Senior Manager Compliance

At National Foods Limited, we are on a journey of growth and on building our most valuable assets which include our brands, financial strength, global presence, and our unbridled commitment to becoming a truly sustainable and a renowned company in the world.

Job Purpose:

To own and drive NFL’s ethics and compliance program – maintaining the Code of Conduct and related compliance policies, administering the integrity/whistleblowing channel, leading investigations into misconduct and policy breaches (outside matters governed by a mandatory statutory process), and building a culture of integrity across the organization, in close coordination with the business function and the Board Audit Committee.

Job Responsibilities: 

• Act as Policy Owner for the Code of Conduct and related compliance policies (anti-bribery/corruption, conflicts of interest, gifts & hospitality, whistleblowing, third-party due diligence), maintaining and periodically updating them in line with applicable laws, regulations and industry standards.
• Own and maintain Tier 2 compliance policies (e.g. Anti-Bribery & Anti-Corruption Procedures, Gifts & Hospitality Guidelines) under NFL's Policy Governance Framework, and provide subject-matter input into Tier 1 policy reviews (Code of Conduct, Whistleblowing Policy, Conflict of Interest Policy) as required.
• Monitor changes in laws, regulations and industry standards relevant to compliance, and ensure such changes are properly communicated across NFL and reflected in the relevant compliance policies in a timely manner.
• Drive company-wide communication and training so employees understand and apply compliance policies, and foster a culture of integrity and ethical conduct throughout the organization.
• Set the tone from the top on ethical conduct and foster an environment in which employees feel safe and comfortable reporting concerns without fear of retaliation.
• Administer the integrity/reporting portal as the central intake point for compliance-related concerns and disclosures, ensuring confidentiality, proper case triage and timely handling of reports.
• Monitor integrity portal usage trends and report on them to leadership and the relevant governance forums.
•  Lead or oversee internal investigations into reported misconduct, policy breaches or compliance violations – excluding matters subject to a mandatory statutory process – ensuring investigations are conducted fairly, consistently and in line with due process.
•  Coordinate with the Ethics Committee, People, Legal and business units as needed on investigations; document findings and recommend corrective/disciplinary actions.
• Where the respondent is a “workman” under applicable labour law, ensure disciplinary action is executed via the applicable chargesheet/show-cause/domestic-inquiry procedure to preserve enforceability before the Labour Court. 
• Immediately refer any complaint involving sexual harassment or gender-based discrimination to the statutory Inquiry Committee constituted under the Protection against Harassment of Women at the Workplace Act, 2010; ensure the Compliance investigation process is never used as a substitute for this statutory mechanism.
• Design and run NFL's overall compliance monitoring and testing program, and conduct compliance risk assessments across the business. 
• Report compliance metrics, incidents and trends to senior management and the Board via agreed governance forums, harmonizing escalation/classification thresholds with NFL's existing Investigation Protocol and Incident Management and Reporting Policy to ensure consistent Board Audit Committee notification timelines.
• Act as point of contact for sector/operational regulators, as agreed with the business, on day-to-day compliance matters.
• Maintain the Compliance policy inventory and version control, ensuring all policies within scope are current, accessible and clearly communicated to relevant stakeholders.   
• Escalate material breaches to the Board Audit Committee, maintaining a functional reporting line directly to the Audit Committee Chair for matters involving actual or potential senior-management misconduct, to safeguard investigative independence.
• Ensure that, where a matter is subject to a mandatory statutory process (e.g. the Inquiry Committee under the Protection against Harassment of Women at the Workplace Act, 2010, or the show-cause/domestic-inquiry procedure under industrial relations law), that statutory process is followed and takes precedence over the general Compliance investigation framework.
• Maintain a RACI clarifying Compliance vs. Governance accountabilities, to prevent overlap and ambiguity.
• Continuously assess and improve the compliance program and processes, benchmarking against industry best practice, to adapt to evolving regulatory requirements.

Preferred Qualification, Skills and Experience:

• Bachelor's degree in Law, Business, Finance or a related discipline, with 8 – 12 years of progressive experience in compliance, ethics, legal, audit or risk within a listed company or multinational
• LLB/Master's preferred; demonstrated experience running investigations and whistleblowing/integrity programs strongly preferred

Location:
Karachi, Pakistan

Grade:
M3

National Foods Limited provides equal employment opportunity (EEO) to all persons regardless of age, color, origin, physical or mental disability, race, religion, creed, gender, marital status, status with regard to public assistance or any other characteristic protected by federal, state or local laws.