We continue to formalize our best practices and solidify them. Our Ethics & Compliance Program is there to help us act on our values. It is more than just a program – it’s a way of doing business.
We are proud of our Ethics & Compliance Program. Our dedication to its principles and our values has brought us concrete recognition that we are on the right path:
- We are signatories to the United Nations Global Compact and are committed to ensuring that our business policies incorporate and support the UN Global Compact’s Ten Principles.
- We have recently won major projects in Canada –including government contracts-- worth over $10 billion, underlining our clients’ confidence in our ability not only to do the best job, but to do it ethically.
- The SNC-Lavalin Ethics & Compliance Program has been recognized by Brazilian authorities and SNC-Lavalin is now registered as a Clean Company under the new Brazilian Clean Company Act.
- Our Chief Executive Officer was invited to join the World Economic Forum Partnering Against Corruption Initiative (PACI) Vanguard CEO community, which consists of 25 CEOs from various industries across the world collaborating in the fight against corruption. He also participated as a speaker at the World Economic Forum’s Infrastructure & Urban Development Governors Meeting in January 2015.
- We are regularly invited to speak worldwide about anti-corruption and compliance at both international and national conferences, including those hosted by Transparency International, TRACE International, the International Bar Association, C5 Group, International Anti-Corruption Committee of the American Bar Association, Kinstellar, the Engineering and Construction Risk Institute, Marcus Evans, IBC Legal, among many others.
- We are also regularly invited to speak at universities, associations and ethics-based organizations as experts on ethics and compliance, including Ethisphere, the Ethics & Compliance Officer Association, EthicScan and the Canadian Business Ethics Research Network (CBERN)
Code of Ethics
Our Code of Ethics & Business Conduct lies at the heart of our Ethics & Compliance Program and sets the expectations for integrity and ethics in our business dealings. It is reviewed annually to ensure it is always up to date. An intrinsic part of our onboarding program, annual training and certification on our Code is also a condition of employment. We even train and certify our Board of Directors. Every manager, at every level, is accountable for ensuring that we deliver a world-class ethics and compliance performance.
2015 Code certification rate*: 99.5%
Code of Ethics and Business Conduct available in 11 languages
*Employees in scope do not include craft labour
We ensure that all our stakeholders receive clear and consistent messages, both internally and externally. Our internal communications ensure frequent and consistent placement of compliance messages, rollouts of ethics and compliance communication campaigns and the use of all possible communication channels, from our president’s blog and management meetings to annual performance reviews and our intranet.
We prepare a variety of Ethics Moments that managers use at the beginning of meetings in an effort to drive culture change across the organization. As with our Health & Safety Program, which has become a focal point at departmental and company-wide meetings for more than ten years, integrity is now an inherent part of everyone’s thoughts, plans and actions.
Externally, we offer detailed information on ethics & compliance initiatives, list of contacts to promptly address questions and issues and information on the company’s vision and plans for the future. We also frequently and regularly communicate our ethics and compliance message at international and national conferences, as well as at universities, associations and ethics-based organizations. In addition, our President and CEO’s message to shareholders for at the Annual General Meeting of 2015 also included a clear ethics and compliance message.
Percentage of President’s monthly blogs in 2015 that addressed ethics and compliance: 100% (12 blogs)
Total number of page views in 2015 for the Ethics & Compliance section of the corporate website: 24,000+
Education and Training
We go to great lengths to ensure that employees everywhere understand and comply with the standards of conduct we expect of them. Training modules are constantly enhanced and integrated into the Learning Management System, including target-group-specific online training modules and general non-mandatory training for all. Ongoing training includes:
In-person anti-corruption and compliance awareness training. This 3.5-hour training session is being provided globally and is mandatory for employees in “sensitive roles,” including all executive, senior and general management functions, as well as all staff in business development, procurement, project management, general management and government relations.
Code of Ethics and Business Conduct certification. This training is completed annually by all employees (regular, occasional, temporary, contractual, full- or part-time, etc.), consultants, loaned personnel, officers and members of the Board of Directors of SNC-Lavalin.
Antitrust training. This training is mandatory for our employees in Senior Management, Legal Affairs, Business Development, Finance and Procurement.
Gifts and hospitality scorecard process training. This training is given to employees, assistants and key users, as needed. We also added two new e-learning training sessions on gifts and hospitality – one on the subject of offering gifts and hospitality, the other on receiving.
Third-party due diligence process training. This training is for employees working with business partners and involves instruction on using a due diligence IT solution.
Training of business partners. Certain of our business partners are required to undergo mandatory online anti-corruption training.
Employees that have received in-person anti-corruption training in 2015: over 1,700
Location of in-person anti-corruption and compliance awareness training: ongoing at more than 100 sites worldwide
Number of participants in third-party due diligence process training sessions in 2015: 1,050
Number of training sessions for business partners: 57
Compliance Consultation Centre
Our Compliance Consultation Centre is for employees seeking information or advice on how to address ethics matters that arise in the course of daily business. It is an easy and convenient way for employees to reach the Ethics & Compliance Team; however, the Centre is just one avenue of how employees can ask questions – most questions go directly to Managers and Compliance Officers.
