snc-lavalin a journey to best-in class ethics and …ecrisponsor.org/npresentations/1-3mon.pdf ·...
Post on 08-May-2020
4 Views
Preview:
TRANSCRIPT
SNC-LAVALIN
A JOURNEY TO BEST-IN CLASS
ETHICS AND COMPLIANCE
STEFAN HOFFMANN-KUHNT
HEAD OF COMPLIANCE PROGRAM,
SNC-LAVALIN GROUP INC., MONTREAL, CANADA
Engineering & Construction Risk InstituteMontreal, June 4th, 2014
MYTHS AND FACTS ABOUT
CORRUPTION
3
That„s what you hear:
"Everybody does it and in
some countries it is simply
part of the culture."
"I did it in the interest of
the company, I did not put
any money in my pocket."
"The honest companies are
being the stupid ones.
Compliance is a
competitive disadvantage."
That‟s what you see:
There does not exist any
country where corruption
would be permitted.
The truth is: I want to be
promoted by my company
and to get my bonus.
Many examples prove:
Corruption is not a
foundation for conducting
sustainable and successful
business.
CONSEQUENCES OF CORRUPTION
4
Source: PricewaterhouseCoopers, Wirtschaftskriminalität und Unternehmenskultur 2013 (White-collar crime and business culture 2013)
EXECUTIVES' ESTIMATIONS OF CORRUPTION COSTS
Increased enforcement by authorities
Demotivation of employees
Loss of market capitalization
Increase of PR expenditures
Damage to governmental relations
Reputational damage
Increase of litigation expenditures
Management attention
Damage to customer relations
REPUTATIONAL DAMAGE
5
"It takes 20 years to build
a reputation and five
minutes to ruin it!”
Warren Buffett, CEO
Berkshire Hathaway Inc.
over 100
OUR COMMITMENT TO ETHICS
EXCELLENCE
Our ambition is to become the global benchmark against which
other companies measure themselves. We strive to set a higher
standard for:
(1) How ethics is woven into the fabric of the way we do
business, and
(2) Transparency in the way we report to our stakeholders.
6
SNC-Lavalin is committed
to doing business
with highest integrity
PROGRAM IMPLEMENTATION AND VALIDATION
8
PREVENT
• Tone from the Top
• Policies and Procedures
• Compliance Risk
Management
• Training & Communication
• Support and Advice
• Business Partner Due
Diligence
• Personnel Processes
• Collective Action
DETECT
• Effective Controls
• Resources & Skills for
Global Investigations
• Regular E&C Audits
• Compliance Reviews
RESPOND
• Disciplinary Sanctions
• Unbiased Consequences
• Remediation of
Systematic Deficiencies
• Prevention of Recurrence
MANAGEMENT RESPONSIBILITY
COMPLIANCE ORGANIZATION
INDEPENDENT COMPLIANCE MONITOR / EXTERNAL VALIDATION
PREVENTION
Tone from the Top
Policies and Procedures
Education and Training tailored to
Compliance risks
Clear Communications
Compliance Organization as
Trusted Advisors
Business Partner Due Diligence
Integration in Personnel Processes
Collective Action against Corruption
9
General focus on prevention of wrongdoing through:
TONE FROM THE TOP
• Clear and consistent messages from top leadership team
• Engage middle management in compliance communication
• Include Compliance messages in regular management meetings
and events
• Management leads by word and deed
• Encourage open communications
• Reiterate that everyone is responsible for Ethics & Compliance
• Recognize exemplary Ethics & Compliance behavior
• Integrate Ethics & Compliance related performance criteria in
compensation system
10
All managers have to deliver the Tone from the Top:
POLICIES AND PROCEDURES
Business Partners
Gift & Hospitality
Facilitation Payments
Political Contribution
Sponsorships & Donations
Reporting of Misconduct
Investigation Protocol
Amnesty Program
11
Maintain a Framework of Good Governance
EDUCATION AND TRAINING
12
CREATE APPROPRIATE AWARENESS WITH STAFF AT ALL LEVELS
TARGET# STATUS
In-Person Training
• General Awareness
• Anti-Corruption
• Business Partner
General Management
Procurement, Bus.Dev.
