SNC-Lavalin: Journey to Ethics Excellence

SNC-Lavalin: Journey to Ethics
Excellence
November 2015
A world leader
Founded in 1911, SNC-Lavalin is one of the leading engineering and construction
groups in the world and a major player in the ownership of infrastructure.
From offices in over 50 countries, SNC-Lavalin's employees are proud to build what
matters. Our teams provide EPC and EPCM services to clients in a variety of industry
sectors, including oil and gas, mining and metallurgy, infrastructure and power.
SNC-Lavalin can also combine these services with its financing and operations
and maintenance capabilities to provide complete end-to-end project solutions.
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SNC-Lavalin At a Glance
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Offices in over 50 countries – 40,000 Employees
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End-to-End Project Services Solutions
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Tier-1 Engineering and Construction solutions delivered across four key
markets:
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Infrastructure, Mining & Metallurgy, Oil & Gas and Power
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The 2012 Crisis Had Consequences
› Loss of reputation
› Charges were laid against former employees
› Share price fell drastically
› Lawsuits were filed against the company
› Loss of contracts and revenue
And, with regards to the World Bank:
› Suspension of the right to bid and work on projects financed by the World Bank, and
suspension of the right to receive funds from any loan made by the World Bank
› Cross-debarment of projects funded by AfDB (African Development Bank), ADB (Asian
Development Bank), IADB (Inter-American Development Bank) and EBRD (European
Bank for Reconstruction and Development).
› Term: 10 years (which can be reduced to 8 years)
› External monitoring by an independent monitor reporting directly to
the World Bank
Our ambition became to be the global benchmark
against which other companies measure
themselves
2015
2014
Employees were
trained and certified
on the Code
of Ethics
2013
2012
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Ethics and Compliance Hotline Available and Promoted
Key Leadership Changes
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Compliance is a key management responsibility
but also a fundamental prerequisite for all
Employees are
trained and certified
on the updated version
of the Code of Ethics
2015
2014
2013
2012
•
•
•
•
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New Chief Compliance Officer Function
Global Compliance Organization Fully Ramped Up
New 90-Day Amnesty Program
New Business Partners Policy
External Validation/Monitoring by Compliance Monitor Begins
New Anti-Corruption Manual Published
New Global Compliance In-Person Training Program
New Business Partner Compliance Due Diligence IT Tool
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Ethics and compliance principles, procedures and
controls are integrated into all key processes
Employees are
trained and certified
on the newly updated version
of the Code of Ethics
2015
2014
2013
2012
•
•
•
•
•
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New Gifts & Hospitality Procedure
New Facilitation Payments Procedure
Authorization by Autorité des marchés financiers (AMF)
to bid on public contracts in Québec, Canada
New Political Contributions Policy
Completion of Ethics and Compliance Risk Assessment
of all Business Units, Sectors and Corporate Functions
Ethics and Compliance becomes part of the
Compensation Process for Management
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Current focus: to maintain a company-wide
culture of integrity
Employees are
trained and certified
on the once again
updated version of the
Code of Ethics
2015
2014
2013
•
•
2012
•
•
•
New Duty to Report Procedure
Completion of the Second Ethics
and Compliance Risk
Assessment of all Business
Units, Sectors and Corporate
Functions
New Anti-corruption Policy
New Hiring of Government
Officials Procedure
New Antitrust Policy
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Compliance Is a Key Management Responsibility
›
This responsibility goes beyond the rolemodel function of senior management:
all our managers must exemplify ethical
behavior and compliance with law and
internal policies.
›
Ethics & compliance principles,
procedures and controls are firmly
embedded and integrated in all of the
key processes of SNC-Lavalin’s
operations.
›
The current SNC-Lavalin Compliance
Program encompasses all of SNCLavalin’s activities.
Neil Bruce, President and Chief Executive Officer
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Our employees adhere
to the Code of Ethics
›
Our Code applies to all employees, is
available in 11 languages and updated
every year.
›
Complying with our Code and its
underlying policies and procedures is
part of the terms and conditions of our
employees’ relationship with SNCLavalin.
›
On an annual basis, employees are
required to complete a certification
process to ensure that our Code is
understood and properly applied in our
daily activities.
›
We expect any third party we do
business with to share our values and
high ethical standards of conduct.
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SNC-Lavalin’s Ethics & Compliance Program
PREVENT
DETECT
RESPOND
Management Responsibility
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Tone from the Top
Policies and Procedures
Compliance Risk
Assessment
Training and
Communication
Support and Advice
Business Partner Due
Diligence
M&A Due Diligence
Personnel Processes
Collective Action
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Effective Control
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Disciplinary Sanctions
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Resources and Skills for
Global Investigations
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Regular E&C Audits
Unbiased Consequences
Remediation of Systematic
Deficiencies
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Compliance Review
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Prevention of Recurrence
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Ethics and Compliance
Hotline
Ethics and Compliance Organization
Independent Monitor/ External Validation
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SNC-Lavalin’s Compliance Control Framework
provides for independent and continuous testing
of the effectiveness of our Program
Doing the right thing
“Maintaining a reputation of integrity
depends on the actions of everyone in the
organization. By adopting positive
behaviour, we send a strong message that
our company is an upstanding organization,
worthy of the trust and respect of its
stakeholders.
›
My goal is to continue to work towards a
company-wide culture of integrity where
policies and processes are important but
the culture of integrity itself is sufficient for
all to know what is right and what is wrong.”
›
Dr. Hentie Dirker, Chief Compliance Officer
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Values that guide us
Our values keep us anchored and on track. They speak to how we run our business, how we express
ourselves as a group, and how we engage with our stakeholders and inspire their trust.
Teamwork & excellence
We’re innovative, collaborative, competent and visionary.
Customer focus
Our business exists to serve and add long-term value to our customers’ organizations.
Strong investor return
We seek to reward our investors’ trust by delivering competitive returns.
Health & safety, security and environment
We have a responsibility to protect everyone who comes into contact with our organization.
Ethics & compliance
We’re committed to making ethical decisions.
Respect
We consistently demonstrate respect for all our stakeholders.
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