‟Ethics and compliance is woven into the very fabric of our organization. Whether demonstrated in our annual employee certification program or six core values, we are committed to ethics and compliance excellence in all that we do.
The Tone from the Top
We turn words into action, starting at the top
“Tone from the Top” involves clear and consistent messages from the top leadership team, engaging middle management in compliance communications. This way the “Tone from the Top” becomes the “Tone in the Middle,” which we believe is essential for our program’s success. Compliance messages are included in regular management meetings and events, with the clear message that everyone is responsible for ethics and compliance.
We expect our management to lead by both word and deed.
Our aim of becoming a benchmark against which other companies measure themselves is a lofty one. That is why we have made compliance a key management responsibility. But it goes beyond the role-model function of senior management: all our managers must act ethically. And their business decisions and actions must always be in complete accordance with the law, our values and our policies.
Our Compliance Communication Team prepares a variety of Ethics Moments that all managers use at the beginning of meetings – an initiative modeled on our very successful safety program, which has become second nature and an inherent part of everyone’s thoughts, plans and actions. We want ethics and compliance to become second nature as well.
Our managers also have additional responsibilities under our Code, since they are responsible for promoting a culture of compliance and integrity. This includes a positive working environment in which people are treated with dignity and respect.
House of Policies
All our functions and business units are working to make our policies strong and keep them meaningful.
We launched a “House of Policies” initiative as part of a global mandate aiming to strengthen governance. It is a cross-functional effort that involves the support and commitment of all corporate functions and business units. The aim was to ensure that all policies and procedures across all spheres of the company are:
- Coherently applied;
- Aligned with corporate standards;
- Compliant with laws and regulations;
- Complete, pertinent and consistent in levels of detail and format;
- Reviewed and approved by the appropriate level of authority;
- Communicated appropriately; Available to all employees online; and
- Updated and reviewed on a regular basis.
Our Anti-corruption Policy
Our Anti-corruption Policy reinforces our commitment to the highest standards of governance, ethics and compliance.
The Anti-Corruption Policy is the umbrella policy for a set of Standard Operating Procedures (SOPs) that explain how to apply the policy to our business activities:
- Duty to Report SOP - Explains our duty to report in good faith, and without fear of retaliation, any known or suspected past, actual or potential wrongdoing or breach of our Code of Ethics and Business Conduct.
- Facilitation Payments SOP - Strictly prohibits the payment, authorization of payment, or the promise to pay, directly or indirectly, of any Facilitation Payment. Business Partners SOP Regulates the level of due diligence to be done on third party business partners and intermediaries before any engagement is permitted. Supported by a state-of-the-art IT tool that provides global transparency on third party risk exposure and continuous monitoring.
- Political Contribution SOP - Prohibits the use of company funds, property, services or resources in aid of political parties or for candidates for public office.
- Donations & Sponsorships SOP - Defines our charitable giving and sponsorship principles and priority areas. Establishes guidelines for funding decisions and the criteria against which requests for donations are evaluated.
- Gifts & Hospitality SOP - Provides guidance for employees when giving or receiving gifts and hospitality. The SOP is supported by helpful tools such as web-based and mobile applications to determine when giving or receiving is appropriate and permitted, especially when government officials are involved.
More than 5,700 employees received anti-corruption in-person training in the last three years
We implemented an extensive training program to create anti-corruption awareness at all levels. This in-person training is being provided in over 100 different sites worldwide to all employees who may have to deal with third parties.
We also offer online training on a variety of ethics-and-compliance-related topics through our Learning Management System.
All employees and consultants must also receive yearly training and certification on the Code of Ethics and Business Conduct, which is updated regularly. For our employees without access to a computer, training on the Code is offered in class with toolbox talks and pictograms.
In addition, following due diligence process and approval, all our business partners rated as medium- or high-risk are given mandatory anti-corruption training.
It takes clear and consistent communications to make a program thrive.
Internally, we use all possible communication channels to reach our employees with ethics and compliance messages, frequently and consistently.
Externally, we provide our stakeholders with detailed information on ethics and compliance initiatives, a list of contacts to promptly address questions and issues, and information on the company’s vision and plans for the future.
Here are some examples:
Ethics and Compliance Intranet Site
Our frequently updated intranet site offers useful information on ethics and compliance and is available in English and French. The information available includes:
- A list of our Services and Responsibilities:
- Business Partner Policy and CDD Tool Support
- Code of Ethics training and certification support
- Compliance Advice
- Compliance Control Framework - Policies and Governance
- Compliance Training
- Debarment Information
- Gifts & Hospitality Policy and scorecard support
- Ethics and Compliance Hotline for reporting an Ethics and Compliance issue
- All compliance-related policies and SOPs with related appendices and supporting documents
- Instructions for reporting violations of any of our policies or Standard Operating Procedures
- Links to the Code of Ethics and Business Conduct
- Compliance Material/Tools Library
- Training/Education Materials
- Team contact information
Pictograms have been specifically developed for use in presentations, posters and training in cases where employees cannot read or write in any of our official languages.
The Highlights of the Ethics and Compliance Program Brochure
This document contains the guiding principles of our program and how the prevent, detect and respond elements are applied to the way we do business.
Risk Assessment Workshops
Risk is a fact of life; it’s how we manage it that makes a difference.
Every year, each business unit, function and region holds Compliance Risk Assessment Workshops to determine appropriate risk mitigation measures and evaluate the effectiveness of our compliance program.
As a result, we continually improve our program through new policies, enhanced procedures, further communication efforts and new training material.
Mergers & Acquisitions Compliance Due Diligence
We want to make sure only ethical companies join our family.
We are often involved in acquiring other companies, making investments, and pursuing strategic partnerships and joint ventures. So it should come as no surprise that we perform a stringent due diligence before entering into any business agreement or relationship with any third party.
We want to help others avoid ethics and compliance pitfalls.
Collective action means getting together like-minded companies to focus on specific issues in ethics and compliance. We support global anti-corruption efforts and continue to encourage a constructive dialogue between governments, industries and business.
We also want people to hear our story, so they can learn from our experiences.
Some of the initiatives we are exploring as part of our collective action efforts are:
- Partnering Against Corruption Initiative (PACI)
- United Nations Global Compact
- TRACE International Canada
- Participation as panelists or speakers in over 30 conferences on Ethics and Compliance held in 10 countries
- Outreach and best practices sharing with competitors and the academic community
- Cooperation with Canadian Universities presenting Global Business Ethics