Since 2012, we’ve made great strides in establishing a strong ethics and compliance organization and program. In 2014, we brought our Ethics & Compliance Program to life by implementing numerous initiatives to help employees make the right decisions. In 2015, we focused on our House of Policies, revising and adopting several corporate policies to strengthen our governance framework.
New Duty to Report Standard Operating Procedure
In January, a new Duty to Report SOP was issued, requiring all employees to disclose in good faith concerns, complaints or allegations of wrongdoing or misconduct.
Launch of newly revised Code of Ethics and Business Conduct
In January, the newly revised Code of Ethics and Business Conduct was launched globally.
Code of Ethics and Business Conduct Certification
March brought the close of our annual three-month Code of Ethics and Business Conduct certification process. Once more, SNC-Lavalin’s Code was reviewed and updated and is now available in 11 languages. Every employee and consultant working for the company is trained on the requirements imposed by the Code on an annual basis. In 2015, we once more achieved 99.5% employee certification*.
*Employees in scope do not include craft labour
Updated Conflict Of Interest Disclosure Form
Third Annual Compliance Officer Meeting
New Corporate Trade Compliance Program
Our new Corporate Trade Compliance Program was launched in July through a trade compliance workshop to create clear trade compliance guidelines that will help employees make the right decision in challenging situations and create the necessary tools to achieve this.
Comprehensive Ethics and Compliance Risk Assessment of All Business Units Completed
Each Business Sector, Function and Region participated in our second comprehensive annual compliance risk assessment exercise to evaluate the effectiveness of our compliance program and discuss the risk mitigation measures in place or to be implemented.
New Anti-Corruption Policy
The New Anti-Corruption Policy replaces the Anti-Corruption Manual. The Policy reinforces SNC-Lavalin's commitment to the highest standards of governance, Ethics and Compliance, and sets forth its guiding principles on corruption and bribery. It is the umbrella policy for a set of SOPs that explain how to apply the policy to our business activities:
- Gifts & Hospitality
- Facilitation Payments
- Business Partners
- Political Contributions
- Donations & Sponsorships
- Duty to Report
New Standard Operating Procedure for the Hiring of Current or Former Government Officials or Their Immediate Family Members
The Standard Operating Procedure provides clear guidelines for hiring current or former government officials or their immediate family members, and is aligned with our Ethics & Compliance Program.
Settlement agreement with the African Development Bank Group (AfDB)
SNC-Lavalin reached a settlement with the African Development Bank Group (AfDB), following an approach by the Integrity and Anti-Corruption Department (“IACD”) of the AfDB and cooperation by SNC-Lavalin with the IACD. Under the agreement, SNC-Lavalin International Inc. will not be debarred, provided SNC-Lavalin meets certain conditions for a period of two years and 10 months.
New Antitrust and Competition Policy
The Policy promotes and ensures compliance with the highest levels of antitrust legal and ethical requirements, and preserves fair, honest and vigorous competition by helping employees recognize the kinds of conduct that antitrust and competition laws address.
United Nations Global Compact
SNC-Lavalin announced it joined the United Nations Global Compact (UNGC), the largest corporate social initiative in the world with more than 9,000 business and non-business participants in more than 130 countries. In addition to setting out a single global standard that transcends national, sectoral and regional standards, the UNGC promotes a sustainable approach to business and encourages companies in increasingly globalized markets to make universal principles and values an integral part of their strategies and actions. By joining the UNGC, SNC-Lavalin underscores its commitment to putting its extensive know-how and resources to work to meet the world’s sustainability challenges.