Code of Conduct 2019 - SNC-Lavalin
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Code of Conduct 2019
VALUES THAT Safety
We put safety at the heart of everything we do, to safeguard people, assets
GUIDE US
and the environment.
Integrity
We do the right thing, no matter what, and are accountable for our actions.
Our values are the essence of our Collaboration
company’s identity. They represent how We work together and embrace each other’s unique contribution to deliver
we act, speak and behave together, and amazing results for all.
how we engage with our clients and
stakeholders. Innovation
We redefine engineering by thinking boldly, proudly and differently.
2 SNC-LAVALIN | CODE OF CONDUCT 2019 3
TABLE OF
CONTENTS
Values that Guide us 2 5 Protecting Our Assets 40
Making the Right Decision 8 5.1 Electronic Resources 43
1 Upholding Our Code 10 5.2 Confidentiality of Information 44
1.1 Everyone Is Involved 12 5.3 Intellectual Property 44
1.2 Compliance 13 5.4 External Communications 45
1.3 Living Our Values and Our Code 14 6 Reporting Violations and Complaints 46
1.4 SNC-Lavalin’s Commitment to you, and to all our stakeholders 15
6.1 Duty to Report 48
2 Focusing on Our People and Our Workplace 16 6.2 Internal Investigations 49
2.1 Mutual Respect in the Workplace 18
2.2 Health, Safety and Environment 18
2.3 Drugs and Alcohol 19
2.4 Security 19
2.5 Personal and Private Information 20
3 Avoiding Conflicts of Interest 22
4 Adopting Appropriate Business Practices 26
4.1 Antitrust and Competition 28
4.2 Anti-Bribery and Anti-Corruption 29
4.2.1 Facilitation Payments 29
4.2.2 Gifts and hospitality 30
4.3 Third Parties 31
4.3.1 Business Partners 31
4.3.2 Government Officials 32
4.4 Political Contributions 33
4.5 Lobbying 33
4.6 Money Laundering and Tax Evasion 33
4.7 Trade Compliance, Export Controls and Anti-Boycott 34
4.8 Insider Trading 34
4.9 Accounting Practices and Record Keeping 35
4.10 Engaging in Corporate Social Responsibility 37
4.10.1 Human Rights 37 Terms in blue, bold and italic in this document are defined in a glossary that can be found, among other
4.10.2 Community Engagement 37 Policies and Procedures mentioned, on our internal database: http://www.snclavalin.com/en/files/
documents/policies/integrity-glossary_en.pdf.
4.10.3 Donations and Sponsorships 38
Dear colleagues,
At SNC-Lavalin, we are committed to doing business the right way.
Our Integrity Program is a benchmark in our industry, and is an
integral part of our daily work and decision-making process. We
demand integrity and professionalism of ourselves, just as others –
MESSAGE
such as our shareholders and clients – expect it of us.
Our 2019 Code of Conduct is one of the many tools we’ve created
to strengthen our Integrity Program. The Code is a living document
FROM THE
that we improve upon annually, and it applies to each and every
one of us – from the Leadership Team and managers to employees
and in-house contractors. We are all responsible for adhering to the
Code.
PRESIDENT You are the voice of our company’s values, so please take the time
to read and understand the Code and encourage your colleagues to
do the same. We make hundreds of decisions every day, and while
most ethics-related decisions are made using good judgment, the
correct answer is sometimes unclear. The Code offers guidance on
the right thing to do when faced with those difficult situations. If
the answer is still unclear after consulting the Code, speak to your
manager, integrity officer or Human Resources representative.
I’m proud of the work we’ve done together over the last several
years to become an ethics and compliance leader in our industry.
Thank you for your commitment to operating with the highest
ethical standards, for fostering an environment that is based on
integrity and transparency, and for doing business the right way.
Neil Bruce
PRESIDENT AND CHIEF EXECUTIVE OFFICER
6 SNC-LAVALIN | CODE OF CONDUCT 2019 7
Our Code isn’t a collection of rules and it cannot cover every situation. It helps us use
our judgment and common sense to make the right decisions.
Some decisions are easy to make. However,
MAKING whenever we are unsure of any work-related
actions or decisions, we must ask ourselves the
THE RIGHT
following questions:
DECISION
›› Does it comply with SNC-Lavalin’s values and with our
Code and its underlying policies?
›› Is my action legal?
›› Is it fair, ethical and morally acceptable?
›› What is my “gut feeling” telling me?
›› How would it look if it were reported on the news or in
another public forum?
›› Would my reputation or SNC-Lavalin’s be negatively
affected?
›› Could someone perceive this as a conflict of interest?
›› Could my action (or inaction) put anyone’s health, safety or
well-being at risk?
If the answer to any of the above questions is not clear and obvious, or if we are
uncomfortable with our answer, we must seek guidance from the available resources
listed in the section entitled Contacts.
