Ethics & Compliance

FAQ

  • 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
  • Policy on Policies
  • Anti-corruption
  • Business Partners
  • Gifts & Hospitality
  • Facilitation Payments
  • Antitrust
  • Political Contribution
  • Sponsorships & Donations
  • Investigation Protocol
  • Duty to Report
  • 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
    • Training
        • Mandatory In-Person Anti-Corruption Training for staff in General Management, Procurement, Business Development, Project Management and Government Relations
        • 4,059 employees were trained by means of more than 200 sessions to date in more than 35 countries
      • Code of ethics Certification:
        • By March 31, 2014, all staff and consultants were certified
        • By March 31, 2015, all staff and consultants were certified
      • Gifts & Hospitality Scorecard Process Training:
        • Over 37 training sessions given worldwide
      • Third Party Due Diligence Process Training:
        • 70 training sessions worldwide
    • 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
    • Compliance Officers
      • Promote an ethics-based culture in day-to-day business
      • Support Tone from the Top within sectors/regions
      • Encourage reporting of compliance violations and concerns
      • Offer education and training to raise awareness among employees on subjects relating to ethics and compliance
      • Provide compliance advice and support to employees
      • Develop and execute compliance operating plans within sectors/regions
      • Conduct compliance monitoring, oversight and reporting
      • Coordinate compliance input for acquisitions, joint ventures, and related transactions
    • Compliance Consultation Centre
      • E-mail address accessible directly or through the company intranet
      • Meant for employees seeking further information or advice on how to address ethics and anti-corruption matters that arise in the course of business
    • The Ethics & Compliance team offers support and advice to employees
      • Help with business Partner Compliance Due Diligences
      • Answer questions or offer advice regarding the application of or compliance with the Code of Ethics and related policies and procedures
    • 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 Business Unit 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)
    • Member of Transparency International
    • Participated as panelist or speaker in over 30 conferences on ethics and compliance held in a dozen countries
    • Outreach and best practice sharing with competitors, clients, suppliers and the academic community

 

Detect

    • Resources / skills for global deployment of compliance investigations
    • Independent and continuous testing of the effectiveness of all modules of the SNC-Lavalin Ethics & Compliance Program via the Compliance Control Framework
    • 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
    • Regular compliance reviews
    • Periodic and “spot” risk assessments
    • External review and assessment of the program
    • 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