Job Description:
Accountabilities:
• Be the focal point of T&S across Energy Market Regulatory Authority (EMRA) and Customs Authority.
• To ensure that Shell Turkiye is conducting T&S activities in full compliance with all national and international laws and regulations that pertain to its particular industry, as well as professional standards, accepted business practices, and Shell internal standards and rules (Shell Trade Compliance, Anti-trust rules).
• Work closely with global BIAM team under Global Supply and Commercial Fuels team, ensure T&S operations in Turkiye is fully complied with Shell E&C Manual.
• Keep up to date with, and understand, relevant laws and regulations (Petroleum Law, EMRA regulations, Customs procedures, Tax regulations).
• Inform related parties in company of the legislative changes, make impact analysis together with legal and business, ensure compliance with the new legislations.
• Lead T&S Assurance Team and ensure that all activities are compliant in a timely manner.
• Responsible of EMRA standard reporting for T&S and coordinate reporting process with other LoBs in the country.
• Prepare and file application for licenses, request necessary license amendments.
• Prepare and submit of EMRA tariffs and following approval procedure of tariffs in EMRA.
• Responsible for Customs & related tax procedures (including reporting) for T&S and give support other LoBs’ customs related issues.
• Responsible of managing Customs Agent firms.
• Contract owner of two Customs Agent.
• Responsible of import operations with customs advisor for the materials (marketing, eco-marathon etc.) which are not scope of T&S but of LoBs.
• Ensure that all backlog Bank Letter of Guarantees (BLG) which are given to customs by T&S dept. come to closed status.
• Supervise products team about BLGs release process.
• Ensure that all costs which effect customs declaration are declared correctly and timely.
• Responsible of providing correct and full data for customs/EMRA/tax investigations with assurance team.
• Responsible of providing monthly biodiesel ED refund tables with assurance team.
• Give support to E-recording project (for Ministry of Finance) with assurance team.
• Give support to PQ in managing Inspection companies.
• Give support to terminals about coast operation licenses.
• Liaise with The Scientific And Technological Research Council Of Turkey (TUBITAK) for National Marker applications.
• Responsible for keeping AEO (Authorized Economic Operator) license active for both STAS and SCTL. Represent & Manage STAS & SCTL customs audit across customs authority for AEO (every 2 year). Ensure activity report is prepared and submitted to customs authority in time (every year).
• Responsible from all National Marker (NM) operations including storage and distribution ensuring compliant reporting & provide assurance through detailed process checks and ad-hoc on site stock controls over national marker injection operations in STAS, JV & 3rd party terminals.
• Manage Independent Audit Company contract as contract owner for NM process.
• Keep update NM procedure and inform related parties about procedure changes.
• Compliance audit in all terminals about NM process once in a year. Report audit results to Supply Manager and Distribution Operations Manager.
• Assure that new terminals are compliant to NM procedure and report uncompliant subjects to Product Manager and Distribution Operations Manager.
• Provide assistance to internal or external auditors in compliance reviews.
• Being responsible of coordinating EMRA notifications for each license in STAS & SCT, communicating EMRA for notifications problem and new notification forms & system except retail dealers’ automation system notifications.
• Ensure that all EMRA fee declarations are submitted and paid correctly and timely.
• Give support T&S projects for compliance issues when needed.
• Contribute to the representation of T&S Dept. of STAS and JV terminals in various organizations including, Maritime & Transportation & Communication Ministry, Ministry of Finance and other governmental departments.
• To work closely with legal and tax department while aligning with Government Relations Advisor.
• To participate in EMRA workshops.
• To participate in PETDER Supply committee monthly meetings.
• To participate in PETDER LPG technical committee monthly meetings.
• To participate in TOBB Fuel Regulation committee monthly meetings.
• To participate in TOBB LPG Regulation committee monthly meetings.
• To participate in International Investors Association Customs Committee (YASED) monthly meetings.
• Represent Shell all PETDER, TOBB, YASED meetings and provide inputs.
• To participate and manage incident investigations related with EMRA and customs legislation.
• To be an active member of T&S LT.
• To participate TOBB, PETDER workshops.
• Carry out necessary legislative trainings for relevant staff.
• Fully compliant with ISO9001 Management Quality system and ISO27001 Information security management systems.
Dimensions:
• LoB:
o Shell & Turcas Petrol A.S.
T&S
Lubes
o Shell Company of Turkey
Aviation
Marine Lubs
Chemicals
• 3 direct staff
o 1 Customs Advisor
o 1 Senior Analyst
o 1 Assurance Analyst
• 3 customs agents (2 for fuel imports + 1 for base oil import/ lubes exports)
o Contract Size :3 Mln USD/year
• 1 National Marker Transport Contractor
o Contract Size: 0,3 Mln USD/year
• Figures:
o Volumes per annum: 5,95 Mln t
o Diesel grades 4.8 Mln t (3.7 Mln t Retail +1.1 Mln t Supply)
o Mogas:0,65 Mln t
o LPG :0,36 Mln t
o Jet A1 :0,10 Mln t
o Fame :25 Kt
o Ethanol:15 Kt
o LNG :1.5 Mln Sm3 -2018
o Fuel Import Volume per annum : 2 Mln t
• Supply points:
o Fuels: 3 company depots; 4 NOV depots; 5 OSPs
o Auto-LPG: 2 company depots, 5 OSPs, 24 ex-rack depots
o Time Charter Fleet: 1 vessel / Spot Rental Fleet: 2-3 vessels
• Penalties:
o NM : 2 M $ administrive fine per case and lose distribution license according to Petroleum Law. Jail time of 2-5 years for the persons in charge according to Anti-Smuggling Law.
o EMRA Notifications: 500 k $ administrive fine per case.
o Penalty is applied for missing Customs declaration. It is three times of the tax value.
• EMRA fees:
o Income Fee : Declaration and payment is monthly. Appr. 2 M $ per year.
o Participation Fee: Declaration and payment is yearly. 2 M $ per year.
• Licences are as below:
- Shell & Turcas Petrol A.S:
- Distribution License for Fuel
- Distribution License for LPG
- Transportation License
- 3 Depot License (Fuel)
- 1 Depot License (LPG)
- Lubricant License
- 2 Transmission License
- Shell Company of Turkey
- Distribution License for Aviation and Marine
- 2 Depot License
- Transmission License
• Permissions:
- Trade Permission Between Distribution Companies
- Ticket Permission
- Etanol Blending Permission
- Biodiesel Blending Permission
- Coast/Jetty Usage Permission
- Third Party Sales Permission (DAT)
