senior Enterprise Ethics and Compliance Manager and the Nawah General Counsel.
• Monitor and schedule assigned work and, where applicable, assist in reviewing and evaluating the performance of consultants appointed from external firms.

Professional Certifications

• Not applicable (N/A) for minimum.
• Preferred: Professional qualification (ACA, ACCA, CIMA, CPA) or certifications such as CFE. Certifications on Compliance and Ethics or Certification in Enterprise Risk Management or auditing.

Qualifications

• Bachelor’s degree in a relevant field.

Experience

5 years of relevant experience.

Pref -

• 10 years of industrial experience, of which 5 years in investigation reviews or compliance-related functions as a Senior Analyst or as an Internal Auditor.
• Experience in the Nuclear Industry or Energy/Oil and Gas Sectors.
• Proficiency in case management tools and investigative techniques.

Experience in fraud investigation, ethics and compliance, or a related field, including managing complex investigations, stakeholder reporting, and co-sourcing activities