8 SNC-LAVALIN | CODE OF CONDUCT 2019 9
Pavillon Pierre Lassonde du Musée national des beaux-arts du Québec, concept
consortium OMA*AMO Architecture P.C. / Provencher Roy et associés architectes.
UPHOLDING
OUR CODE
10 SNC-LAVALIN | CODE OF CONDUCT 2019 11
1.1 Everyone Is Involved
SNC-Lavalin’s Code of Conduct (“our Code”) seeks to ensure integrity and transparency in
the conduct of our business and in our relationships with others. THE WAY
Our Code applies to all employees, individual consultants, loaned personnel, officers and
members of the boards of directors of SNC-Lavalin.
WE BEHAVE
MATTERS
Complying with our Code and its underlying policies is part of the terms and conditions
of our relationship with SNC-Lavalin. On an annual basis, we are required to complete a
certification process to ensure that our Code is understood and properly applied to our daily
activities.
We expect any third party we do business with to respect our values and high ethical
standards of conduct.
Our Code is reviewed and updated periodically and can be found on our website at
www.snclavalin.com, under Integrity.
Ma’aden Umm Wu’al Sulphuric Acid Plant and Power Plant
1.2 Compliance
As we operate all over the globe, we are subject to the laws of many countries and we must
comply with all of them.
When local laws allow behaviour that is not
permitted by our Code, our Code prevails.
Should there be a conflict that you do not know how to resolve, or should you be uncertain
about the application or interpretation of a law or regulation, SNC-Lavalin Legal team should
be consulted before any decision is made or action taken.
12 SNC-LAVALIN | CODE OF CONDUCT 2019 13
1.3 Living Our Values and Our Code 1.4 NC-Lavalin’s Commitment to you, and
S
No matter where we are and what we do, we are all, collectively and individually, the face
to all our stakeholders
of SNC-Lavalin. Behaving in accordance with our culture and values and adhering to our
Code are what will protect our reputation and safeguard our future, allowing us to continue NC-Lavalin promotes integrity and the highest ethical standards in all aspects of its
S
building what matters. Our culture, values and the way we work determine whether clients business. To ensure we all live by our values and comply with the obligations set forth in our
and business partners want to do business with us, and whether talented people choose a Code, SNC-Lavalin is committed to:
career with us.
›› Build and foster a corporate culture of integrity;
We are committed to support our people in adopting behaviours that are aligned with our ›› Create appropriate awareness of our Code at all levels;
Code, values and culture. Because we care about our people, clients and reputation, and
that sits at the heart of our culture, we commit to take the necessary steps and actions to ›› et up measures to prevent, detect and respond to unethical or non-
S
address non-compliant behaviours. compliant behaviour;
›› rovide globally available support, information and resources to help
P
The way we behave matters. Whether we’re working alongside colleagues, meeting with you in the application of our Code;
clients or attempting to attract new talent, we all represent SNC-Lavalin, and each other.
›› Continuously improve our corporate governance standards; and
How we interact with others is what defines us as a company, and each of us has a part to ›› rotect people who come forward in good faith with compliance-
P
play in maintaining and enhancing our reputation as one of the world’s leading engineering related concerns from retaliation.
and construction firms.
Each and every one of us must:
Work ethically and honestly, do what’s right, and comply with the Code, its policies and procedures and
applicable laws;
Act with integrity at all times and in all circumstances;
Encourage people to take personal ownership and responsibility for the things they control and the
decisions they make;
Take personal and professional pride in our work and its outcomes, and share the responsibility for doing
things right the first time and delivering on our promises;
Look out for our own health, safety and security and that of those we work with;
Treat others with respect and dignity, as we would like to be treated, and support a diverse workplace in
every aspect, which contributes to our collective success; and
Protect our environment, because the future depends on what we do today, and the communities we
work in, to ensure we have a positive impact.
We all lead by example and act as role models by adopting behaviours that support our
shared values.
14 ACR End Shield SNC-LAVALIN | CODE OF CONDUCT 2019 15
FOCUSING ON
OUR PEOPLE
AND OUR
WORKPLACE
16 SNC-LAVALIN | CODE OF CONDUCT 2019 17
2.1 Mutual Respect in the Workplace 2.3 Drugs and Alcohol
At SNC-Lavalin, we consistently demonstrate respect for all of our stakeholders. Our We must never be impaired by alcohol or drugs while on duty and are strictly prohibited from
day-to-day activities require us to interact with individuals of various ethnic backgrounds, consuming, selling or purchasing drugs at work.
cultures, religions, political convictions, ages, genders, disabilities and sexual orientations.
The diversity of our people is one of our greatest assets, allowing us to benefit from a Moreover, except as authorized by a member of the Executive Committee and always
variety of professional and educational backgrounds and points of view. Embracing those in accordance with applicable local laws, we are prohibited from consuming or serving
differences contribute to making us more agile and able to respond adequately to changes in alcoholic beverages on SNC-Lavalin premises.
our business environment and work in a collaborative manner.
