Compliance Manager

Commercial Services Compliance Manager

Gurugram, India | Controls & Assurance

Purpose of the Role

The Commercial Services Compliance Manager provides independent Second Line oversight, challenge, and assurance across the Commercial Services control environment, covering both Sarbanes-Oxley compliance and wider internal controls.

The role works with Commercial Services leadership, process owners, and control owners to support effective risk assessment, control design, documentation, testing, and remediation, while reinforcing clear First Line ownership and accountability.

The role oversees Commercial Services control testing performed in India and coordinates relevant activities with Group Internal Audit (GIA), external auditors, and other assurance providers. It also provides risk and control advice and challenges for transformation, automation, transition, and continuous-improvement initiatives.

The role requires someone with recent and extensive PCAOB and SOx external audit experience, ideally gained at manager level or above within a Big Four firm or through an equivalent role. The role holder will apply this experience to strengthen control design and documentation, improve testing quality, anticipate external auditors’ expectations, and support technically robust discussions with external auditors.

The role provides functional guidance and coaching to junior team members and leads through influence in a matrix environment without direct line-management accountability.

Key Accountabilities

Risk and Control Framework

• Prepare risk assessments and control documentation within the scope of Commercial Services, liaising with relevant stakeholders to agree on scoping, key risks, and controls.
• Partner with process and control owners to design, document and maintain effective SOX and internal controls.
• Oversee the completeness and accuracy of Commercial Services Risk and Control Matrices and supporting documentation.
• Assess whether controls appropriately address identified risks and are sufficiently precise, sustainable, and evidence based.
• Identify control gaps, duplication, and unnecessary complexity, and recommend proportionate improvements.
• Reinforce First Line ownership and accountability for risks, controls, evidence, and remediation.

Testing, Assurance and Remediation

• Oversee and coordinate the Commercial Services Sox, internal control and substantive testing performed in India.
• Establish clear expectations for testing quality, evidence, documentation, and conclusions.
• Review testing outcomes and identify recurring issues or broader implications for the control environment.
• Support the evaluation of control deficiencies, including root-cause analysis and assessment of potential broader impact.
• Drive the development and implementation of practical, sustainable remediation plans with control owners, secure auditor agreements, and ensure timely closure.
• Collaborate with external auditors and internal stakeholders to drive data analytics and automation initiatives, including continuous control monitoring, to enhance assurance coverage and efficiency.

Audit and Stakeholder Coordination

• Coordinate Commercial Services engagement with GIA, management testers, and external auditors.
• Support responses to audit enquiries, evidence requests, and control observations.
• Constructively challenge audit findings where appropriate, using relevant evidence and a clear understanding of the control environment.
• Monitor audit actions and support their timely and sustainable resolution.
• Act as a trusted risk and control adviser to Commercial Services leadership, process owners, and control owners.

Escalate significant control issues, delays, and emerging risks to the relevant leadership.

Continuous Improvement and Change

• Identify opportunities to standardise, simplify, rationalise and automate controls and assurance activities.
• Promote preventive and automated controls where these provide a more effective and sustainable response to risk.
• Provide independent risk and control advice for Commercial Services transformation, transition, and automation initiatives.
• Support project teams with appropriate control requirements into new or changing systems.
• Ensure that control ownership is established, and material control gaps are addressed before transitioning into business-as-usual operations.
• Contribute to strategic and one-off Controls & Assurance projects affecting Commercial Services.

Functional and Matrix Leadership

• Provide day-to-day functional guidance, coaching and technical support to junior members of the Commercial Services compliance team.
• Promote consistent application of SOX and internal control methodologies.
• Foster collaboration, accountability, constructive challenges, and continuous improvement.
• Lead through influence across Commercial Services and the wider Controls & Assurance network.
• Champion Rio Tinto’s values of care, courage and curiosity and maintain high professional standards.

Reporting and Governance

• Prepare and review risk assessments, control assessments, deficiency evaluations, and remediation updates.
• Maintain clear and accurate documentation of significant control matters and conclusions.
• Prepare concise reporting on testing, deficiencies, remediation, audit actions, and improvement initiatives.
• Present relevant control and assurance matters to Commercial Services and Controls & Assurance leadership.

Experience, Skills and Qualifications

• Bachelor's or master's degree in accounting, finance, business administration, or related discipline.
• CA, CPA, or equivalent professional qualification is preferred; CISA or another relevant qualification is desirable.
• 10+ years of recent and relevant experience in PCAOB and SOx external audit experience is essential, ideally gained at manager level or above within a Big Four firm or through an equivalent role.
• Strong p