Compliance Manager - Commercial Services

Location: Gurgaon

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 practical knowledge of PCAOB expectations, Sox requirements, internal control over financial reporting, control design, testing, deficiency evaluation, and remediation.
• Demonstrated experience working directly with external auditors on walkthroughs, risk assessments, control identification and documentation, testing, audit evidence, deficiencies, and remediation.
• Strong knowledge of Commercial Services and related financial and operational processes, or the ability to develop this knowledge quickly.
• Experience providing independent Second Line oversight and constructive challenges.
• Experience supporting internal audit, transformation, automation, or continuous improvement initiatives.
• Working knowledge of relevant ERP systems; data analytics experience is desirable.
• Strong stakeholder management, analytical, written, and verbal communication skills.
• Experience providing functional leadership, coaching, or mentoring within a matrix environment.

Success Measures

• Stronger and clearer First Line ownership of Commercial Services risks and controls.
• Complete, accurate and current risk and control documentation.
• Effective and timely delivery of SOX and internal control testing.
• Improved testing quality, evidence, and assurance coverage.
• Timely and sustainable remediation of control deficiencies and audit findings.
• Reduced recurrence of control issues.
• Effective coordination with GIA and KPMG.
• Increased standardisation, simplification, automation, and Continuous Control Monitoring.
• Effective integration of controls into transformation and process-change initiatives.
• Clear and timely reporting of significant control matters.

About Rio Tinto

Rio Tinto is a leading global mining and materials company. We operate in 35 countries where we produce iron ore, copper, aluminium, critical minerals, and other materials needed for the global energy transition and for people, communities, and nations to thrive.

We have been mining for 150 years and operate with knowledge built up across generations and continents. Our purpose is finding better ways to provide the materials the world needs – striving for innovation and continuous improvement to produce materials with low emissions and to the right environmental, social and governance standards. But we can’t do it on our own, so we’re focused on creating partnerships to solve problems, create win-win situations and meet opportunities.

Respect and Inclusion

At Rio Tinto, we particularly welcome and encourage applications from Indigenous Peoples, women, the LGBTQ+ community, mature workers, people with disabilities and people from different cultural backgrounds.

We are committed to an inclusive environment where people feel comfortable to be themselves. We want our people to feel that all voices are heard, all cultures respected and that a variety of perspectives are not only welcome – they are essential to our success. We treat each other fairly and with dignity regardless of race, gender, nationality, ethnic origin, religion, age, sexual orientation or anything else that makes us different.