Building and maintaining respectful and meaningful professional relationships by making For more information
constructive two-way communication, actively listening to others and engaging with people Consult the SNC-Lavalin Blue Book on health, safety and the environment.
creates a positive work environment where we can enjoy our work, progress our career and
develop our full potential.
We are all entitled to personal dignity, privacy and the preservation of our rights. Consistent 2.4 Security
with our values, we respect others and have zero tolerance for any behaviour or actions
that are violent, intimidating, hostile, degrading, humiliating or offensive and amount to
discrimination, harassment or violence. We are committed to protecting our people, assets and information wherever we operate in
the course of our business operations or during business travels.
Health, Safety and Environment
We will not knowingly engage in any business activity encompassing a security risk that
2.2 cannot be properly managed and reasonably mitigated. Nor will we do business with
any security provider that does not meet or adhere to our principles relating to security
standards and human rights.
In everything that we do, nothing is more important than the safety of everyone. SNC-Lavalin
is also equally committed to protecting the environment and aims to do business in an We are all accountable for following SNC-Lavalin’s Global Security Policy, procedures and
environmentally responsible and sustainable manner. protocols.
SNC-Lavalin ensures that the applicable workplace health, safety and environmental
For more information
legislation is treated as a minimum standard in all areas where we conduct business.
Consult our Policy on Consult our Policy on Global Security.
Our health, safety and environment program, which is based on hazard recognition, risk
assessment and the elimination of hazards, seeks to establish an incident-free work
environment. We are all accountable for ensuring that all employees go home safely at the
end of the day.
For more information
Consult the SNC-Lavalin Blue Book on health, safety and the environment.
18 SNC-LAVALIN | CODE OF CONDUCT 2019 192.5 Personal and Private Information
SNC-Lavalin is committed to respecting individual privacy laws. We will ensure that the
use of personal data is always explained transparently and is used only for the purpose for
which it was collected or to meet legal obligations.
All employees are responsible for ensuring personal data is protected, secured and kept
confidential and that personal data is only retained for as long as is necessary to achieve the
original processing purpose or to satisfy our legal and regulatory requirements.
The appropriate personal data processing is vital to the continued success of our business
and maintaining the trust of our clients, employees and stakeholders. We are committed
to the implementation and continual improvement of a framework, which ensures that
personal data is handled appropriately, consistently and in accordance with applicable Data
Protection and Privacy Law.
For more information
Consult our Data Privacy Compliance Policy.
20 Dubai Metro SNC-LAVALIN | CODE OF CONDUCT 2019 21AVOIDING
CONFLICTS
OF INTEREST
Pavillon Pierre Lassonde du Musée national des beaux-arts du Québec, concept
22 consortium OMA*AMO Architecture P.C. / Provencher Roy et associés architectes. SNC-LAVALIN | CODE OF CONDUCT 2019 23When an actual, potential or perceived conflict of interest is deemed to exist, management will
outline the measures required to remedy the situation. The information disclosed in the form will be
treated confidentially and made available only to individuals directly involved in assessing or managing
the conflict of interest.
EACH OF US IS
We must always:
›› Act and make decisions in the best interest of SNC-Lavalin;
›› ompletely and truthfully disclose, in a timely manner, all information related
C
RESPONSIBLE
to an actual, potential or perceived conflict of interest; and
›› bide by any mitigation measures implemented to remedy a Conflict of
A
Interest.
We must never:
›› e guided in our actions or decisions by our own personal benefit or that
B
of a family member or someone with whom we have a close personal
relationship;
›› llow ourselves to be in a position where we cannot be objective toward a
A
family member or close personal relationship, either by supervising them or
doing business with a company they fully or partially own or work for; and
›› roceed when we know or are unsure if a situation constitutes a conflict of
P
interest.
Some examples of situations that constitute a conflict of interest that must be
disclosed include:
Throughout the course of our activities, ›› We are engaged or will be engaging in secondary employment.
we must ensure that we always act ›› e accepted or will be accepting a directorship/non-executive position with a
W
in the best interest of SNC-Lavalin. for-profit or nonprofit third-party organization.
›› e established or will be establishing a business relationship with a
W
competitor, business partner, supplier or client of SNC-Lavalin.
We must not let our professional judgment and actions in relation to our duties and
›› e own or plan to own a significant financial interest in a competitor,
W
obligations toward SNC-Lavalin be unduly influenced by secondary interest that would
business partner, supplier or client of SNC-Lavalin.
financially, professionally and/or personally benefit us or a family member or someone
with whom we have a close personal relationship. We must therefore avoid any conflict of ›› e have an immediate family member who currently works at SNC-Lavalin
W
interest in the performance of our duties. or we are in a close personal relationship with someone who does.
