Legal Manager ? Compliance, Risk and Governance

PURPOSE OF THE JOB

Providing Group-wide leadership, coordination, oversight, and continual development of Samancor Chrome's Compliance Management System (CMS) in accordance with ISO 37301:2021, the Samancor Compliance Policy, the Legal Compliance Framework, and applicable legal, regulatory, and organizational requirements.

BALANCED SCORECARD PILLARS, ROLES AND RESPONSIBILITIES:

SAFETY, HEALTH, ENVIRONMENT AND QUALITY

• Identify and assess level of baseline- and issue-based risk exposures in area of responsibility by considering exposures to the business, financial and legal issues, people, equipment, material, environment, processes, etc.
• Consider the level of risk, apply mitigation and implement control measures for residual risk (set objectives, minimum requirements, etc.)
• Manage SHEQ compliance within the Department through effective use of the Toolbox
• Utilise the Integrated Management System (IMS) to analyse, identify trends, initiate, mitigate, investigate and report SHEQ status

PEOPLE

Manage the Department:

• Ensure an enabling climate/culture
• Manage labour stability by minimising labour turnover
  • Labour complement in line with budget
  • Achieve HDSA/Female targets for the Department
• Manage performance against set targets and competencies
  • Ensure IDP’s are linked to performance results and implemented as per plan
• Conduct career discussions and implement actions with all identified talent (quarterly)
• Ensure discipline is maintained (absenteeism, lateness, overtime, misconduct, etc.)
• Coach and counsel people to ensure improved performance levels
• Conduct recruitment interviews Training:
• Coordinate compliance awareness and ISO 37301 training across all relevant Samancor processes and sites.
• Evaluate the effectiveness of compliance training and awareness activities.
• Provide Champions with appropriate guidance, tools, training and support.

CUSTOMERS

• Maintain and improve relationships with key stakeholders
• Ensure customer and supplier satisfaction

BUSINESS PROCESSES

Serves as the principal organizational focal point for ISO 37301 and facilitates the integration of Group governance requirements with operational implementation.

• Lead the implementation, maintenance, evaluation and continual improvement of the Samancor ISO 37301 Compliance Management System (CMS).
• Ensure that the CMS remains integrated into Samancor's existing governance, risk, operational and management-system processes rather than developing unnecessary parallel systems.
• Coordinate implementation across all processes and sites and maintain Group-wide consistency while recognizing operational and regulatory differences between business units.
• Maintain organizational readiness for ISO 37301 surveillance and recertification audits.
• Coordinate the Group process for identifying, assessing, communicating and maintaining applicable compliance obligations.
• Work closely with Group Legal, operational specialists and relevant process owners to ensure applicable legal, regulatory, license, permit, contractual and voluntarily adopted requirements are appropriately identified and translated into manageable compliance obligations.
• Support an effective site-to-Group Legal regulatory-change interface, whereby operational sites and processes identify and communicate applicable requirements and changes for appropriate review and incorporation into Samancor's authoritative compliance framework.
• Coordinate a consistent methodology for identifying, assessing, treating and monitoring compliance risks and opportunities across all Samancor processes and sites.
• Ensure material compliance risks are appropriately incorporated into existing Group, process and site risk-management arrangements.
• Coordinate periodic assessment of internal and external issues relevant to the CMS.
• Facilitate a consistent Group-wide approach to identifying relevant interested parties and their compliance-related needs, expectations and issues.
• Ensure that significant interested-party requirements are appropriately linked to compliance obligations, risks, controls, communication and monitoring where applicable
• Work with process owners and site management to ensure appropriate controls are established for significant compliance obligations.
• Undertake or coordinate risk-based verification of control implementation and effectiveness.
• Promote integration of compliance requirements into existing procedures, management plans, operational controls, contractor management, procurement, change-management processes and other relevant business activities.
• Coordinate Samancor's compliance monitoring and measurement framework.
• Develop and maintain appropriate compliance objectives, KPIs, thresholds and reporting mechanisms in collaboration with relevant process owners.
• Analyze and report on matters including compliance status, regulatory changes, significant compliance risks, control effectiveness, breaches and incidents, overdue actions, audit results, corrective actions and emerging compliance trends.
• Prepare consolidated compliance and performance information for senior management and relevant governance structures.
• Promote an organizational culture of compliance, integrity and ethical conduct.
• Work with HR, Legal, SHEQ, management and other relevant functions to establish role-based compliance competence and awareness requirements.
• Facilitate regular engagement, cross-site learning, and communication on regulatory developments, emerging risks, good practices, and lessons learned.
• Compliance Champions support implementation but do not replace management or process-owner accountability.
• Ensure audit frequency and depth consider compliance risk, regulatory significance, previous performance, incidents, organizational change and previous audit results.
• Conduct or coordinate ISO 37301 internal audits where appropriate.
• Ensure auditors are competent and sufficiently independent of the activities being audited.
• Track findings, corrective actions, closure and effectiveness verification.
• The CMS internal compliance-audit programme should complement and not replace the independent third-line assurance role of Internal Audit.
• Coordinate preparation of ISO 37301 management-review inputs
• Track management-review decisions and actions through to completion and effectiveness.
• Coordinate CMS-related corrective action.
• Act as Samancor's principal organizational coordinator for ISO 37301 certification. Reporting
• Prepare monthly, quarterly and annual compliance reports.
• Present risk reports to Executive Management.
• Report significant compliance breaches and emerging risks.
• Develop dashboards and management information.

GROWTH

• Continuous improvement of the Samancor ISO 37301 Compliance Management System (CMS).

SHAREHOLDER VALUE

• Manage the Departmental budget

BEHAVIOURAL COMPETENCIES:

• Safety Leadership
• Innovation
• Strategic Leadership
• Strategic Planning, Organising & Control
• Results Orientation & Implementation
• Systematic Problem Solving & Decision Making
• Aligning Performance for Success
• Building and Maintaining Relationships
• Change Leadership
• Financial & Entrepreneurial Insight
• Adhering to Values

WORKPLACE COMPETENCIES:

Systems:

• Microsoft Programs
• Samancor Chrome Systems (IMS, EBMS, Chromedoc, MES, SAP, Coupa)

Knowledge:

• Demonstrate sound knowledge and practical understanding of:

  • ISO37301:2021 Compliance Management Systems
  • compliance risk assessment;
  • compliance obligations and regulatory management;
  • internal auditing;
  • corrective action and root-cause analysis;
  • monitoring, measurement and evaluation;
  • management review;
  • management of change;
  • document and record control

• Demonstrate an understanding of:

  • ISO 9011 – Guidelines for auditing management systems
  • ISO 3