Project Management,
Government Relations
3081
employees
globally
• 2256 / 3081 trained
• 152 / 191 sessions
• 45 various office &
project sites
ExCom / OpCom
Board of Directors
18
11
Q2
April 14, 2014
Code of Ethics
Certification
All staff / consultants 30500 99.96% certified
Tone at the top
TRAINING TARGET GROUP
COMPLIANCE IN-PERSON TRAINING
13
• In person Anti-Corruption and Business Partner Policy Training provided to approx. 3,000+ employees in
„sensitive roles‟: All Executive, Senior and General Management Functions as well as all staff in
Business Development, Procurement, Project and General Management and Government Relations
• 70+ Cities / 4 languages
• Provided by SNC-Lavalin and local Anti-Corruption specialists and to be completed by Q2/2014
2022
154
29
40
33
15
67
26
174
36
25
54
106
103
175
358
14
8
14
COMPLIANCE COMMUNICATION
Internal Communication
• Frequent and consistent placement
of Compliance Messages
• Use of all possible communication
channels
External Stakeholder Management
• Clients
• Business Partners and Suppliers
• Governmental Agencies
• Industry Associations
• Media
Clear and Consistent Messages to All Stakeholders:
15
NEW ETHICS & COMPLIANCE
INFOZONE PAGE Useful Information on
Compliance
Frequently asked Questions
Compliance Process
Descriptions
Contact Information for
Compliance
Available in French and
English
Will be frequently updated
ANTI-CORRUPTION MANUAL
A new resource intended to complement the Code of Ethics, setting
out mandatory principles in 7 key corruption risk areas:
1. Gifts and Hospitality
2. Prohibition of Facilitation Payments
3. Corporate Charitable Donations
4. Sponsorships
5. Business Partners
6. Recordkeeping
7. Mergers and Acquisitions, Joint Ventures,
and Minority Stakes
The Manual provides information on consultation and approval
protocols for a range of common business activities: Compliance
Officers are prominently featured as a key point of contact.
16
17
Board of DirectorsPresident and Chief
Executive Officer
Chief Compliance
Officer
Compliance Organization
Infrastructure Concessions &
Investments Compliance
Officer
Robert G. Card
David G. Wilkins
Compliance
Program
Monitoring &
Reporting
Compliance
Training and
Consultation
Compliance
Coordination
Compliance
Investigations
Project Office
Corporate
Functions
Compliance
Officer
General
Construction
Compliance
Officer
Transportation
Construction
Compliance
Officer
Infrastructure
Group
Compliance
Officer
Operations &
Maintenance
Compliance
Officer
Infrastructure
Engineering
Compliance
Officer
Power Group
Compliance
Officer
Res., Env. &
Water Group
Compliance
Officer
Mining &
Metallurgy
Compliance
Officer
Oil & Gas
Compliance
Officer
Africa, Asia &
Middle-East
Compliance
Officer
Latin America
Compliance
Officer
Europe
Compliance
Officer
Environment &
Water
Compliance
Officer
As of June 1, 2014
18
• Full transparency and accountability for 3rd Party Risk
• Risk level of the proposed relationship between SNCL and the
Business Partner will determine the depth of necessary
Compliance Due Diligence (CDD) and the required level of
authority for management approval
• Responsibility for CDD rests with the Business Unit that wants
to engage the Business Partner
• Overall process is supported by a user-friendly IT-solution
Business Partner Due Diligence
BasicRed Flag
Evaluation
Integrity Check
Lower Risk
Medium Risk
Higher Risk
Risk Assessment Due Diligence
Higher Risk
Medium Risk
Lower Risk
Approval
BU LoA
BU
EVP
BU
CO
Chief
CO
BU
EVP BU CO
© SNC-Lavalin
19
2014 GOAL STRUCTUREFinancial Objectives
(Overall Weight: 2/3)
Non-Financial Objectives(Overall Weight: 1/3)
Objective 1
Ethics and Compliance (25%)*
15% - Company Program Implementation: continue to implement an
effective and sustainable ethics and compliance program
10% - Program execution: effectively execute and operationalize the
Ethics and Compliance Program within area of responsibility
HSSE (10%)
• Goal 1
• Goal 2
• …
Objective 2
Strategy, Organization and People (65%)
• Goal 1
• Goal 2
• …
COLLECTIVE ACTION AGAINST
CORRUPTION
Partnering Against Corruption Initiative (PACI)
United Nations Global Compact
Transparency International
International Anti-Corruption Academy (IACA)
Construction Sector Transparency Initiative (CoST)
Ordre des Ingénieurs du Québec
Endow Faculty Chair on Global Business Ethics at Canadian
University
20
Several initiatives being explored to promote fair and
equal market conditions:
DETECT AND MONITOR
• Effective controls
• Resources / skills for global deployment
of compliance investigations
• Regular Ethics & Compliance audits
• Regular compliance reviews
• Periodic and “spot” risk assessments
• External review and assessment of
program
21
Identify misconduct and compliance gaps through:
COMPLIANCE CONTROL FRAMEWORK
22
'Tone from the Top'
Compliance
Organization
Case
Monitoring Effectiveness10
1
3
2
Tracking
Training &
Program
Commun-
ication
4
Implementation of Policies and Procedures
3rd parties / Business Partners
Tender & Contracts
Gifts & Hospitality
Finance & Accounting
Integration with Personnel Processes9
8
7
6
5
Independent and continuous testing of the effectiveness
of all modules of the SNC-Lavalin Compliance Program
CHANNELS FOR WHISTLEBLOWING
AND CONSULTATION
23
TELL US ASK US
Compliance
Consultation Centre
(CCC)
Requesting advice
and support on
compliance in
business activities
By email
Channel
Purpose
How to
contact
?!