›› e are/were or an immediate family member is/was a government official in
W
A conflict of interest, whether it is actual, potential or perceived, can expose SNC-Lavalin to
the last 5 years.
certain risks, such as decreased shareholder value, legal liability or reputational damage.
As such, we must immediately disclose a conflict of interest using the Conflict of Interest
Disclosure Form. This form is available on Infozone, our intranet, or through Human For more information
Resources. Consult our procedure on Conflicts of Interest.
24 SNC-LAVALIN | CODE OF CONDUCT 2019 25ADOPTING
APPROPRIATE
BUSINESS
PRACTICES
26 SNC-LAVALIN | CODE OF CONDUCT 2019 27Anti-Bribery and Anti-Corruption
We are vigorously competitive in all of our markets, but we are also fair and act in full
compliance with the law. Unlawful conduct is strictly prohibited. It is sometimes normal to 4.2
be unsure about the interpretation of a law or regulation or about the correct legal or ethical
action to take. SNC-Lavalin Legal or Integrity teams can be consulted to provide proper
guidance. SNC-Lavalin is committed to conducting business with integrity and we prohibit corruption
and bribery in all its forms. We must not, directly or indirectly, accept, request, offer, promise,
grant or authorize a bribe, kickback, payment or anything that can be considered as such
(gifts, entertainment, employment, contracts or benefits of any kind) to or from any third
4.1 Antitrust and Competition party that may or appear to influence action, inaction or a decision, with the intent to obtain
an improper advantage, retain business or obtain undue influence over that third party’s
actions.
At SNC-Lavalin, we must all engage in fair, competitive business practices which comply
with antitrust and competition legislation where we do business. These laws are generally We are all responsible for educating ourselves on how to recognize corrupt activities and
designed to uphold free and open competition in the marketplace. ensure that we are not involved in any such type of activities, whether directly or indirectly.
Prohibited behaviour includes discussions, collusion or agreements with third parties to, For more information
among other things:
Consult our procedure on Compliance
›› Fix or control prices, terms or conditions;
›› Restrict competition or dealings with suppliers or customers;
›› hare confidential information with competitors, business partners
S
or any other relevant party 4.2.1 Facilitation Payments
›› ivide or allocate customers, markets or territories between
D
SNC-Lavalin and our competitors; or Facilitation payments are unofficial payments (as opposed to legitimate and official fees
›› ot submit a bid, withdraw a bid or submit an artificial bid in order to
N or taxes) made to an individual for the purpose of securing or accelerating the performance
direct the winning bid to another bidder with whom we are colluding. of a service or a routine governmental action to which the person or company making the
payment is already entitled.
It is strictly prohibited from making any facilitation payments.
Entering into joint venture agreements with our
competitors in order to pursue project opportunities is If, however, in order to prevent an imminent and serious threat to our health, safety or
welfare, or that of a family member, we have no alternative but to provide a payment, this
not a violation of antitrust and competition legislation would be considered as an extortion payment and would be permissible under such duress.
unless it is deliberately meant to reduce competition.
Any such payments made under these exceptional circumstances must be accurately
reported to your manager, integrity officer and the appropriate regional security director
as soon as practically possible to ensure accurate recording of transactions and proper
For more information disclosure to the relevant authorities.
Consult our procedure on Compliance.
For more information
Consult our procedure on Compliance.
28 SNC-LAVALIN | CODE OF CONDUCT 2019 294.2.2 Gifts and hospitality 4.3 Third Parties
Gifts and marks of hospitality are courtesies which are part of normal business practices
In our business, third parties with whom we interact typically include:
but which can be considered as forms of bribery or influence peddling. We can offer or
accept occasional gifts, meals or entertainment that are unsolicited, reasonable in value and ›› Clients
compliant with the law, our Code and its underlying policies.
›› Competitors
You can offer, accept or exchange gifts, meals or entertainment as long as: ›› Suppliers
›› enefits are not illegal, indecent or offensive in any way, involve
B ›› Government officials
gambling, or otherwise violate our values or the standards put
forward in our Code of Conduct and our policies; ›› usiness partners (further described in Section 4.3.1 – Business
B
Partners)
›› enefits are not given or received, directly or indirectly, in exchange
B
for any improper advantage or expectation that a business
At SNC-Lavalin, we strive to deal transparently and accurately with third parties. We want to
relationship will be unjustly influenced;
work with third parties who share our values and culture of high integrity and expect them
›› enefits are reasonable in value, appropriate to the occasion, and
B to embrace and implement practices that are consistent with our Supplier Code of Conduct.
appropriate to the position and management levels of the provider We will never contract or deal with a third party in order to do indirectly what our Code of
and recipient; Conduct prohibits us from doing directly.
›› enefits are given or received in an honest and transparent manner
B
and are auditable; and
4.3.1 Business Partners
›› he frequency and timing of the benefits given to or received from
T
the same individual or organization do not raise any conflict of
interest, appearance of conflict of interest or impropriety. At SNC-Lavalin, we define a business partner as any third party who acts on behalf of or is
partnered with SNC-Lavalin for the purpose of undertaking a specific task.
