Ethics & Compliance
Tullow Oil PLC (Tullow) is a well-established, recognised independent oil and gas company focussed on Africa and South America. The Tullow Group has interests in over 30 exploration and production licences across eight countries in Africa and South America, and its primary operating locations are in Ghana and Kenya.
Tullow has an exciting opportunity for an Ethics and Compliance (E&C) Investigations Lead to join the small, London-based E&C team.
The position will require you to protect Tullow and its staff through proactive management of all elements of Tullow’s established E&C Programme – including (but not limited to) Anti-Bribery and Corruption measures (ABC).
The successful candidate will have specific responsibilities for:
• The proactive, effective, and efficient investigation of all reported/potential cases of unethical conduct and/or non-compliance with laws, regulations, and Tullow’s Code of Ethical Conduct (CoEC), in accordance with Tullow’s Investigation Procedure.
• Management of E&C-related due diligence (DD) assurance activities in relation to third parties working with Tullow, via the Dow Jones platform and other resources.
This is a full-time permanent position, based in Tullow’s Chiswick office with hybrid remote-working arrangements. Occasional overseas business trips will be required, potentially involving visits to offshore and other operating facilities.
• Promptly and proactively coordinate/lead E&C investigations, as/when required, in accordance with Tullow’s Investigation Procedure.
• Coordinate with, and adequately supervise/manage, any of Tullow’s E&C Investigation Specialists that may be required to support investigations.
• Coordinate with, and adequately supervise/manage, any external investigation resources required.
• Maintain accurate and detailed records pertaining to all reported E&C concerns, including subsequent investigations, reporting, follow-up, and closure of any recommended actions, using the E&C Investigations Tracker and other effective mechanisms.
• Maintain, implement, and periodically review the Investigations Procedure. Take responsibility for continuous improvement (including innovative methodologies/systems) in the established processes/practices/templates and establishment of cost-effective external specialist call-off support.
• Develop, maintain, and report on appropriate E&C investigation Key Performance Indicators (KPIs), and strive to improve the informative reporting of these KPIs for the Senior Leadership Team (SLT), Audit Committee and Board (and other applicable stakeholders).
• Manage and enhance Tullow’s E&C risk assessment (including anti-fraud and high-risk transactions/processes), in conjunction with input from other relevant teams – such as Internal Audit & Risk, Finance and Human Resources (HR).
• Proactively assist with the E&C awareness and investigation training initiatives, to drive improvement in Tullow’s business ethics culture, with a focus on high and emerging risk areas, and support for Tullow’s ‘Safecall’ reporting tool.
• Proactively assist with the E&C awareness and investigation training initiatives, to drive improvement in Tullow’s business ethics culture, with a focus on high and emerging risk areas. This includes a specific focus on third party awareness.
• Proactively drive awareness of, and support for, Tullow’s ‘ComplianceLine’ reporting tool, to increase the level of concerns reported, and endeavour to increase the proportion of concerns reported directly to the E&C team. This includes a specific focus on awareness by third parties.
• Maintain responsibility for E&C-related DD assurance activities, using the Dow Jones platform – including continuous monitoring or screening matches and FCPA Tracker investigation updates; weekly review/management of ‘red flag’ risk mitigations/actions; established monthly/quarterly assurance checks; and continuous improvement related to such assurance activities and associated DD record-keeping. This will include all third parties including suppliers, high-risk consultants, and oil marketing third parties.
• Excellent English language (verbal and written) skills.
• Excellent interpersonal, report-writing and presentation skills.
• Excellent investigative and interviewing skills.
• Excellent ability to assess/analyse complex business information; identify key issues and root causes; develop appropriate conclusions; and express clear, realistic, and implementable recommendations.
• Resilient character, with the ability to engage positively with people at all levels of the organization yet deploying strong leadership and influencing skills at the appropriate time.
• Accomplished networker, with the ability to gain the trust of staff.
Education and Experience:
• Relevant professional qualification(s) – such as Associate Chartered Accountant (ACA), Chartered Accountant (CA), Association of Chartered Certified Accountants (ACCA), Certified Internal Auditor (CIA), Certified Fraud Examiner (CFE) and/or International Certified Compliance & Ethics Professional (CCEP -I) or other relevant professional qualification(s).
• Relevant Risk Management, Internal Audit, External Audit, E&C, ABC, investigations/interviewing, data analysis/interrogation, anti-fraud management experience and/or human rights and worker welfare.
• Practical experience in a multi-national company (preferably energy or oil/gas-related), and specifically conducting/leading operational audits, forensic audits and/or E&C investigations.
• Knowledge of the external legal/regulatory environment and latest trends in enforcement of anti-bribery laws – including a good knowledge of the U.S. Foreign Corrupt Practices Act (FCPA) and U.K. Bribery Act (UKBA).
• Familiarity with finance, supply chain, DD and HR processes/controls – including, preferably, working knowledge of the SAP business technology and Dow Jones DD platforms.
• Practical experience of conducting risk-based third-party E&C DD on individuals and entities, in accordance with applicable legislation and international best practice, preferably via the internationally-recognised ‘Dow Jones’ third-party risk management platform.
• Extensive overseas work experience – preferably with a focus on Africa, South America and other developing countries.
• Knowledge of best-practice E&C programs/frameworks and key processes/controls – including (but not limited to) Conflicts of Interest (COI), Gifts & Hospitality (G&H), Donations/Contributions, third party DD, Public Officials & Politically Exposed Persons (POs/PEPs).
• Practical experience of planning and conducting worker welfare inspections, audits, and assessments, in accordance with applicable legislation and international best practice
At Tullow, all individuals are treated fairly and respectfully, where everyone has equal access to opportunities and resources to contribute to Tullow’s overall success.
To Achieve This, We Offer Our Employees:
• Regular working from home in the UK, with at least two working days per week in the Chiswick office.
• Ability to manage working hours to balance work/life commitments.
• A performance-driven culture that generates results.
• A commitment to your personal and professional development.
• A chance to make a difference to our business, working in or leading teams of talented, committed people.
• A culture that appreciates inclusion & diversity and provides equal opportunities.
Recognition and reward for your performance.
Our philosophy is to bring people into Tullow with whom we can build a strong, mutually-beneficial, and long-lasting relationship. Working for Tullow will increase your knowledge, broaden your horizons, and extend your professional network. We offer a competitive reward package of base salary, incentives and benefits which is designed to attract, retain and motivate the best talent in our industry.
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