Duty to Report
Ethics and
Compliance
Hotline
(EthicsPoint)
Amnesty
Program
Reporting of Allegations and
Complaints
Reporting of own
involvement in
wrong doing
Any Channel
By Phone
+
Online
Any Channel
COMPLIANCE INVESTIGATION
“Duty-to-report”, EthicsPoint hotline and amnesty program are
important enablers in order to enforce compliant behavior and to
sanction misconduct
Highly experienced Investigation Team set up to investigate
Compliance violations, separate from Internal Audit function
Clear Mandate for Compliance Investigations
Investigation Reports are issued to Ethics & Compliance
Committee, who will approve disciplinary sanctions and further
preventive measures
24
Expeditious investigation of potential misconduct
RESPOND
• Swift and fair disciplinary
sanctions
• Unbiased consequences
regardless of position /
performance in the organization
• Remediation of systematic
deficiencies and harm to
immediately stem any further
consequences
• Prevention of recurrence
• No Retaliation
25
Measures to respond to improper conduct:
CONTINUOUSLY IMPROVE
• Encourage open discussion and
feedback
• Debrief on all incidents
• Also identify “near misses”
• Continuously look for
improvement opportunities
• Re-align policies and processes
• Communicate lessons learned
• Walk the talk and recognize role
model behavior
26
INDEPENDENT COMPLIANCE MONITOR
• Engaged by SNC-Lavalin, the Monitor reports to the World Bank.
• Reviews the implementation and effectiveness of the SNC-Lavalin
Ethics & Compliance Program, measuring against the Integrity
Compliance Guidelines of the WBG
• Provides recommendations for further improvements of the Ethics
& Compliance Program
27
Providing External Validation of Compliance Program:
INDIVIDUAL RESPONSIBILITY IS
KEY!
28
Questions to
guide you
towards
compliant
and
responsible
behavior
Is it the right thing for SNC-
Lavalin?
Is it consistent with my core
values and SNC-Lavalin’s?
Is it legal? Is it ethical?
Is it something I am willing to
be held accountable for?
If the answer
to those
questions is
“Yes”,
Don‟t worry,
be confident!
…IT’S ALL ABOUT PEOPLE –
EVERYWHERE!
29
"In looking for people to hire, you
look for three qualities: integrity,
intelligence, and energy. And if you
don't have the first, the other two
will kill you."
Warren Buffet
CEO of Berkshire Hathaway Inc.
WE CARE embodies SNC-Lavalin’s key corporate values and
beliefs. It is the cornerstone of everything we do as a company.
Health and safety, employees, the environment, communities
and quality: these values all influence the decisions we make
every day. And importantly, they guide us in how we serve our
clients and therefore affect how we are perceived by our external
partners. WE CARE is integral to the way we perform on a daily
basis. It is both a responsibility and a source of satisfaction and
pride by providing such important standards to all we do.
WE CARE about the health and safety of our employees, of those who work under our care, and
of the people our projects serve.
WE CARE about our employees, their personal growth, career development and general well-
being.
WE CARE about the communities where we live and work and their sustainable development, and we commit to
fulfilling our responsibilities as a global citizen.
WE CARE about the environment and about conducting our business in an environmentally responsible manner.
WE CARE about the quality of our work.
30
top related