Given benefits are recorded completely, accurately and in sufficient detail in SNC-Lavalin’s
books and records. We must exercise good judgment and common sense for all business Actions performed by others when assisting us in our business activities have a direct impact
courtesies, in particular when offering to government officials, as they are subject to stricter on us. Legally we may be held liable for the actions of our business partners as if we had
rules, regulations and laws. performed them ourselves. Thus, we need to ensure that individuals or organizations acting
on our behalf behave and conduct themselves as we would conduct ourselves.
Refer to Section 4.3.2 – Government officials for more details.
Our obligation begins with the diligent selection of business partners who share our values
For more information and business principles, and by ensuring that compliance due diligence is performed and
duly approved for each of our business partners. Throughout the business relationship, we
Consult our procedure on Compliance.
must continuously and properly monitor our business partners to prevent misconduct.
For more information
Consult our procedure on Compliance.
30 SNC-LAVALIN | CODE OF CONDUCT 2019 314.3.2 Government officials 4.4 Political Contributions
Given the nature of our business, we regularly interact directly or indirectly with government
We are prohibited from making political contributions on behalf of SNC-Lavalin to political
officials. When dealing with government officials, more restrictive rules apply. Activities
candidates, parties, organizations or any other political entity, at all levels of government.
that may be acceptable when dealing with private-sector company employees could be
inappropriate or illegal when dealing with government officials. Therefore, we all must
exercise extra caution when interacting with government officials. A “government official” We may engage in personal political activities in our own individual capacities, as long as we
is defined as an officer or employee of or any person (e.g. attorney, legal representative) do not make use of SNC-Lavalin’s name, time, funds, property, resources or employee lists,
representing or acting on behalf of: or solicit, during working hours, any individual for political contributions.
›› ny level of government (whether federal, provincial, state,
A
municipal or other); For more information
Consult our procedure on Compliance.
›› Political parties, party officials and candidates for political offices;
›› State-owned and controlled entities;
›› Public international or intergovernmental organizations; or 4.5 Lobbying
›› person who holds a legislative, administrative, judicial or military
A
position.
Many jurisdictions have enacted laws and regulations that require various levels of
disclosure of lobbying activities. It is in the nature of SNC-Lavalin’s business that we may
For illustrative purposes, the following are examples of state-owned and controlled entities: engage in lobbying activities with public office holders. We must be aware of the applicable
public transit and public utility corporations, national airlines, broadcasting corporations, rules and ensure that we are fully compliant. All lobbying activities must be coordinated
universities, hospitals, national agencies, national oil companies, crown corporations, etc. through the Executive Vice-President, Strategy, Marketing and External Relations.
When in contact with government officials, we are responsible for knowing and strictly
adhering to the laws, regulations or rules that apply to interacting with such government
officials or government contracting entities. In all cases, we must:
›› Interact honestly, accurately and transparently with all government
officials;
›› ever offer anything in the nature of a personal benefit to a
N
government official unless it is clearly permissible under applicable
laws and regulations and fully compliant with our Code and its
underlying policies;
›› efrain from giving anything of value to any individual if we have
R
reasons to believe that it will be passed on to a government official;
and
›› ever enter into potential employment opportunities with a current
N
or former government official or a member of his/her immediate
family without having consulted with Human Resources.
For more information
Consult our procedure on Compliance.
32 Louis Armstrong New Orleans International Airport SNC-LAVALIN | CODE OF CONDUCT 2019 334.6 Money Laundering and Tax Evasion 4.7 rade Compliance, Export Controls
T
Money laundering is the method by which money is obtained or generated by unlawful activity
and Anti-Boycott
(e.g. drug trafficking, smuggling, copyright infringement, piracy and corruption) and is disguised
by infiltrating the legal circuit of finance and business in order to hide the money’s origin. As we deliver our products and services all over the world, SNC-Lavalin’s activities must be
conducted in compliance with the export controls, economic sanctions and anti-boycott laws
Tax evasion is the unlawful evasion of taxes by misrepresenting the taxpayer’s affairs with and regulations of all the jurisdictions where we do business.
the goal to reduce or eliminate their tax liability. Misrepresentation may take the form of
dishonest tax reporting through the understatement of income or gains or the overstatement Laws governing trade are complex and violations can lead to significant fines, debarment
of deductions or losses, and can be realized by individuals, corporations or trusts. and the withdrawal of simplified import and export procedures.
