Compliance Manager for Sustainability

Tone from the top / Tone from the middle

• Ensure and documents regular instances of management communicating on the importance of sustainability compliance. (I/ coordinate with Sustainability and functions when they issue sustainability communications).
• Communicate log of any such messages to the relevant authorities on request.

Regulatory watch and advocacy

• Coordinate with Sustainability Legal and Platforms on their regulatory watch whether directly or through trade associations
• Build up an internal and external advisory network to acquire an in-depth knowledge of sustainability obligations applying to LDC in each jurisdiction.
• Engage with government and public officials w/ Sustainability and Platforms ahead of the definition of the regulations or of the guidance to try to push for pragmatic obligations.

Policies and procedures

• Ensure LDC has proper SOP in place related to EUDR CS3D etc. compliance review them regularly to reflect change in regulatory requirements or new risks identified
• Ensure compliance controls and processes are embedded into policies and procedures issued by Sustainability and Platforms.
• Embed sustainability compliance procedures and controls into LDCs systems and / or automate them to minimize associated administrative workload and facilitate their monitoring.

Third party due diligence

• Ensure KYC is performed and documented by platform sustainability in accordance with relevant legislation.
• Define specific risk based parameters beyond which Sustainability Compliance review is needed to finalize the KYC
• Ensure KYC criteria are embedded in LDCs front and back office systems whenever feasible and that KYC processes are automated when possible in order to limit time constraint for commercial and operations.
• Engage with KYC providers of reference to screen our counterparts and transactions against watchlists.
• When traceability is guaranteed through certificates and / or third parties ensure that the information provided is complete accurate and from reputable surveyors.

Risk assessment

• Define risk assessment criteria aligned with the higher risk commitments and LDCs geographical footprint taking advantage of available information and / or external sources.
• Perform a risk assessment (or use existing ones e.g. Human Rights) on the basis of the third party due diligence and other information in order to only put on the market product when there is only a negligible risk of non-compliance.
• I/ liaise with communications to obtain a media / other sources watch on higher risk areas to ensure risk assessment is up to date.
• Conduct on site visits of higher risk areas and suppliers.

Training

• Embed compliance considerations in Sustainability E-learnings (whether for internal purposes or for LDCs supply chain)
• If needed consider building an eLearning for downstream actors customized for product country and risk.
• Conduct one to one or group trainings in higher risk areas.

Continuing advice

• Liaise with Treasury / Insurance to ensure banks and / or insurers are not forcing sustainability compliance commitments which go beyond our legal obligations.
• Liaise with platforms to ensure our contractual obligations upstream and downstream do not go beyond what we can reasonably commit to.
• Engage with commercial and operations when there is a doubt on the compliance of a proposed transaction ensuring the right balance between commercial / sustainability objectives and compliance risk.

Incentives

• Communicate on the need to align incentives with sustainability compliance (eg avoiding unreasonable sustainability commercial objectives which can provide an implicit incentive to bypass compliance with sustainability obligations).

Communication

• Liaise with Sustainability Treasury and Insurance to communicate when required with banks insurers NGOs and other externals about the strength of the sustainability compliance program.
• Liaise with finance to ensure external ESG / sustainability reporting is aligned with sustainability compliance program.

Confidential reporting

• Ensure EthicsPoint hotline is properly set up to handle sustainability / supply chain grievances
• Reallocate EthicsPoint grievances received to Sustainability or Platforms with due regards for confidentiality and conflict of interests
• Follow up on the resolution of grievances received
• Adjust risk assessment and communication based on the geographical footprint and nature of the grievances received

Public reporting

• Together with Comms Media and Platforms actively monitor media NGO reports and other sources to identify new emerging risks.
• Document public reports/grievances and company responses with a similar process as the concerned raised through EthicsPoint.

Investigation

• Mandate Internal Audit and / or external audit providers to investigate reliable grievances and allegations.
• Ensure the root causes of misconduct or policy breaches are analyzed and remediated.
• Amend risk assessments and processes based on the findings and responses emerging from these processes.
• When an allegation is confirmed coordinate with Legal on the communication of the conclusions to the competent authority when compulsory.

