Fractional Compliance Manager

Our client is media rights business from offices in London and Spain. As they grow internationally and work with a widening network of partners, buyers and suppliers, they are  putting in place a formal Corporate Compliance Programme, to be approved by its shareholders and operationally launched during 2026. We are seeking a fractional or part time Compliance Manager to lead with the following requirements. Purpose of the role The Compliance Manager is the independent owner of the Corporate Compliance Programme. The role makes sure the programme is designed, approved and embedded in day-to-day operations, gives the Board an objective view of compliance risk, and acts as the  main point of contact with our clients' compliance representatives. Independence and authority To be effective, the role needs sufficient independence, authority and seniority. In practice this means:

• A direct reporting line to the Board .
• Operating separately from Legal and all other internal functions, so that compliance judgements are made objectively.
• Access to the people, information and records needed to carry out the role.
• Clear escalation routes to the Board, set out in the compliance governance framework. Key Responsibilities:

1. Compliance governance and reporting

• Own and operate the customers compliance governance framework, including the Compliance Officer terms of reference, reporting lines and escalation and approval procedures.
• Report regularly to the Board on programme status, key risks, incidents and open actions.
• Prepare compliance reporting for our customer and their shareholders, using the agreed templates.
• Coordinate with compliance representatives in Spain and other countries as the main compliance contact.

2. Compliance risk assessment and controls

• Lead an initial compliance risk assessment, covering the business model, international activities, third-party relationships and key compliance exposures.
• Maintain the compliance risk map and the risk and controls matrix, classifying risks as low, medium or high and mapping existing and required controls.
• Drive delivery of the mitigation plan, working with control owners across both offices.
• Run periodic reviews and updates of the risk assessment in line with the agreed methodology.

3. Compliance policies

• Own the compliance policy framework, making sure every policy is approved, communicated, rolled out to the team and supported by documentary evidence of implementation.
• Policies in scope: Code of Conduct; Compliance Policy; Whistleblowing Policy and reporting procedures; Anti-Corruption Policy; Anti-Money Laundering Policy; Gifts and Invitations Policy; Travel and Expense Policy; Conflict of Interest, Confidentiality and Chinese Walls Policy (including its communications plan); Procurement Policy; Third-Party Engagement and Due Diligence Policy.
• Allocate clear responsibilities for each policy and keep them current as the business and its obligations change.
• Act as the first point of contact for colleagues with policy questions or approvals, such as gifts, invitations and potential conflicts of interest.

4. Third-party due diligence

• Oversee due diligence on partners, suppliers and other third parties, including verification of ultimate beneficial owners (UBOs), origin of funds and screening.
• Advise on, and escalate, higher-risk third-party relationships before commitments are made.

5. Whistleblowing and internal investigations

• Own the whistleblowing channel, including receipt and handling of reports, confidentiality safeguards and protection against retaliation.
• Lead or oversee internal investigations under the agreed protocol, managing conflicts of interest and following the agreed reporting and record-keeping requirements.
• Report on whistleblowing and investigation activity through the agreed governance and escalation routes.

6. Monitoring and review

• Take part in, and increasingly lead, the Compliance Monitoring Committee and review meetings with clients.
• Maintain the compliance implementation status report and action tracker, and follow up open actions to closure.
• Monitor adherence to policies and identify improvements to the programme over time.

7. Training and compliance culture

• Oversee the compliance training programme for directors, management and staff, tailored to the customers day-to-day operations.
• Make sure attendance is recorded and the effectiveness of training is checked.
• Build a culture where people feel able to ask questions and raise concerns, being a visible and approachable adviser to colleagues in both London and Madrid.

8. Working with the external compliance advisor

• Act as the  day-to-day counterpart to the external advisor during 2026, making sure deliverables are practical, proportionate and ready for approval.
• Take ownership of each deliverable as it is completed, so that the programme is run in-house once the advisor's engagement ends. What we are looking for: Essential
• Corporate compliance experience, in-house or advisory, including building or embedding a compliance programme.
• Practical experience across anti-bribery and corruption, anti-money laundering, conflicts of interest, whistleblowing and third-party due diligence.
• Working knowledge of the UK framework relevant to these areas, including the Bribery Act 2010.
• Experience reporting to a Board or equivalent governance body, and explaining risk clearly to non-specialists.
• Experience running or overseeing internal investigations with discretion and sound judgement.
• The independence and confidence to challenge senior leaders constructively, while staying pragmatic and proportionate for a growing, entrepreneurial business.
• Clear, concise writing and the ability to turn policy into practical guidance people actually use. Desirable
• Familiarity with Spanish corporate compliance expectations
• Spanish language skills.
• Experience in media, rights or entertainment.
• Experience working with shareholders, joint venture partners or group compliance teams.
• A recognised compliance qualification.