Ethics and compliance matters at SNC-Lavalin. We expect every employee to fully understand our policies and procedures, and to consistently put them into action, no matter how challenging the circumstances.
We’re proud of our robust Ethics & Compliance Program. External recognition of our commitment to the program’s principles and to our corporate values reinforces our conviction that we’re on the right path.
In 2017, we won major projects across Canada, including government contracts worth over $6.3 billion, a testament to our clients’ confidence in our ability not only to do the best job, but to do it ethically.
Oversight and reporting
Policies and procedures
Corporate policies provide guiding principles and rules for our entire organization, regardless of location.
Corporate Procedures, Processes & Work Instructions, on the other hand, standardize tasks and processes by specifying rules on a given subject or sets of instructions on how to perform a function. Policies have a broad and global application, while other corporate governance documents can be applicable to a specific geographical region, business unit or corporate function.
Our Policy Oversight Committee establishes good practices in corporate governance and helps review all new and revised policy documents. The committee meets monthly to review any policies and procedures being put forward. Members include the Policy Coordinator and a representative from the following corporate functions:
- Corporate risk management
- Ethics and compliance
- Global human resources
- Information technology
- Integrated management systems
- Internal audit
- Legal affairs
- Marketing, strategy and external relations
As part of our Operational Excellence initiative, we created the Project Delivery Centre of Excellence (PDCE), recently renamed the Capability Hub, a proactive and centralized online repository for employee knowledge sharing. Rolled out at the end of 2017, this hub enables employees to seamlessly share and interact with one another. It also supports transparent communication of our updated policies and procedures.
Our Duty to Report process requires all employees to be vigilant about possible illegal or unethical behaviour and to take appropriate and timely action to prevent or detect improper conduct.
At SNC-Lavalin, people can use our third-party, confidential, 24/7 Ethics & Compliance Hotline to report any suspected misconduct. The hotline allows employees, suppliers, clients and other stakeholders to report potential violations of our Code, company policies or applicable laws, either online or on the phone, in approximately 200 languages without fear of retaliation.
A committee composed of the Chief Compliance Officer, the Head of Compliance Investigations, the Compliance Legal Counsel, the Head of Internal Audit and a Human Resources representative meets on a weekly basis to review, assess and prioritize allegations of compliance violations. Once assigned to the Compliance Investigations team, the team:
- Implements appropriate investigation procedures including the use of specialized expertise as necessary
- Completes investigations in a timely manner to determine whether allegations are substantiated
- Respects and preserves the integrity of the Compliance Investigations’ processes at all times
Our highly experienced Compliance Investigations team reports to the Chief Compliance Officer. Team members are from different professional backgrounds and located in two main hubs, Canada and the Middle East, to ensure worldwide coverage and a timely response to investigating allegations.
Allegations in 2017:
Allegations made via:
New compliance cases opened: 507
New compliance cases opened based on anonymous allegations: 154
Compliance cases closed: 432
Disciplinary sanctions: 32, of which 9 resulted in termination, 6 in written warnings, 9 in verbal warnings and 8 in other sanctions
Code of Ethics and Business Conduct
Our Code of Ethics and Business Conduct lies at the heart of our Ethics & Compliance Program and sets expectations for integrity and ethics in our business dealings. Every manager at every level is accountable for ensuring we deliver a world-class ethics and compliance performance.
Reviewing the Code annually keeps this important document current. Yearly training and certification to the Code is a condition of employment and an intrinsic part of our onboarding program.
Annual training and certification
All employees (regular, occasional, temporary, contractual, full- and part-time), consultants, loaned personnel, officers and Board members receive annual training on our Code. Training for craft employees takes place throughout the year.
In 2017, we trained and certified more than 18,600 employees during this rigorous and ambitious undertaking. This included almost 1,300 individuals, or 7% of participants, who received in-person training.
Following the Atkins acquisition, we also trained and certified their more than 18,000 employees in the fall of 2017 to ensure they know and understand the expectations set out in the Code.
Training for non-craft employees is delivered online in nine languages. With the assistance of local managers and HR teams, employees at remote sites and/or with no internet access receive in-classroom training in three languages. The training includes real-life case studies inspired by compliance investigations and our Compliance Officers’ feedback.