Disciplinary measures

• Ensure breaches of sustainability compliance result in effective proportionate and dissuasive disciplinary measures.

External reporting

• Ensure integrity of any external reporting system.
• Communicate to competent authority whenever LDC  obtain or is ()made aware of relevant new information including substantiated concerns indicating that a relevant product that they have placed on the market is at risk of not complying with this Regulation

Internal Audit

• Coordinate with Internal Audit to ensure sustainability compliance controls are embedded in Internal Audits work programs
• Make sure that an internal audit of the sustainability compliance program is conducted on a regular basis (or alternatively an external assessment)

External Audit

• Ensure LDC is ready for any check by a competent authorities considering that these are expected to be conducted without prior warning.
• Interact with the competent authorities when they conduct an annual check or an ad-hoc investigation.
• Interact with external auditors in their audit of the Integrated Report

Monitoring and periodic testing

• Ensure non-compliant counterparties are blacklisted through integration with MDM and other master data systems.
• Build up automated screening for payments and contracts to non-compliant counterparties information when feasible.
• Perform analytical reviews and / or data analytics on transactions to monitor for atypical flows (eg above average profits purchases abnormal compared to expected volumes from the supplier abnormal patterns on traceability )
• Perform a technical watch on available forensic techniques (eg chemical or DNA analysis) and conduct periodic forensic tests on LDCs products.

Mergers and acquisitions

• Perform a pre-deal review of key acquisitions or JVs to make sure the sustainability compliance profile of the target is aligned with our policies or taken into consideration in the negotiation for pricing and remediation.
• Perform a post-deal review to ensure LDCs sustainability compliance program is properly integrated.

Education and experience

• Ideally agriculture engineer or similar
• Master in audit or similar
• Ideally experiences in sustainable development projects
• Minimum of 7 years experience 

Languages

• French (fluent in both oral and written)
• English (fluent in both oral and written)
• Any other language is advantageous

Additional information

What We Offer

We provide a dynamic and stimulating international environment which will stretch and develop your abilities and channel your skills and expertise with outstanding career development opportunities in one of the largest and most solid private companies in the world.

Our Benefits

• Competitive salary and benefits
• Hybrid work available (not applicable to all roles)
• Pension contributions
• Access to Training and Development 
• Access to Concierge Partnerships

Diversity & Inclusion

LDC is driven by a set of shared values and high ethical standards with diversity and inclusion being part of our DNA. LDC is an equal opportunity employer committed to providing a working environment that embraces and values diversity equity and inclusion.

LDC encourages diversity supports local communities and environmental initiatives. We encourage people of all backgrounds to apply.

Sustainability

Sustainable value is at the heart of our purpose as a company.

We are passionate about creating fair and sustainable value both for our business and for other value chain stakeholders: our people our business partners the communities we touch and the environment around us

Additional Information :

What We Offer

We provide a dynamic and stimulating international environment which will stretch and develop your abilities and channel your skills and expertise with outstanding career development opportunities in one of the largest and most solid private companies in the world.

Our Benefits

• Competitive salary and benefits

• Flexible working

• Access to Training and Development

• Discretionary Bonus

• Profit Sharing plan

• Lunch vouchers

• Public transportation refund 

• Workers council social benefits

• Legal annual paid leave up tp 14 days RTT

Diversity & Inclusion

LDC is driven by a set of shared values and high ethical standards with diversity and inclusion being part of our DNA. LDC is an equal opportunity employer committed to providing a working environment that embraces and values diversity equity and inclusion.

LDC encourages diversity supports local communities and environmental initiatives. We encourage people of all backgrounds to apply.

Sustainability

Sustainable value is at the heart of our purpose as a company.

We are passionate about creating fair and sustainable value both for our business and for other value chain stakeholders: our people our business partners the communities we touch and the environment around us

Remote Work :

No

Employment Type :

Full-time