We’ve put a number of measures in place to identify misconduct and compliance gaps, including:
- more effective internal controls
- resources and skills training for global compliance investigations
- regular ethics and compliance audits
- regular compliance reviews
- periodic and ‘spot’ risk assessments
- external program reviews and assessments
- a confidential ethics and compliance hotline
- a Duty to Report procedure
When an issue arises, we investigate immediately. We get the facts, determine our legal exposure and resolve the problem. Our Duty to Report procedure and our ethics and compliance hotline help us enforce compliant behaviour and address misconduct.
We also set up a global team of highly trained and experienced investigators to look into compliance violations. This team is separate from our audit function and reports to the Chief Compliance Officer, who is responsible for overseeing the investigation process.
Investigators are located in Montreal, Toronto, Ivry-sur-Seine and Abu Dhabi. Together they speak nine languages. Their backgrounds range from forensic accounting and law to police enforcement.
Compliance control framework
In 2014, we began rolling out a compliance control framework to enhance the efficiency of our Ethics & Compliance Program. It entails independent and continuous testing of the effectiveness of all program modules. The framework includes internal controls for:
- clear authority, accountability and reporting
- effective accounting and financial reporting
As part of this process, audits and assessments are conducted to ensure compliance with anti-corruption policies as well as the framework’s overall effectiveness. Ongoing monitoring helps us make sure that our compliance measures adhere to evolving regulations.
Duty to report
Our Duty to Report Standard Operating Procedure (SOP) requires all employees to disclose, in good faith, concerns, complaints or allegations of wrongdoing or misconduct. Employees can speak with their supervisor, HR representative or compliance officer.
Our Compliance Consultation Centre provides relevant information and advice. Employees can also make use of our confidential ethics and compliance hotline from anywhere in the world, online or by telephone. We thoroughly investigate and address every complaint that has any substance.
In September 2014, a Montreal-based employee reported a competitor’s fraud attempt through internal channels. The competing firm’s employee wanted to sell information that would have given us an unfair and illegal advantage in the bidding process on a project. We worked closely with the police to identify those responsible for the attempted fraud.
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