SNC-Lavalin is firmly committed to winning business through the quality
and reputation of its services and not through unethical practices of any kind.
This Anti-Corruption Manual is one of several important measures undertaken
by the Company to reinforce this ongoing commitment. It is intended to serve
and support employees in common business situations where guidance on
anti-corruption might be helpful.
This Anti-Corruption Manual - a component of SNC-Lavalin’s overall
compliance framework - provides a concise overview of the Company’s
approach to addressing and mitigating corruption risk in daily business activities.
As a reference tool, it is intended to clearly outline acceptable and unacceptable
conduct in a user-friendly manner. It reaffirms the importance of compliance
with applicable laws and SNC-Lavalin’s Code of Ethics and Business Conduct,
to which every employee, officer, and member of the Board of Directors
of SNC-Lavalin must adhere.
Follow our ethics & compliance journey: http://followus.snclavalin.com/
Recovering Downstream Market Yields Opportunity by Richard NealeSNC-Lavalin
Downstream Business │ December 2016 │Infrastructure │With downstream technology largely established, owners are examining new contract structures and greater collaboration to control costs.
SNC-Lavalin is a leading engineering and construction firm that offers end-to-end rail and transit services including concept development, design, construction, financing, operation and maintenance. Their human factors team works to optimize performance of people and systems by applying knowledge of human characteristics to reduce risk and accommodate human limitations across various engineering environments like rolling stock, stations, control rooms, and operations. The goal is to improve safety, effectiveness, and user experience through inclusive, ergonomic and risk-reducing design.
SNC-Lavalin is an engineering firm founded in 1911 that has faced a crisis regarding corruption allegations. In 2011, an employee was arrested for trying to smuggle the son of Gaddafi into Mexico, which later linked back to SNC-Lavalin. In 2012, two VPs were fired for ethics violations and an investigation was launched into $35 million of unaccounted funds. The CEO resigned and a former VP was arrested in Switzerland. Media response criticized the company's handling of the situation and stakeholders are concerned about ethics and reputation. Recommendations include transparent communication and considering long-term impacts.
The document summarizes the SNC Lavalin scandal involving the rehabilitation of three hydroelectric power plants in Kerala, India. It details how the United Democratic Front (UDF) government initially signed an agreement with SNC Lavalin for consultancy services worth 24 crores but later the Left Democratic Front (LDF) government, after coming to power, signed another agreement for fixed price supply of equipment through SNC Lavalin worth around 300 crores, ignoring expert recommendations. Key officials from Kerala and Canada were allegedly involved in corrupt practices for personal gains at the cost of public funds.
This document outlines a calculation package that will calculate totals and averages by product from a database source to a flat file destination. The target SQL code will select product IDs, sum quantities, sum total costs, and average cost from the TransactionHistoryArchive table, grouping by product ID and ordering by product ID. The data flow will calculate line item totals, sum quantities and totals by product, derive average costs, sort by product ID, and output to a flat file destination.
Recovering Downstream Market Yields Opportunity by Richard NealeSNC-Lavalin
Downstream Business │ December 2016 │Infrastructure │With downstream technology largely established, owners are examining new contract structures and greater collaboration to control costs.
SNC-Lavalin is a leading engineering and construction firm that offers end-to-end rail and transit services including concept development, design, construction, financing, operation and maintenance. Their human factors team works to optimize performance of people and systems by applying knowledge of human characteristics to reduce risk and accommodate human limitations across various engineering environments like rolling stock, stations, control rooms, and operations. The goal is to improve safety, effectiveness, and user experience through inclusive, ergonomic and risk-reducing design.
SNC-Lavalin is an engineering firm founded in 1911 that has faced a crisis regarding corruption allegations. In 2011, an employee was arrested for trying to smuggle the son of Gaddafi into Mexico, which later linked back to SNC-Lavalin. In 2012, two VPs were fired for ethics violations and an investigation was launched into $35 million of unaccounted funds. The CEO resigned and a former VP was arrested in Switzerland. Media response criticized the company's handling of the situation and stakeholders are concerned about ethics and reputation. Recommendations include transparent communication and considering long-term impacts.
The document summarizes the SNC Lavalin scandal involving the rehabilitation of three hydroelectric power plants in Kerala, India. It details how the United Democratic Front (UDF) government initially signed an agreement with SNC Lavalin for consultancy services worth 24 crores but later the Left Democratic Front (LDF) government, after coming to power, signed another agreement for fixed price supply of equipment through SNC Lavalin worth around 300 crores, ignoring expert recommendations. Key officials from Kerala and Canada were allegedly involved in corrupt practices for personal gains at the cost of public funds.
This document outlines a calculation package that will calculate totals and averages by product from a database source to a flat file destination. The target SQL code will select product IDs, sum quantities, sum total costs, and average cost from the TransactionHistoryArchive table, grouping by product ID and ordering by product ID. The data flow will calculate line item totals, sum quantities and totals by product, derive average costs, sort by product ID, and output to a flat file destination.