We must abide by anti-money laundering laws and regulations and with all tax laws and SNC-Lavalin employees working on international opportunities and projects are expected
regulations in all the jurisdictions in which we operate. We must act diligently to prevent to abide by our procedure on Trade Compliance. For further guidance, contact the Integrity
SNC-Lavalin from being involved or used in money laundering, tax evasion or other criminal team, Legal team or Procurement team.
activities. We must therefore apply the appropriate level of due diligence prior to entering
into a relationship with a client or other third parties. We are also required to recognize and
monitor potential warning signals that could help detect unusual and suspicious activity.
We must immediately report any doubtful activity that may involve money laundering, tax
evasion or other criminal doings. 4.8 Insider Trading
For more information We may have access to “inside information” that is not yet known to the public and that,
Consult our procedure on Compliance. if publicly known, may have an impact on the price of SNC-Lavalin shares or those of our
clients, suppliers or joint venture partners that are traded on financial markets. Inside
information may include non-public financial information, sales and earnings figures, plans
for dividend changes or new financing, acquisitions, major new contracts or other financial
matters, changes in senior management, claims and litigation, etc.
Trading on SNC-Lavalin shares or those of any of our clients, suppliers or joint venture
partners—or advising others to do so—while being in possession of inside information is not
only prohibited by our Code, but is also illegal and may constitute a serious criminal offence.
Senior officers of SNC-Lavalin have additional responsibilities under the law with respect to
securities transactions.
We all have a role in ensuring that inside information is not disclosed to anyone, including
clients, consultants, family, friends, financial analysts and journalists.
For more information
Consult our policy on Disclosure & Insider Trading, or contact Legal.
34 Karebbe Hydroelectric Project SNC-LAVALIN | CODE OF CONDUCT 2019 35Accounting Practices
The use of SNC-Lavalin’s funds or other assets for any unlawful or improper purpose is
4.9 strictly prohibited, as are false or misleading entries and unrecorded bank accounts created
for any purpose, whether regarding sales, purchases or other activities, and improper or
and Record Keeping unusual financial arrangements with a third party (such as over-invoicing or under-invoicing).
Managers and officers, as well as those responsible for accounting and record-keeping
functions, are expected to be vigilant, not only in ensuring enforcement of this prohibition but
also in having oversight of the proper use of SNC-Lavalin’s assets.
Accurate, complete and reliable records are crucial to our business as they guide decision-
making and strategic planning. They are the basis of our financial reports and are necessary
to fulfill SNC-Lavalin’s obligation to provide full and truthful disclosures to investors, For more information
stakeholders and regulatory authorities. Consult our policy on Finance or contact Finance.
All our records must be complete, accurate and reliable, and prepared in accordance with
applicable laws and regulations as well as SNC-Lavalin’s accounting and reporting policies
and procedures. 4.10 ngaging in Corporate Social
E
Each of us must make the following commitments with
Responsibility
respect to our books and records, regardless of the
purpose for which the information is used:
4.10.1 Human Rights
usiness records, expense reports, invoices, vouchers, payrolls, employee records and other reports are
B
prepared with care and honesty, and in a timely fashion;
We believe that all human beings should be treated with dignity, fairness and respect.
All transactions are approved in accordance with our Levels of Authority Policy and other applicable SNC-Lavalin is committed to supporting the protection and preservation of human rights
policies and in compliance with applicable laws, rules, standards and regulations; throughout its worldwide operations and to ensuring that it is not involved in, or benefits
from, human rights abuses.
All transactions are supported by proper documentation;
We will not engage in activities that encourage human rights abuses or that support
Transactions are recorded based on sound judgement and accounting principles; trafficking in persons or the use of child labour or forced labour. Moreover, we will never
knowingly do business with subcontractors, business partners, suppliers or any other
third parties who do not adhere to the principles regarding human rights put forward in
o transaction, asset, liability, suspected liability claims, potential claims, litigation or other financial
N
information is concealed from management, Legal or Corporate Finance, or from SNC-Lavalin’s internal our Supplier Code of Conduct. These principles apply regardless of local legislation and
or external auditors; customs.
All efforts are made to resolve all issues and concerns raised in internal and external audit reports;
For more information
Consult our Modern Slavery and Human Trafficking Statement.
Any unrecorded funds or assets, suspect accounting or false or artificial entries in our books
and records are immediately reported to Integrity or Internal Audit;
Any known inaccuracies, misrepresentations or omissions are disclosed to relevant stakeholders
and promptly corrected through credits, refunds or other mutually acceptable means;
4.10.2 Community Engagement
All documents issued and signed are, to the best of our knowledge, accurate and truthful; SNC-Lavalin is committed to strengthening sustainable benefits to the local communities
in which we live and work around the world. By being attentive to community needs
No secret or unrecorded cash funds or other assets are established or maintained for any purpose; and and expectations, and by respecting each community’s uniqueness, we build strong and
sustainable relationships. We collaborate with local non-governmental organizations,
governments and private-sector partners to develop and implement sustainable programs
Access to sensitive or confidential information is restricted to ensure that it is not accidentally
or intentionally disclosed, modified, misused or destroyed. around our projects.
