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.
Here are some key measures we put in place as part of our ongoing quest for ethics and compliance excellence.
New Gifts and Hospitality Standard Operating Procedure
Issued in January, our new Gifts and Hospitality Standard Operating Procedure spells out the mandatory principles and procedures for exchanging gifts and hospitality with third parties. To simplify the process, we added the following helpful tools:
- a compliance scorecard for giving gifts and hospitality
- a compliance scorecard for accepting gifts and hospitality
- an entertainment benefit pre-approval form
We also implemented specific key-user training on the Gifts and Hospitality Policy as well as on compliance due diligence processes.
New Facilitation Payments Standard Operating Procedure
Approval by the Autorité des marchés financiers (AMF)
We issued a new Standard Operating Procedure to strictly prohibit facilitation payments, regardless of whether or not they’re tolerated in countries where we do business.
Also in February, we received approval from the Autorité des marchés financiers (AMF) to bid on public contracts in Quebec, Canada. The decision reflects our unwavering commitment to the highest standards in ethics, governance, compliance and accountability. It also recognizes our significant and ongoing efforts to implement an effective ethics and compliance framework at all levels of our organization.
Code of Ethics and Business Conduct certification
March brought the close of our three-month Code of Ethics and Business Conduct certification process. Every year, all employees must undergo Code of Ethics training and certify that they’ll abide by the Code’s provisions. In 2014, we achieved 100% employee certification.
Second annual compliance officer meeting
First Independent Compliance Monitor report
New Political Contributions Policy
In April, we held our second annual two-day, in-person meeting for our compliance officers and deputy compliance officers from around the world.
The following month, the Independent Compliance Monitor to the World Bank issued his first semi-annual report on our Ethics & Compliance Program. He visited our offices and interviewed employees around the world on the program’s implementation and effectiveness. He also measured the program against the World Bank Group’s Integrity Compliance Guidelines. The Monitor gave us a positive first review as well as valued recommendations for improvement.
We also issued a new Political Contributions Policy. It clearly states that the company doesn’t make political contributions. Exceptionally, in countries where permitted by law and if justified, political contributions require the prior written approval of our Political Contributions Compliance Committee and are reported to the Board of Directors on an annual basis
House of Policies
Due diligence for Kentz acquisition
In June, we launched the ‘House of Policies’ governance framework as part of a global mandate to strengthen governance. It establishes a mandatory policy and procedure development process, including roles, responsibilities and required approval levels. This initiative enhances control over the rollout and implementation of policies and procedures across the company.
Also in June, following extensive ethics and compliance due diligence, we announced our intention to acquire Kentz Corporation. We completed the acquisition on August 22, 2014. Kentz is a leading global oil and gas services company.
Ethics and compliance risk assessment
The ethics and compliance risk assessment workshops allow us to identify which risks present potential ethical opportunities and pitfalls. In 2014, we performed our first comprehensive annual compliance risk assessment exercise with key members of all business units, corporate functions and regions. It yielded a consolidated list of compliance risks. This list enabled us to pinpoint strengths and areas for improvement in our Ethics & Compliance Program.
Second Independent Compliance Monitor report
Ethics and compliance as part of compensation
In November, the Independent Compliance Monitor to the World Bank issued his second semi-annual report. His conclusions confirm that we’re on the right path in ethics and compliance.
We also made ethics and compliance part of our compensation process, underscoring the fact
that ‘doing the right thing’ is a priority.
For more information on our journey toward ethics and compliance excellence, visit http://www.snclavalin.com/en/ethics-compliance/