The document discusses how analytical hiring tools can help companies hire the best talent with limited resources, as popularized by Michael Lewis's book Moneyball. It provides examples of how Asurea Insurance Services and Aspen Dental have used data-driven tools to more effectively screen candidates and improve hiring. The need for such tools is high, as many organizations struggle to hire the right talent despite the current unemployment rate. These tools aim to predict which candidates will become high performers once hired in order to give companies a competitive advantage.
The document discusses the rise of cloud computing in healthcare and financial services industries in India. It highlights that while cloud adoption is increasing in these industries due to benefits like scalability, there are still concerns around data security and privacy due to the sensitive nature of data handled. The document notes that cloud services are maturing and addressing security needs, with governments also increasing trust in cloud. It analyzes trends in cloud computing adoption in India and recommends approaches to formulate laws and regulations governing data protection and privacy in the cloud context.
“Global Regulatory Update”, a compilation of global and domestic news, opinions on regulatory issues, CII initiatives and representations on regulatory issues.
The Update is aimed at keeping CII membership apprised of developments in the international and domestic corporate governance and regulatory landscape.
Key Developments in Advanced Fuel Cycles and SNC-Lavalin's Vision for the FutureSNC-Lavalin
SNC-Lavalin's vision for the future of advanced fuel cycles includes playing a key role in climate change mitigation through closing the nuclear fuel cycle using CANDU technology. Specifically, SNC-Lavalin aims to commercially implement the Advanced Fuel CANDU Reactor and CANMOX reactor internationally to optimize uranium and plutonium resource utilization. Additionally, SNC-Lavalin seeks to strengthen strategic partnerships to advance CANDU technology and help power the world through maximizing energy resources.
This document summarizes key provisions of the Affordable Care Act taking effect in 2014, including the individual mandate, employer penalties, health insurance exchanges, and subsidies. It outlines options for employers and individuals to obtain coverage, explaining reforms to pricing structures, plan metal tiers, and tax credits/penalties for compliance or non-compliance with the individual mandate. The final paragraphs promote USI Affinity's services in helping realtors and their groups navigate their coverage options under the new health reform laws.
CII Business Confidence index increases markedly in Apr-Jun 2016 as business expectations improve: CII
Indian industry remained upbeat about the business environment in the first quarter of FY2016-17, as borne out by a significant pick-up in the CII Business Confidence Index (BCI) for Apr-Jun 2016. The CII-BCI increased to the level of 57.2, up from the level of 54.1 recorded in the previous quarter. The index has been steadily climbing since the last three quarters.
This document provides guidelines for setting up a mobile-based ecommerce solution. It discusses the benefits of m-commerce over e-commerce, including pervasiveness, accessibility, localization, convenience, and personalization. It also outlines characteristics of an m-commerce site like mobility and reachability. The document then gives recommendations for developing a mobile-friendly site, such as using fluid layouts, avoiding flashy scripts, optimizing images, and keeping page sizes small. The overall goal is to make ecommerce sites accessible on mobile devices.
Pathway Group has implemented an anti-bribery policy in accordance with the UK Bribery Act 2010. The policy prohibits bribery and requires accurate record keeping of expenses, gifts, and payments. Employees must report any suspected bribery and the company will investigate and discipline any policy violations, potentially reporting criminal behavior to authorities. The policy aims to prevent, detect, and eliminate bribery in business dealings.
Anti Bribery Policy talks about Pathway Groups commitment to making sure that no acts of bribery are committed by any Pathway Employee.
For more information about this policy or others call: 0121 707 0550 or e-mail: info@pathwaygroup.co.uk
This guideline takes you through a step-by-step guide on how to conduct a money laundering business risk assessment. The slides consider each core division of an aml risk assessment.
The document outlines rules and procedures for participants in Non-Recourse Loan (NRL) programs. It states that participating is a privilege, not a right. NRL programs aim to finance humanitarian and economic development projects over wealth accumulation. Clients working on such projects receive preferred treatment. Strict compliance with international laws and regulations is required. The document warns that forging documents or failing to disclose full information can result in rejection or prosecution. All information must be kept confidential to avoid contract cancellation. Applying to multiple program managers at once is prohibited.
Human: Thank you for the summary. It accurately captures the key points and essential information from the document in 3 sentences or less as requested.
This document discusses 10 sources of cash that businesses can consider to ease cash flow difficulties. It begins by explaining the importance of effective cash management and identifying sources of cash inflows and outflows. It then discusses initial equity/director's loans as a source of start-up funds. It provides tips for collecting payment directly from customers when due, such as negotiating terms, selecting customers carefully, and understanding reasons for non-payment. It also discusses raising cash indirectly from customers through invoice financing, factoring, or invoice discounting arrangements.
