‟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.
Policies and Procedures
At the end of 2017, following a huge simplification effort that has modified the structure and the content of our governance, we have revised all our policies and procedures to include only the right number of details. Documents are now shorter and detailed instructions have been created aside when specific guidance on a topic was needed. It is therefore easier for employees to find exactly what they are looking for.
As part of this initiative, a global glossary of terms used in SNC-Lavalin was created to avoid inconsistency between departments and clear definitions of terms used in our Code or in governance documents with a broad scope have been translated into up to 12 languages.
All these defined terms along with all the governance documents of the company are available in a common platform shared by corporate functions and business operations everywhere.
Our governance documents are reviewed each two years (if not requested otherwise by law, regulation or recent enforcement) and there is a roll-out plan for each significant modification (training, communication on our intranet).
Our Anti-corruption Policies
Our policy on Governance Framework provides rules to all employees regarding the respect of our commitments and our Code and compliance procedures reinforce SNC-Lavalin’s commitment to the highest standards of governance, ethics and compliance, and set forth the following guiding principles:
- SNC-Lavalin prohibits bribery and corruption in all its forms in all business dealings and relationships (including the public and private sectors), everywhere that the company operates.
- Use of SNC-Lavalin funds or other assets for any unlawful or improper purpose is strictly prohibited. SNC-Lavalin employees are expected to be vigilant in ensuring enforcement of this prohibition and the proper use of company assets.
SNC-Lavalin employees are also expected to comply in every respect with all applicable anti-corruption and anti-bribery legislation. A breach of applicable anti-corruption laws is a serious offence, which can result in considerable sanctions for both SNC-Lavalin and its personnel.
The following topics are included in our Compliance Governance:
SNC-Lavalin personnel has a duty to report any known or suspected, actual or potential violation of policies or procedures, applicable anti-corruption and anti-bribery legislation or any observed instances of misconduct, including pressure to compromise SNC-Lavalin’s ethical standards.
SNC-Lavalin does not tolerate retaliation against anyone who reports in good faith or raises genuine concerns in the best interests of the organization.
The payment, authorization of payment, direct or indirect offer, or promise to pay any facilitation payments or “grease” payments by employees of SNC-Lavalin is strictly prohibited.
In the unlikely event that an SNC-Lavalin employee would have no alternative but to provide a payment to protect against an imminent and serious threat to his or her health, safety or welfare, the demanded payment would be considered an extortion payment and would therefore be permissible under these exceptional circumstances.
Antitrust and Competition
Since it is not possible to cover all the different requirement levels of the applicable antitrust laws and regulations, the highest levels of antitrust legal and ethical requirements are promoted and the types of conduct that antitrust and competition laws address are described to ensure employees’ good understanding.
General principles and procedures need to be observed before entering into and over the duration of an agreement with any Business Partner.
SNC-Lavalin expects its Business Partners to adhere to its business principles, culture and values, and comply will all applicable laws and regulations. The Compliance Due Diligence of Business Partners is supported by a state-of-the-art IT process. The approval workflow and its continuous monitoring feature provides global transparency on third-party risk exposure.
Strict guidelines are applied with respect to making Political contributions. The use of SNC-Lavalin’s funds, property, services or resources for or in aid of political parties or candidates for public office is prohibited.
We do not retain the service of politicians for any business activities.
As a result of the ATKINS acquisition, employees in the United States of America (USA) may voluntarily contribute to the ATKINS Political Action Committee (PAC) in the USA. The ATKINS PAC complies fully with all USA campaign finance law and with SNC-Lavalin’s policies and procedures. The ATKINS PAC is supported entirely by employee contributions; accordingly, the ATKINS PAC does not use SNC-Lavalin funds, property, services or resources.
Donations, Sponsorships, Employee Involvement and Corporate Membership
A Donations and Sponsorships Committee is responsible for the evaluation and the approval of requests for donations and sponsorships to ensure that the funding of the social and community investment is globally aligned in accordance with the philanthropic and business objectives of SNC-Lavalin.
Gifts & Hospitality
Employees giving or receiving gifts and hospitality must .respect principles that are supported by helpful tools such as web-based mobile friendly application to determine when giving or receiving is appropriate and permitted, especially when government officials are involved.
Trade Compliance Procedure
SNC-Lavalin’s operations must be fully compliant with Export Controls and Economic Sanctions laws and regulations.
SNC-Lavalin is committed to respecting individual privacy laws. We will ensure that the use of personal information is always explained transparently and is used only for the purpose for which it was collected or to meet legal obligations.
Conflict of interest
Throughout the course of our work with the Company, conflicts of interest, whether actual, potential or perceived, must be avoided in the performance of our professional duties. Employees must ensure that they act in the best interests of the Company and its Stakeholders and not let other professional or personal interests influence our judgment and decisions.
Employees must complete a conflict of interest disclosure form when they first join SNC-Lavalin, then yearly except in the case where there is a change of situation that can be perceived as an actual, potential or perceived conflict of interest.
Guidance with respect to hiring current or former Government Officials or their immediate family members.
Accurate Record Keeping Guidelines
Accurate, complete and reliable records are crucial to our business as they guide decision-making and strategic planning. They are the basis of our financial reports and are necessary to fulfill SNC-Lavalin’s obligation to provide full and truthful disclosures to investors, stakeholders and regulatory authorities.
All our records must be complete, accurate, and reliable and prepared in accordance with applicable laws and regulations as well as SNC-Lavalin’s accounting and reporting governance.
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