In parallel with the content development, we develop the training processes and the communication plan, implement it in our systems and create the reporting tools. Throughout these activities, our team works closely with our Learning Management System team to ensure that all the tools are ready and easy to use and that our online process is running smoothly.
Craft employees (blue collar and construction workers) receive continuous training in eight languages on the 12 major aspects of our Code that impact them the most. This in-person training is delivered during monthly Health & Safety and other meetings. A facilitator gives a 10-minute presentation about one aspect of our Code including a real-life example. The presentation ends with a ‘Duty to Report’ message and pertinent contact information.
We take steps to ensure all our stakeholders receive clear and consistent messages, both internally and externally.
Internal communication activities and channels include:
- Ethics and compliance campaigns
- CEO blog
- Management and other meetings
- Annual performance reviews
Managers begin meetings with Ethics Moments to help reinforce our ethics and compliance culture. Like safety, integrity is top of mind for everyone and an integral part of meetings, planning and actions at all levels.
Externally, we provide stakeholders with detailed information on our ethics and compliance initiatives, our vision, plans and contacts for promptly addressing questions and issues. We also regularly share our ethics and compliance messages and commitments at:
- International and national conferences
- Universities, associations and ethics-based organizations
- Our Annual General Meeting of Shareholders
Business Partner Compliance Due Diligence
We take significant steps to ensure our business partners fully understand our ethics and compliance expectations. We expect our partners to adhere to our business principles, culture and values and comply with all applicable laws and regulations. In fact, all business partners must sign our Anti-Corruption Compliance Attestation, which commits them to abiding by the same standards of business conduct and practices as we do.
In 2017, we introduced our Supplier Code of Conduct in our business partner and procurement process. In 2018, this new process will replace the Anti-Corruption Compliance Attestation.
We actively foster a risk-aware culture at all levels across our organization. Through our business partner selection process, we continue to strive for a well-balanced and optimal risk-reward trade-off. Our Business Partner Compliance Due Diligence effort is supported by a state-of-the-art IT process. The approval workflow and its continuous monitoring provide global transparency on third-party risk exposure.
Business Partner Compliance Due Diligence (CDD) risk levels
The total number of approved Business Partner CDDs decreased by 24% in 2017 compared to 2016. The significant decrease in CDDs is due to a better evaluation of the scope of services rendered by business partners.
Business Partners CCDs by region
The geographic location of our business partners remained relatively stable across the board. The notable increase in North America and decrease in Europe are primarily due to regular shifts in development and projects in these areas.
During our annual Ethics & Compliance Risk Assessment process, senior management teams up with our compliance officers, directors, managers and subject matter experts in over 50 countries of operation to assess the compliance risks in their respective sectors, business units and regions.
We continuously cross-check our risk exposure against our compliance program to identify gaps and required adjustments. Based on the findings, we enhance our policies, procedures, communication activities and training materials to close any gaps.
In 2017, we enhanced our risk assessment approach by incorporating:
- Risk and control self-assessments deployed on a regional basis
- Optimizing workshops by synergizing efforts across the organization
We strive to remain at the forefront of emerging risks and respond to modern-day challenges effectively. This proactive approach is fundamental to mitigating across the full spectrum of potential threats for our stakeholders and surrounding environment. More recently, we’re evaluating our exposure to data privacy, a risk that threatens many international organizations.
Guarding against complacency
Since 2012, we’ve built and implemented a robust ethics and compliance prevention, detection and response system across an organization dispersed around the globe. Our training and communication plans ensure employees share our values, adhere to our ethics and compliance processes, and feel comfortable about voicing concerns.
And yet, our job is far from done. First and foremost, we must guard against complacency. Strong ethics and compliance cultures require constant attention. Maintaining a vibrant ethics and compliance culture also entails providing both existing and new employees with regular training.
As part of SNC-Lavalin’s Operational Excellence program, we’re continuously improving our Ethics & Compliance Program. We’re not only monitoring and ensuring the effectiveness of our systems and processes, but also assessing their efficiency in helping us achieve our business objectives. The end result will be seamless business processes that enable us to make timely and astute decisions, using integrated processes and, wherever possible, avoiding the duplication of tools.