36 SNC-LAVALIN | CODE OF CONDUCT 2019 37We empower local workers, companies and
communities through training, mentorship and
capacity building, transferring valuable expertise
and implementing initiatives to enhance project
employment and procurement opportunities.
4.10.3 Donations and Sponsorships
SNC-Lavalin’s approach to donations and sponsorships aims to support ideas and initiatives
with the potential to stimulate progress and build the future of our society.
Our goal is to have a positive impact on communities,
learning and innovation.
In order to achieve this goal, we contribute primarily to educational causes, particularly
initiatives that support the next generation of talent; we also encourage charities that
build caring communities in the regions we operate. SNC-Lavalin values the importance
of employees’ community involvement priorities. Employees are encouraged to undertake
opportunities to volunteer or get involved in their community.
We encourage employees to make use of this program
to utilize their professional skills and experience.
At all times, we must be aware of the fact that donations and sponsorships may present
corruption risks and could be perceived as a way to seek or obtain an improper advantage.
Employees may not make promises or guarantees on behalf of SNC-Lavalin to any charities
or causes without obtaining prior approval in accordance with our procedure on donations,
sponsorships and employee involvement.
38 Burj Al Arab SNC-LAVALIN | CODE OF CONDUCT 2019 39PROTECTING OUR ASSETS
Electronic Resources
We all share a personal responsibility and legal duty to protect SNC-Lavalin’s information and that of
our clients and partners. 5.1
SNC-Lavalin provides the electronic resources required for conducting business, including
email, information systems and electronic equipment, software, Internet and network
Protecting information and assets is vitally important not access. All work-related electronic communications must be done through work email
only to us but also to our clients and partners. addresses. Using non-corporate email addresses to send or receive work-related
communications is strictly forbidden.
While moderate personal use of SNC-Lavalin electronic resources is permitted if it does not
It is essential that information such as financial results, business plans, technical information and interfere with work duties, abuse of this privilege is regarded as misconduct.
design outputs, intellectual property and personal information is not compromised in any way and is
used and distributed appropriately and responsibly. Electronic resources provided to us by SNC-Lavalin remain the exclusive property of
SNC-Lavalin and must be used responsibly, appropriately and ethically. We must never use
Assets must be used responsibly, appropriately and ethically, and protected from damage and SNC-Lavalin’s electronic resources for the exchange, storage or processing of content that:
unauthorized access. We must not use SNC-Lavalin assets for any unlawful, unethical or improper
›› Is prohibited by law (such as the illegal downloading of material
purpose, or for personal or third-party benefit or gain.
protected by copyright laws);
You should always: ›› Promotes or engages in harassment;
›› afeguard personal information, SNC-Lavalin’s confidential information and
S ›› ould be perceived as being racist, defamatory, discriminatory,
C
intellectual property; violent, heinous, sexist or pornographic; or
›› Protect the company’s assets as if they were your own; and ›› May tarnish SNC-Lavalin’s reputation.
›› nsure assets are maintained to an appropriate standard and not used
E
When using electronic resources, we must always take the appropriate precautionary
inappropriately.
measures to avoid compromising the integrity of SNC-Lavalin equipment or systems, or
disclosing private or confidential information.
You should never:
›› se or access confidential information or intellectual property belonging to
U SNC-Lavalin may exercise its surveillance rights surrounding the use of its electronic
clients, competitors, business partners or former employers without their resources and reserves the right to monitor and review any content exchanged, stored or
written consent or for obtaining an unfair advantage; processed on SNC-Lavalin electronic resources, as permitted by law.
›› ccess or store inappropriate information, data or images using company
A
It is understood that, in the course of our work and business activities with SNC-Lavalin
equipment;
and where justified to the extent permissible by law, any personal information that is
›› ail to report theft, damage or inappropriate use or suspect breach of
F exchanged, stored or processed using SNC-Lavalin electronic resources may be subject to
information; and the above monitoring and review. We understand that this information may also be subject
to disclosure to law enforcement authorities.
›› Use or share personal information about colleagues or other stakeholders.
For more information
For more information regarding the permitted usage of SNC-Lavalin electronic
resources, consult our procedures on Global Information Technologies.
42 SNC-LAVALIN | CODE OF CONDUCT 2019 43In addition, any intellectual property developed outside of our relationship with SNC-Lavalin
belongs to SNC-Lavalin if its development arises as a result of the use of confidential
information acquired in the course of our relationship with SNC-Lavalin.
The copying, taking or destroying of any SNC-Lavalin intellectual property upon the
cessation of our relationship with SNC-Lavalin is unlawful. Moreover, SNC-Lavalin strictly
forbids the unauthorized use, theft or misappropriation of intellectual property belonging to
third parties.
For more information
Please consult our procedure on Cyber & Data Security.
