Legal Counsel-ethics

**Legal Counsel
- Ethics**

**Purpose of the Job**

Legal Counsel
- Ethics of ENGIE India will ENGIE India, will act as the key Ethics Officer responsible for ensuring compliance with the highest standards of ethics and integrity within ENGIE’s India operations, fully aligned with Group policies and India’s legal framework

**Reporting line**

The Legal Counsel for Ethics will report to India General Counsel & Ethics Officer.

**Key Accountabilities**:

- **Ethics and Compliance Advisory**
- Acquire a good and precise understanding of ENGIE ethical documents, rules and policies
- Provide day-to-day advice and support on ethical and compliance matters across business lines including Procurement, Business Development, HR, Operations, and Finance.
- Ensure implementation and operationalization of Group Ethics policies and procedures locally.
- **Training and Awareness**
- Conduct ethics and compliance induction for all new joiners.
- Deliver refresher training programs on the Code of Ethics, ENGIE ethics policies related to Conflicts of Interests, Gifts and Hospitality, Human Rights, Sanctions/Embargo compliance, Prevention of Sexual Harassment and Data Privacy among the others.
- Organize and carry out annual training for all new directors in accordance with the Group’s Framework for Directors Guide;
- Promote a culture of integrity through regular engagement activities, workshops, newsletters, and campaigns.
- Design and launch new initiatives to embed ethics and human rights principles into day-to-day business operations.
- **Ethical Risk Assessment and Monitoring**
- Lead the Annual Risk Mapping Exercise on Ethics, Human Rights, Anti-Corruption, and Data Privacy for India operations.
- Monitor emerging risks related to sanctions, embargoes, human rights, and corruption.
- Prepare the Ethics assessment and memo during the development phase of projects (due diligence reports, partners’ checks, human rights reports for new countries etc.) and provide for AMEA HUB/Group’s approval
- **Investigations**
- Manage preliminary assessment and full investigations into allegations of misconduct, harassment, conflict of interest, and other breaches of ENGIE ethics policies.
- Conduct interviews, collect evidence, draft Investigation Reports, file the investigation reports on the Common Ethics Tool (CET), and support disciplinary or corrective action recommendations.
- **Due Diligence and Third-Party Reviews**
- Review due diligence checks on business partners, suppliers, and consultants.
- Analyze red flags identified during checks, propose risk mitigation measures, and document decisions.

**6. Internal Audit and Internal Control Coordination**
- Coordinate with Internal Audit teams on ethics-related audit findings and action plans.
- Actively participate in Internal Control exercises to assess compliance risks and mitigation measures.

**7. Sponsorships, Donations, and Charitable Contributions**
- Review and advise on ethical aspects of all donations, sponsorships, and CSR activities.
- Ensure proper approvals and documentation in line with Group and local policies.

**8. Data Privacy and Protection**
- Support Data Privacy compliance efforts, including awareness sessions, privacy notices, Data Protection Impact Assessments (DPIAs), and incident reporting.
- Ensure alignment with Group GDPR policies and India’s Data Protection regulations.

**9. Sanctions/Embargo Monitoring**
- Ensure compliance with Group policies on Sanctions and Embargoes, conduct risk checks, and provide clearance advice for new markets, suppliers, or partners.

**10. Group Policy Implementation**
- Ensure roll-out and local adaptation of new and existing Group policies related to ethics and compliance across Procurement, Business Development, HR, Legal, and Operations.

**11. Reporting and Documentation**
- Use Group tools such as the Common Ethics Tool (CET) for reporting incidents and following up on corrective action plans.
- Prepare periodic reports for AMEA and Group headquarters on key ethics KPIs, cases, and risk management activities.

**Key relationships are as follows**:
**Internal Interfaces**
- India General Counsel and Ethics Officer
- AMEA Ethics Officers and assistants
- Business Developers.
- Finance, HR.
- Group Ethics Department in Paris
- Officers of project company and Ethics Correspondents.

**External Interfaces**
- Contractual Counterparties: partners, suppliers.

**Qualifications**
- Legal Qualification and/or master’s degree from a reputable university.

**Experience**
- 8+ years legal or compliance practice.
- Corporate practice.

**Language**
- Excellent command of English

**Knowledge and skills**
- Strong professionalism and ethical standards.
- Strong writing & drafting skills.
- Ability to conciliate business requirements within a very highly demanding ethical environment.
- Ability to provide sound and practical ethical advice.
- Ability to deal with complexity.
- Organizational skills.
- Ability to work within a