Ethics & Compliance

Ethics & Compliance FAQ

 


Over 65 concrete actions for solid ethics & compliance

 

Prevent

  • Clear and consistent messages from top leadership team
  • Engage Middle Management in compliance communication
  • Include compliance messages in regular management meetings and events
  • Management leads by word and deed
  • Encourage open communications
  • Reiterate that everyone is responsible for ethics and compliance
  • Recognize exemplary ethics and compliance behavior
  • Integrate ethics and compliance-related performance criteria in compensation system

All of our corporate policies are reviewed and updated biennially

The following Policies, SOPs and guidelines provide rules and instructions to all employees with respect to our ethics and compliance commitment:

  • Anti-corruption
  • Antitrust
  • Business Partners
  • Duty to Report
  • Facilitation Payments
  • Gifts & Hospitality
  • Investigation Protocol
  • Policy on Policies
  • Political Contribution
  • Sponsorships & Donations
  • Annual risk assessment workshops for each sector, region and function
  • Results are consolidated to help understand where we may be exposed
  • Continuous cross-checking against our ethics and compliance program to detect gaps
  • Appropriate adjustments made through new policies, enhanced procedures, further communication efforts and new training material
  • Mitigation measures are implemented through specific action plans

All employees and consultants must read the updated Code of Ethics and Business Conduct, undergo training and obtain their certification.

An extensive training program is fully implemented to create appropriate anti-corruption awareness at all levels. Mandatory in-person training sessions are provided to employees with likely third-party contact in over 100 different sites worldwide.

In addition, we offer training on the topics of Antitrust and Competition, Business Compliance Partners, Gifts and Hospitality, Insider Trading, among others.

    • Internal Communications
      • Frequent and consistent placement of ethics and
        compliance messages on the Intranet
      • Use of all possible communication channels
    • Ethics & Compliance Intranet Site
      • Useful information on compliance
      • Frequently asked questions
      • Compliance process descriptions
      • Compliance policies
      • Various online tools
      • Contact information for compliance
      • Available in French and English
      • Frequently updated
    • External Stakeholder Management
      • Clients
      • Business partners and suppliers
      • Governmental agencies
      •  Industry associations
      •  Media

Sector or Regional Compliance Officer: assigned to each of SNC-Lavalin's sectors and regions and are responsible for compliance matters and initiatives within their sector, corporate function or region

Compliance Consultation Centre:to reach compliance experts able to provide information or advice regarding how to address ethics and anti-corruption matters that may arise in the course of business

The anonymous Ethics & Compliance Hotline: to report a violation

The Ethics and Compliance intranet site: for access to various ethics and compliance resources, such as:

  • The Code of Ethics and Business Conduct
  • Policies and procedures
  • List of Compliance Officers and relevant key contacts
  • Latest news
  • Blogs
  • Frequently Asked Questions (FAQs)
  • Compliance Consultation Centre
  • Ethics & Compliance Tools, such as:
    • Business Partners Compliance Due Diligence Tool (BPC Tool)
    • Gifts & Hospitality Online Application (Scorecards)
    • Ethics Moments
    • The "Our Choice" video
    • Conflict of interest disclosure form
    • Deviation to Policy Documents tool
    • Full transparency and accountability for third party risk
    • Risk level of the proposed relationship between SNC-Lavalin and the Business Partner will determine the depth of necessary Compliance Due Diligence (CDD) and the required level of authority for management approval
    • Responsibility for CDD rests with the Sectors that wants to engage the Business Partner
    • Overall process is supported by a user-friendly IT-solution
    • Thoroughly analyzing the target company’s ethics and compliance standards in a dedicated Ethics & Compliance Due Diligence work stream
    • Measuring the target company’s ethics and compliance status-quo against the reference framework of the 11 Integrity Compliance Guidelines of the World Bank Group
    • Reviewing all ethics-and-compliance-relevant documents and information made available for an evaluation
    • Performing integrity checks on the target company’s senior management and ownership structure
    • Conducting in-depth personal interviews with the target company’s senior management, including the CEO, CFO, Chief Compliance Officer and other key functions
    • Developing a detailed integration plan along the identified gaps between SNC-Lavalin’s and the target company’s ethics and compliance programs
    • Screening and Due Diligence of Employees
      • Mechanisms established for screening and completing due diligence of new hires and appointees to the company’s leadership team
      • Services of credible, independent service providers have been retained for this purpose
    • Important part of non-financial objectives of the variable pay of senior managers linked to Ethics & Compliance
      • Program Implementation 
      • Program Execution: Evaluation of Ethical & Compliant Behavior
    • Performance evaluation criteria include E&C
  • Partnering Against Corruption Initiative (PACI)
  • United Nations Global Compact
  • TRACE International
  • Participation as panelists or speakers in conferences on ethics and compliance worldwide
  • Best practice sharing workshops and meetings with competitors, clients and other stakeholders

 

Detect

A control framework is a network of internal controls and testing procedures designed to provide assurance to management that certain risks are appropriately mitigated. Such a Compliance Control Framework has been implemented for independent and continuous testing of the effectiveness of all the SNC-Lavalin Compliance Program elements.

    • Expeditious investigation of potential misconduct
    • “Duty-to-report” policy clarifies that not reporting observed issues is in itself a violation
    • Highly experienced investigators, separate from internal audit function
    • Clear mandate for compliance investigations
    • Investigation reports are issued to the Ethics & Compliance Committee, which approves disciplinary sanctions and further preventive measures
  • The ethics and compliance program is constantly reviewed and enhanced

A compliance review is a comprehensive review of an organization's adherence to compliance rules and guidelines, including an evaluation of the strength and thoroughness of compliance preparations. The review of policies and procedures, user access controls and risk management procedures, training, communications, investigation processes and various processes are all typically part of a compliance review.

    • Multiple channels for reporting
        • The employee’s immediate supervisor or a more senior supervisor
        • Human Resources representatives
        • Legal Affairs representatives
        • Compliance Officers
        • The Ethics & Compliance Office
        • The Ethics and Compliance Hotline
        • The Compliance Consultation Center (CCC)

 

Respond

    • SNC-Lavalin applies consistent and meaningful disciplinary actions when wrongdoing is uncovered
    • Sanctions are swift and fair and the consequences are unbiased i.e. regardless of the person’s position within the company or their performance
    • Process Improvement
      • We examine the causes that were at the root of any control breakdown and perform a remediation of systematic deficiencies and/or harm to immediately stem any further consequences
      • This way, we ensure that risk is mitigated and controls are strengthened
    • Continuous Improvement
      • Encouraging open discussion and feedback
      • Debriefing on all incidents
      • Identifying “near misses”
      • Tracking remediation activities
      • Continuously look for improvement opportunities
      • Re-aligning policies and processes
      • Communicating lessons learned
      • Walking the talk and recognizing role model behavior