Head of Risk & Compliance
Circularity Scotland
March 7, 2022
Glasgow, United Kingdom
Job Type
Public Sector and Not for Profit
Internal Audit, Risk and Compliance


Circularity Scotland Limited (CSL) was incorporated in November 2020 and approved by the Scottish Government as the Scheme Administrator for Scotland’s Deposit Return Scheme (DRS) in March 2021. CSL is the vehicle set up by Members to deliver their collective legal obligations arising from The Deposit and Return Scheme for Scotland Regulations 2020, passed by the Scottish Parliament in May 2020. The legislation had cross party support when it was passed by the Scottish Parliament on May 2020, with an implementation date now set for the summer of 2023. The scheme is designed to encourage the maximum possible recycling of single-use drinks containers in the country as part of the Government’s commitment to the circular economy.

CSL is a company limited by guarantee whose members comprise the country’s largest drinks producers, retailers and relevant trade associations. It is regulated by the Scottish Environmental Protection Agency (SEPA). The company will work with organisations throughout the supply chain: producers, wholesalers, importers, retailers and the hospitality sector.

In full implementation CSL will have turnover in excess of £700m per annum and will have significant cash reserves primarily driven by the timing impact of receiving deposits from producers and paying out deposits to consumers. CSL will act on behalf of c4,500 producers to deliver their legal responsibilities. All costs of operating and funding the DRS are the responsibility of these producers through the contracted producer fee charged to them by CSL.

Scotland is following in the footsteps of more than 40 other countries with DRS implementation, and the governments at Westminster and Dublin are in advanced planning for their own legislation. CSL’s stated ambition is also to become the Deposit Management Organisation for the equivalent scheme, which is to be implemented in England and Wales, thereby ensuring a seamless DRS scheme right across mainland Britain and in so doing, delivering increased efficiencies through economies of scale. CSL has been designed to be capable of extending its operations to deliver that scheme – moving it to a company with turnover in excess of £5bn.

CSL will need to set up the processes, systems, infrastructure and staffing required to deliver those obligations by the agreed scheme Go Live date. The infrastructure required to deliver the management of logistical and financial transactions associated with three billion scheme articles will be significant and needs to be incredibly robust given the high volume of low value transactions.

There will be reporting requirements to a number of high-level stakeholders including Scottish Government, Scottish Environment Protection Agency (SEPA) and the members/producers themselves, many of which are large corporations. CSL is transforming from a ‘start up’ to a high-profile company of significant scale and complexity from day one of Go Live. In addition, CSL will need to operate and be able to demonstrate a robust ‘control environment’ and have processes in place to control fraud attempts.


The Role

The Head of Risk & Compliance will report to the Finance Director and also to the Audit Committee of CSL. They will be a key liaison with the appointed external auditors. Risk assessment and risk management requires the individual to work across all parts of the business and to develop a strong understanding of the business operations / systems / business partners / contractual relationships.

The main purpose of the role is to assess the business risks for CSL and to develop the control environment structures and processes to assess, score and mitigate business risk. The role will also be responsible for assessing and putting in place appropriate insurance cover.

Many of those risks are associated with our ability to comply with the range of standards, regulations and policies that affect the business environment in which we operate.  The role will ensure that we comply with current requirements; that there are processes in place to track any changes to those requirements; that there are controls in the appropriate parts of CSL to manage compliance and to provide the necessary level of reporting.

The Head of Risk & Compliance will be one of the senior managers within the finance team and will co-operate and collaborate with the other roles of Head of Accounting, Head of Financial Control, and Head of Fraud and Data to collectively deliver a robust and effective risk management resource for CSL.


Key Activities and Responsibilities:

CSL will manage the deposits received and deposit payments (of 20p) made on approx. 3 billion scheme articles. The Core DRS system will collect all the transactions which monitor the circular flow of the Scheme Articles from when they are deposited on the market by producers to when they are returned and recycled. These transaction flows will translate into finance transactions for billing.

CSL will outsource operations and logistics activities to a third party and will outsource the operation and maintenance of the core DRS IT system.

The Head of Risk and Compliance will review and assess the insurable risks covered in the contracts with these key business partners and will review their insurance cover to ensure compliance.

The Head of Risk and Compliance will identify and report the insurable risks to be covered by CSL and ensure adequate insurance is maintained.

This role will deliver the following for CSL: -

  • Develop the Risk Management System appropriate for the organisation; develop the appropriate set of risk registers; document, score and identify appropriate mitigations for all risks identified and ensure appropriate risk management practices are embedded throughout the organisation
  • Identify and track the range of standards and regulations to which CSL must comply and ensure the necessary change and risk management practices are in place
  • Business Continuity and Disaster Recover Plans; documented, assessed and tested periodically. Ensuring that similar plans are in place and managed / tested with our key partners
  • Internal Audit function
  • Business insurance
  • Key point of contact with external auditors and audit committee on internal control assessments
  • Communicate the results of audits / risk assessment of an audit via written reports and oral presentations
  • Influence key stakeholders on the requirement to improve and strengthen internal controls


The Individual

Qualifications and Experience


  • Qualified CA with at least 10 years post qualification experience working in a commercial role
  • Proven track record of building robust organisation control environments
  • Experienced in working across organisation teams to gain a detailed understanding of business operations, compliance requirements and potential risks
  • Highly organised, with excellent attention to detail
  • An energetic and enthusiastic self-starter with the ability to act on own initiative
  • Strong interpersonal skills and the ability to collaborate, guide and gain influence
  • Internal control/ internal audit experience
  • Experience of working with senior level staff and developing relationships with key stakeholders
  • Ability to analyse, evaluate and understand core IT systems and identify potential risks
  • Ability to drive continuous improvement of audit and control procedures


  • Knowledge of the drinks and/or waste management industries
  • Team building, Staff management and development
  • Previous start up experience
  • An interest in environmental issues


What to do next

To find out more or see a full Position Profile, please contact their retained advisor, Hazel Wynn at Rutherford Cross on [email protected].

An attractive financial package is available commensurate with background and experience required for the role. In addition to a competitive salary in the region of £70,000 per annum, 33 days annual leave (statutory days included) and benefits, you will work within a collaborative and social team focused on delivering results.

Depending on your qualification, location and preference, hybrid or remote working options are available.

Please note that any direct or third party approaches will be sent to Rutherford Cross for review and assessment.

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