Building what matters, sustainably – 2016 Sustainability Report

UK Modern Slavery Act Statement

UK Modern Slavery Act Statement by SNC-Lavalin entities captured by the statute

Introduction and business structure

Founded in 1911, SNC-Lavalin is one of the leading engineering and construction groups in the world and a major player in the ownership of infrastructure. From offices in about 50 countries, SNC-Lavalin's employees are proud to build what matters. Our teams provide engineering, procurement construction, consultancy, completions and commissioning services together with a range of sustaining capital services to clients in our four industry sectors, Oil and Gas, Mining and Metallurgy, Infrastructure and Power. SNC-Lavalin can also combine these services with its financing and operations and maintenance capabilities to provide complete end-to-end project solutions.

SNC-Lavalin maintains high standards for health and safety, ethics and compliance and environmental protection, and is committed to delivering quality projects on budget and on schedule to the satisfaction of its clients.

Within the SNC-Lavalin Group, the following companies operate in the UK and have a worldwide turnover that meets the threshold for disclosure:

  • SNC-Lavalin Rail and Transit Limited
  • Candu Energy Inc.

This statement is signed by these two subsidiaries, in accordance with the requirements of the Act.

Corporate policies and guidance documents

SNC-Lavalin’s Code of Ethics and Business Conduct lies at the heart of our Ethics & Compliance program and sets the expectations for integrity and ethics in our business dealings across all of our divisions, Sectors, business units, regions, and subsidiaries. Our Code is unequivocal when it comes to human rights:

“We believe that all human beings should be treated with dignity, fairness and respect.

“SNC-Lavalin is committed to supporting the protection and preservation of human rights throughout its worldwide operations and to ensuring that it is not involved in human rights abuses.

“We will not engage in activities that encourage human rights abuses or that support trafficking in persons or the use of child labour or forced labour. Moreover, we will never knowingly do business with subcontractors, business partners, suppliers or third parties who do not adhere to our principles regarding human rights.” 

In 2015, SNC-Lavalin adhered to the UN Global Compact and is always working on strengthening the processes required to ensure compliance to its guiding principles. 

Risk Assessment

As part of our commitment, we have conducted a preliminary risk assessment to determine which part or parts of our businesses could potentially be at risk of human rights abuses, and determined what processes exist to manage these risks.

While no region or country can be considered to be entirely risk free when considering human rights issues we are of the opinion that both SNC-Lavalin Rail and Transit Limited and CANDU Energy Inc. operate in low risk environments, in relation to issues addressed by the UK Modern Slavery Act.

It should be further noted that the nature of our business is such that we do not consider ourselves to be at risk of directly employing child labour. We have great respect for the labour laws in the countries in which we work.

Existing processes to manage this issue

Current best practices within SNC-Lavalin include:

  • Ensuring that employment contracts are negotiated and agreed to in the language of the candidate.
  • Wages are paid in a timely and consistent manner, in accordance with local laws.
  • Passports are not retained by the employer. However if specifically requested by an employee, the Company can provide safe custody of passports in fire & water proof lockers.
  • In countries where exit permits are required for an employee to leave the country, the Company issues such permits for employees on request.
  • When it is necessary to use recruiting agencies it is company policy to pay all placement fees; as well we demand that the recruiting agencies we use do not charge any placement fees to candidates. Deviation from this policy will lead to an inquiry by our Compliance Investigation team and termination of the relationship with that recruiter.
  • Existence of a grievance mechanism which enables workers to discuss the matter verbally in their own language or in English. There is an escalation procedure and a whistleblowing process which allows any employee to raise any concern anonymously, if they wish to be anonymous. 

Anti-Human Trafficking Training

In 2017, SNC-Lavalin Group Inc. launched an on line training program for employees in key positions on the subject of Avoiding Trafficked Labour. This e-learning training activity explains human trafficking and how to recognize it and proposes compliance strategies for our managers to use internally and throughout their supply chains. This training is mandatory for approximately 1,600 employees, including the entire senior management team, as well as managers and professional staff in the human resources, legal, and ethics and compliance teams. The leadership teams of SNC-Lavalin Rail and Transit Limited and CANDU Energy Inc. are included in this group.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes the statement of SNC-Lavalin Rail and Transit Limited and CANDU Energy Inc. for the financial year ended 31 December 2016.

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Richard George
Group Managing Director
SNC-Lavalin Rail and Transit Limited

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Preston Swafford
CEO, President and member of the Board of Directors
Candu Energy Inc.

1 Please see section 4.10.1 of our Code of Ethics and Business Conduct