Questions answered cover a large variety of topics, including anti-corruption, conflict of interest, corporate donations, data privacy and security, ethics and compliance, gifts and hospitality, human resources, insider trading, protection of company assets, workplace behavior and workplace health and safety.
Number of requests addressed by the Compliance Consultation Centre in 2015: 161
Business Partner Due Diligence
We make reasonable efforts to make our Business Partners are aware of our ethics and compliance expectations and thus encourage them to adopt principles and practices that are comparable to our own. All Business Partners must sign the Anti-Corruption Compliance Attestation which confirms their commitment to abide by the same standards of business conduct and practices as SNC-Lavalin.
We expect its Business Partners to adhere to our business principles, culture and values, and comply with 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 provide global transparency on third-party risk exposure.
Number of business partner compliance due diligences performed last year: 964
Percentage of low, medium and high risk level Business Partners:
- Low Risk 75%
- Medium Risk 20%
- High Risk 5%
Regions with the most Business Partners:
- North America (47%)
- Europe (17%)
- Middle-East and India (14%)
Sectors doing the most Business Partners compliance due diligences:
- Infrastructure (38%)
- Oil & Gas (29%)
- Power (16%)
Policies and Procedures
Corporate policies provide guiding principles and rules for the entire organization, regardless of location. Corporate Standard Operating Procedures (SOPs), on the other hand, provide rules on a specific subject or sets of instructions on how to perform a function with the objective to ensure the standardization of tasks and processes within the organization. Policies have a broad and global application, while SOPs can be applicable to a specific geographical region, business unit or corporate function.
Our Policy Oversight Committee, which establishes good practices in policy governance and assists in the review process for all new and revised policy documents, meets on a monthly basis to review new policies and procedures being put forward.
The Policy Oversight Committee consists of the Policy Coordinator and representatives of each corporate function: Corporate Risk Management, Ethics and Compliance, Finance, Global Human Resources, Integrated Management Systems, Internal Audit, Legal Affairs, Marketing, Strategy and External Relations.
Some of the policies, SOPs and guidelines providing rules and instructions to employees with respect to our ethics and compliance commitment are the:
- Antitrust and Competition Policy;
- Political Contribution Policy;
- Business Partners SOP;
- Donations, Sponsorships, Employee Involvement and Corporate Membership SOP;
- Gifts & Hospitality SOP;
- Hiring Current or Former Government Officials or Their Immediate Family Members SOP;
- Conflict of Interest Disclosure Guidelines; and
- Accurate Record Keeping Guidelines.
Number of new policies issued in 2015: 10
Number of new SOPs issued in 2015: 30
Areas affected by the new policy documents: Ethics & Compliance, Finance, HR, Legal, Integrated Management Systems, Communications
Our annual Ethics & Compliance Risk Assessment process involves top executives and senior managers in the Company – together with the relevant Compliance Officers – systematically determining and assessing the compliance risks to their sectors and business units.
The risk exposure is continuously cross-checked against our compliance program to detect gaps and appropriate adjustments required. Our policies, procedures, additional communication efforts and new training material are enhanced accordingly.
Number of participants in the 2015 risk assessment: 247
According to our Duty to Report Standard Operating Procedure, all our employees have a duty to be vigilant of circumstances that may indicate illegal or unethical behaviour and act both appropriately and in a timely manner to prevent or detect improper conduct.
We have provided employees with various channels for reporting any suspected misconduct. We’ve established a confidential hotline operated by an external service provider, which is available 24/7 for 365 days a year. This channel allows both employees and third parties (suppliers, clients, etc.) anywhere in the world to report potential violations of SNC-Lavalin’s Code of Ethics and Business Conduct, as well as any company policy or the law, without fear of retaliation. Reports can be made by telephone or going online.
In addition to the Ethics & Compliance Hotline, employees can contact their Managers, Compliance Officers, Human Resources Representative, Legal Representative or send an e-mail through the Compliance Consultation Centre.
How allegations were made:
- E-mail: 61%
- Online: 19%
- Ethics & Compliance Hotline: 10%
- Mail: 3%
- Telephone: 2%
Number of languages in which allegations can be made to the hotline: 170+
New compliance allegations in 2015: 414
Percentage of new compliance cases opened in 2015 based on anonymous allegations: 11%
Compliance cases closed in 2015: 72% (of 479)
Our outreach efforts focus on engagement with external stakeholders, including industry peers and clients, as well as ethics and compliance experts, to exchange best practices for effective compliance programs. They are part of our overall commitment to demonstrating our dedication to ethics excellence and integrity.
Our outreach efforts included best practices sharing with competitors and the academic community, working with Canadian Universities presenting global business ethics and participating as panelists or speakers in conferences on Ethics and Compliance. Our International memberships include the World Economic Forum’s Partnering Against Corruption Initiative (PACI), the United Nations Global Compact and TRACE International.
Number of ethics-and-compliance-related speaking engagements SNC-Lavalin took part in 2015: 32
Number of international speaking engagements: 15 (47%)
For more information about our Ethics & Compliance Program, please see our Highlights.