Compliance Manager

Reports To: Chief Legal Officer

Job Purpose

To manage Gulftainer’s compliance programme across the Group, translating applicable requirements and internal policies into practical controls, clear responsibilities, and measurable actions. The role identifies compliance risks, monitors adherence, supports investigations, and provides the Chief Legal Officer with reliable visibility of material issues and corrective actions.

Key Responsibilities

Compliance Framework and Planning

• Develop and maintain a Group compliance framework covering relevant business activities, entities, and jurisdictions.
• Maintain a compliance obligations register identifying applicable requirements, responsible owners, required evidence, and key deadlines.
• Conduct compliance risk assessments with business and functional leaders, prioritising areas with the greatest exposure.
• Prepare an annual compliance plan with defined reviews, deliverables, owners, and reporting milestones for approval by the Chief Legal Officer.
• Review proposed business activities and operational changes to identify compliance requirements before implementation.

Policies and Practical Controls

• Develop, review, and update compliance policies, procedures, and guidance in coordination with Legal and relevant functions.
• Translate policy requirements into practical approval steps, checks, records, and escalation procedures.
• Monitor adherence to requirements relating to anti-bribery and corruption, conflicts of interest, gifts and hospitality, third-party integrity, and other relevant compliance areas.
• Maintain appropriate registers for declarations, approvals, exceptions, and identified breaches.
• Assess requests for exceptions and refer matters requiring approval to the Chief Legal Officer with a clear recommendation.

Third-Party Due Diligence and Business Support

• Establish a risk-based due diligence process for relevant agents, intermediaries, suppliers, customers, and business partners.
• Coordinate integrity checks, sanctions screening, and other relevant reviews before onboarding or renewal, according to approved procedures.
• Document due diligence findings, unresolved concerns, required safeguards, and approval decisions.
• Work with Procurement, Commercial, Finance, and Legal to incorporate appropriate compliance requirements into onboarding and contracting processes.
• Provide timely, practical guidance on compliance questions and escalate material concerns before commitments are made.

Monitoring and Corrective Actions

• Conduct compliance reviews against the approved plan, testing whether controls are operating effectively and supported by evidence.
• Record findings with a clear risk rating, corrective action, accountable owner, and completion deadline.
• Follow up on overdue actions and escalate unresolved high-risk matters to the Chief Legal Officer.
• Verify that corrective actions address the underlying issue before closing findings.
• Coordinate with Internal Audit, QHSE, HR, IT, and other assurance functions to share relevant findings and avoid duplication

Speak Up, Incident Management, and Investigations

• Support the operation of confidential reporting channels and ensure concerns are recorded and assessed promptly.
• Coordinate or conduct compliance investigations as assigned by the Chief Legal Officer, involving Legal, HR, Internal Audit, or other functions where appropriate.
• Maintain secure case records covering allegations, evidence, findings, decisions, and follow-up actions.
• Handle information with discretion and support adherence to confidentiality and non-retaliation requirements.
• Identify recurring issues and recommend changes to controls, training, or working practices.

Training and Compliance Awareness

• Develop an annual compliance training plan based on role requirements and identified risks.
• Coordinate induction, refresher training, and targeted sessions for employees in higher-risk roles.
• Use practical business scenarios to explain expected conduct, approval requirements, and reporting routes.
• Track training completion, policy acknowledgements, and assessment results, following up on outstanding requirements.
• Evaluate understanding and recurring compliance issues to improve the relevance and effectiveness of training.

Reporting and Stakeholder Coordination

• Prepare a regular compliance dashboard covering key risks, incidents, reviews, overdue actions, due diligence, and training completion.
• Escalate material issues promptly, with supporting facts, potential business impact, and recommended next steps.
• Monitor relevant regulatory developments with Legal and coordinate required changes with responsible business owners.
• Support responses to regulatory enquiries and information requests under the direction of the Chief Legal Officer.
• Maintain organised, retrievable evidence of compliance activities, approvals, and completed corrective actions.

Key Success Factors

• Clear obligations and ownership: An up-to-date compliance obligations register identifies responsible owners, deadlines, and required evidence for in-scope entities and activities.
• Delivery of the compliance plan: Scheduled reviews, policy updates, and training activities are completed within agreed timelines, with any changes approved and documented.
• Effective closure of findings: Every material finding has a risk rating, owner, and deadline; closure is supported by evidence that the corrective action works.
• Controlled third-party onboarding: Required due diligence is completed before approval, with unresolved risks escalated and safeguards documented.
• Timely incident handling: Reported concerns are assessed within agreed timelines, with documented investigation outcomes and follow-up actions.
• Demonstrated employee understanding: Mandatory training and policy acknowledgements meet agreed completion targets, with assessment results used to address knowledge gaps.
• Reliable management visibility: The Chief Legal Officer receives accurate, timely reporting that clearly identifies material risks, overdue actions, and decisions required.
• Sustained control improvement: Recurring breaches and repeat findings are tracked, with root causes addressed and improvements verified.

Core and Behavioural Competencies

• Client Focus
• Acts with Integrity
• Valuing Culture and Diversity
• Teamwork and Collaboration
• Planning and Organising
• Decision Making and Problem Solving

Technical and Functional Competencies

• Compliance risk assessment and programme management
• Interpretation of compliance requirements and translation into practical controls
• Policy development and implementation
• Third-party due diligence and integrity screening
• Compliance monitoring and control testing
• Investigation support, evidence handling, and confidential case management
• Corrective action tracking and verification
• Compliance training and management reporting
• Sound judgment, discretion, and confidence to challenge non-compliant practices
• Understanding of ports, terminals, logistics, and international business environments

Typical Level of Interaction: Works regularly with business leaders, functional managers, and designated compliance owners to clarify requirements, review controls, resolve compliance issues, and verify corrective actions. Escalates material risks, breaches, and decisions to the Chief Legal Officer.

Internal Stakeholders: Chief Legal Officer, Legal, Group leadership, business and country management, Commercial, Operations, Finance, Procurement, HR, IT, QHSE, Internal Audit, and other relevant corporate functions.

External Stakeholders: External legal advisers, compliance consultants, screening providers, auditors, and relevant regulators or authorities, in coordination with the Chief Legal Officer and authorised business representatives.