Sustainability at work – 2014 Report

Prevent

Ethics & Compliance: Prevent

Ethics and compliance excellence starts with the tone set at the top. At SNC-Lavalin, senior management is engaged in and accountable for every step along our journey toward ethics and compliance excellence.

We strive to set and meet a higher standard for how ethics is integrated into the way we do business, along with greater transparency in our reporting to stakeholders.

The following Ethics & Compliance Program elements help us work toward achieving a Tier-1 ethics and compliance performance:

  • robust policies and procedures
  • effective compliance risk management
  • ongoing employee training
  • clear and consistent communication with all stakeholders
  • timely and knowledgeable support and advice
  • business partner and M&A due diligence
  • personnel processes
  • partnerships with external stakeholders
Every manager’s responsibility

All SNC-Lavalin managers must ensure that business decisions and actions in their areas of responsibility fully comply with relevant legal requirements as well as our own values and guidelines. We’ve also integrated ethics-and-compliance-related performance criteria into our compensation system. In summary, we expect our management to lead by both word and deed.

Policies and procedures

Our policies provide guiding principles and rules that apply to the entire organization, regardless of location. Policies are reviewed at least annually. Standard Operating Procedures help us standardize tasks and processes across our organization. Since 2012, we’ve revised or adopted several corporate policies to strengthen our governance framework.

In 2014, we established the ‘House of Policies’ governance framework as part of a global mandate to strengthen governance. It provides a mandatory policy and procedure development, rollout and implementation process for the entire company.

For more information, see the Highlights of the SNC-Lavalin Ethics & Compliance Program brochure.

graph-ethics-triangle-content
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.

  • In-person anti-corruption and compliance awareness training: ongoing at more than 100 sites worldwide. This 3.5- to 5-hour training session is mandatory for all general management, procurement, business development, project management and government relations staff. Almost 10% of the entire workforce has received in-person anti-corruption training to date.
  • ‘Tone at the top’ training: for all members of the Executive Committee, Operations Committee and Board of Directors.
  • 2015 Code of Ethics and Business Conduct certification: completed with all employees and consultants*.
  • Gifts and hospitality scorecard process training: ongoing with all employees, assistants and key users, as needed.
  • Third-party due diligence process training: ongoing with key users and approvers, as needed.

*Due to the Kentz integration process, certification of all Oil &Gas blue-collar employees will be completed on June 30, 2015, via in-person toolbox talks.


Communication

Infozone: our intranet

On our intranet, a frequently updated ethics and compliance section provides employees with useful information in English and French. It includes:

      • the Code of Ethics and Business Conduct
      • frequently asked questions and how-to’s
      • compliance process tools such as a business partner due diligence IT tool as well as gifts and hospitality scorecards
      • compliance policies and material
      • contact information for the compliance team and the Compliance Consultation Centre
Making sure we reach everyone
graph-ethics-code-content

In 2014, we developed a poster of pictograms for use as an aid in the Code of Ethics and Business Conduct training of our employees who do not read or write in one of our official languages.

Anti-corruption Manual

Published in September 2013, this manual complements our Code of Ethics and Business Conduct. It provides a concise overview of our approach to addressing and mitigating corruption risk in our daily business activities. It also sets out mandatory principles in the following key corruption risk areas:

  • gifts and hospitality
  • facilitation payments
  • political contributions
  • corporate charitable donations
  • sponsorships
  • business partners
  • recordkeeping
  • mergers and acquisitions, joint ventures and minority stakes


Due diligence

We established clear mechanisms for conducting thorough due diligence in several areas, including:

  • new hires on the leadership team and appointees to the Board of Directors
  • business partners (e.g. general contractors, subcontractors, agents, architects)
  • mergers and acquisitions

In every case, our goal is to ensure that our leaders, directors and partners share our commitment to ethics and compliance excellence.

Board of Directors

Over the past three years, our Board has undergone significant changes with the appointment of:

  • Robert G. Card (CEO), Chakib Sbiti and Eric Siegel in 2012
  • Jacques Bougie, Lise Lachapelle and Alain Rhéaume in 2013
  • Lawrence Stevenson as Chairman in 2015

Credible, independent consultants provided the due diligence for each of these hires and appointments.

Business partners

We strive to have transparent and clear dealings with the third parties we do business with.  Our objective is to consistently work with third parties who share our values and culture of high integrity. Before making any commitment with a business partner, we take steps to appropriately evaluate the relationship and mitigate any associated risks.

Our business partner due diligence process allows us to base our decisions on full transparency and accountability for third-party risk. Supported by a user-friendly IT solution, this rigorous risk-based process determines the depth of necessary compliance due diligence and the required level of authority for management approval.


Annual compliance risk assessments

Each sector, function and region now participates in an annual compliance risk assessment workshop. The workshop helps us assess the effectiveness of our Ethics & Compliance Program as well as identify appropriate risk mitigation measures.

Joining forces against corruption

We’re active members of the Ethics & Compliance Association (ECOA), the world’s largest body of ethics and compliance practitioners. Through the ECOA, ethics and compliance officers learn from each other and help foster a global commitment to ethics and integrity.

Since 2012, we’ve been a member of TRACE International. This non-profit organization is dedicated to advancing commercial transparency worldwide by providing anti-bribery compliance support. As a TRACE-certified member, SNC-Lavalin is a pre-vetted partner for multinational companies seeking to do business with organizations committed to transparent business practices.

Additional Outreach

We complement our outreach program by:

  • participating in best-practice-sharing workshops and meetings with the compliance officers of clients, competitors and other stakeholders
  • cooperating with Canadian universities teaching global business ethics

In 2014, we started exploring the following initiatives to further promote fair and equal market conditions:

Sharing knowledge

We’ve learned a great deal about what it takes to deliver a world-class ethics and compliance performance. In 2014, several academic institutions, national associations, global organizations and conference organizers turned to us to learn from our knowledge and experience.

Our ethics and compliance team continues to be very much in demand, openly telling our story at key meetings and events. We hope that sharing our experience will help other stakeholders in our industry improve their ethics and compliance processes, ultimately leading to a more level playing field.