5.4 External Communications
Medupi Power Station
We may be solicited for our opinion or information regarding SNC-Lavalin by the
media, outside groups or organizations. These requests must be channelled through
Communications. Even if framed as a request for a personal comment or perspective,
all such requests must be referred to Communications. Unless specifically requested
5.2 Confidentiality of Information or coordinated by Communications, any contact with the media must be done as private
citizens and not as representatives of SNC-Lavalin.
Our confidential information is one of SNC-Lavalin’s most important assets. Whenever we participate or represent SNC-Lavalin as a participant in a conference, panel
or any form of media—television, radio, online, social medium, print, etc.—we must be
authorized by our manager and notification must be provided to Communications in advance,
We must prevent inappropriate or unauthorized access to or disclosure of any confidential
when possible.
information belonging to SNC-Lavalin or entrusted to us by third parties. Our obligation
to safeguard the confidentiality of information continues even after the termination of our
employment with SNC-Lavalin. To this end, SNC-Lavalin has created a procedure that lays Even when giving opinions to outside interest on matters not related to SNC-Lavalin, we are
the ground rules on how to properly classify and apply the adequate level of protection on expected to be cautious and ensure that our comments remain strictly personal and do not
the information we are entrusted with. commit, misrepresent or otherwise involve SNC-Lavalin.
SNC-Lavalin encourages us to be the company’s ambassadors on social media. However, we
For more information
must not disclose any personal data or confidential information to which we might be privy
Please consult our procedure on Cyber & Data Security.
and must always remember to respect our Code.
For more information regarding external communications, consult our policy on External
5.3 Intellectual Property Communications, our procedure on social media, work instruction on Speaking Opportunities
or contact Communications.
Copyrights, trademarks, designs, names, logos, photos, videos and any other form of
intellectual property created or modified during the course of our relationship with
SNC-Lavalin will remain the exclusive property of SNC-Lavalin.
44 SNC-LAVALIN | CODE OF CONDUCT 2019 45REPORTING
VIOLATIONS
AND
COMPLAINTS
46 John Hart Generating Station Replacement SNC-LAVALIN | CODE OF CONDUCT 2019 476.1 Duty to Report 6.2 Internal Investigations
It is the responsibility of each and every one of us to ensure that we all live by the values SNC-Lavalin takes all reports of misconduct seriously and assumes that all concerns and
of SNC-Lavalin and our Code. We all have an important duty and a responsibility to report reports filed are done in good faith and are legitimate. Investigations into allegations of
in good faith any known or suspected violation of our Code and its underlying policies, as potentially unethical or illegal conduct are performed by Compliance Investigations and/
well as any violation of applicable laws, rules or regulations or any observed instances of or Global Security and/or Human Resources and/or Health and Safety using recognized
misconduct or pressure to compromise our ethical standards. investigation techniques in accordance with our internal practices and protocols. This
ensures the quality and integrity of the investigation process are maintained.
If we are involved in a situation or become aware of something that is or may be in breach
of our Code or its underlying policies, we must promptly report it via any of the following
resources:
Investigations are conducted with the utmost respect,
›› Our manager or leadership team;
discretion and privacy, and will be kept confidential
›› Our Integrity officers; to the extent permitted by law.
›› Our Human Resources representative;
›› ther relevant representatives (Health, Safety & Environment,
O
Legal, Global Security, Finance or Internal Audit); or We, too, must keep our interactions with Compliance Investigations confidential. If
Compliance Investigations, Global Security. Human Resources or Health and Safety discover
›› he Reporting Line operated by a secured third-party provider (see
T criminal or otherwise improper activity, SNC-Lavalin may be required to report such activity
the section entitled Contacts). to the appropriate government, law enforcement or regulatory authorities.
We are all required to fully, truthfully and transparently cooperate with Compliance
Investigations, Human Resources, Global Security or Health and Safety by providing all
SNC-Lavalin is committed to creating an environment requested documents and information related to the matter under investigation. We must
in which every person feels free to confidentially not in any way obstruct, hinder or delay any internal investigation. Failure to cooperate may
lead to disciplinary measures, including dismissal. Anyone who is the subject of an allegation
report suspected or actual violations of our Code is always deemed innocent unless facts uncovered during the investigation point to the
contrary.
or its underlying policies and strictly forbids retaliation against any individual who, in good
faith, reports a violation, whether actual or suspected.
If we believe we have experienced retaliation, we are expected to report it just as any
other violation would be reported. If we have any concerns about our duty to report and/or
retaliation, we should contact the Integrity team.
For more information
Consult our procedure on Compliance.
48 Kearl Oil Sands SNC-LAVALIN | CODE OF CONDUCT 2019 49CONTACT
When we have a question or would like to raise a concern, we should
begin by consulting the person who best understands our work and
area of responsibility: our manager or leadership team. We may also
communicate with contacts within our corporate function or business
unit. A detailed contact list can be obtained on the Integrity page on
Infozone or from our Human Resources representative.
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