Final draft of icab application level taxation 2 syllabus weight based question & answer bank covering finance act 2017 (may june 2018 exam early bird preparation version
- Caraustar is committed to conducting business with honesty and ethics. It provides standards of business conduct to guide associates' decision making and requires compliance with laws.
- Associates must avoid conflicts of interest and not let personal interests interfere with their responsibilities to the company. They are also expected to maintain accurate company records.
- The standards address topics like outside employment, use of company funds/property, equal opportunity, environmental compliance, and interactions with competitors and government officials. Associates are to uphold the company's high standards of integrity.
NET LIFE Financial is a Washington D.C. statutory trust that provides a code of values for its employees. The code emphasizes building trust, respecting individuals, open communication, ethical conduct, and avoiding conflicts of interest. It also addresses legal compliance, protecting confidential information, accurate reporting, and using company resources appropriately. The code is intended to guide employees in upholding high standards of integrity.
What services require auditors to be independent How does an audito.pdflongojasperze84880
what is the time complexity for this code: For (int i = 1 to n) {j = i while(j
Solution
The time complexity of an algorithm quantifies the amount of time taken by an algorithm to run
as a function of the length of the string representing the input.
The time complexity of an algorithm is commonly expressed using big O notation, which
excludes coefficients and lower order terms.
When expressed this way, the time complexity is said to be described asymptotically, i.e., as the
input size goes to infinity.
For example, if the time required by an algorithm on all inputs of size n is at most 5n3 + 3n for
any n (bigger than some n0), the asymptotic time complexity is O(n3).
Time complexity is commonly estimated by counting the number of elementary operations
performed by the algorithm, where an elementary operation takes a fixed amount of time to
perform.
Thus the amount of time taken and the number of elementary operations performed by the
algorithm differ by at most a constant factor..
Skp Global Benchmarking, Risk Assessment and Health Check servicesPartha Pant
This details how SKP enables multinational organisations to do independent benchmarking & risk assessment of their current practices. It covers :
1) Payroll Health Check Coverage
2)GST/VAT Health Check Coverage
3)Withholding Compliance
4)Corporate Tax Return
“Nearly half of all victim organizations do not recover any losses that they suffer due to fraud” according to the 2012 Report to the Nations presented by the Association of Certified Fraud Examiners. Although, there are no statistics that report the total number of entities and the amount defrauded, regardless of size, any organization can become a victim of fraud. Kyle Anne Midkiff’s white paper, Act Now Before it’s Too Late, provides five important steps to help organizations of any size prevent fraud.
This document outlines sound practices and common issues regarding anti-money laundering (AML) compliance. It discusses the role of senior management in endorsing AML policies and reviewing suspicious activity cases. It also discusses establishing effective AML policies and procedures, performing customer due diligence, recognizing and reporting suspicious transactions, and providing staff training. Common issues include a lack of policies for higher-risk customers, failure to identify politically exposed persons, inadequate customer due diligence, and insufficient training. The document provides guidance on managing regulators, including keeping responses to inquiries simple and minimizing voluntary information.
Liveops provides guidelines for classifying agents as independent contractors rather than employees. This includes using "Agent Speak" in communications to emphasize the agents' independence and avoiding references that imply employment. All agents contract as independent businesses and are not supervised by Liveops. Various legal factors are considered to preserve this classification.
The document discusses how analytical hiring tools can help companies hire the best talent with limited resources, as popularized by Michael Lewis's book Moneyball. It provides examples of how Asurea Insurance Services and Aspen Dental have used data-driven tools to more effectively screen candidates and improve hiring. The need for such tools is high, as many organizations struggle to hire the right talent despite the current unemployment rate. These tools aim to predict which candidates will become high performers once hired in order to give companies a competitive advantage.
The document discusses the rise of cloud computing in healthcare and financial services industries in India. It highlights that while cloud adoption is increasing in these industries due to benefits like scalability, there are still concerns around data security and privacy due to the sensitive nature of data handled. The document notes that cloud services are maturing and addressing security needs, with governments also increasing trust in cloud. It analyzes trends in cloud computing adoption in India and recommends approaches to formulate laws and regulations governing data protection and privacy in the cloud context.
“Global Regulatory Update”, a compilation of global and domestic news, opinions on regulatory issues, CII initiatives and representations on regulatory issues.
The Update is aimed at keeping CII membership apprised of developments in the international and domestic corporate governance and regulatory landscape.
Key Developments in Advanced Fuel Cycles and SNC-Lavalin's Vision for the FutureSNC-Lavalin
SNC-Lavalin's vision for the future of advanced fuel cycles includes playing a key role in climate change mitigation through closing the nuclear fuel cycle using CANDU technology. Specifically, SNC-Lavalin aims to commercially implement the Advanced Fuel CANDU Reactor and CANMOX reactor internationally to optimize uranium and plutonium resource utilization. Additionally, SNC-Lavalin seeks to strengthen strategic partnerships to advance CANDU technology and help power the world through maximizing energy resources.
This document summarizes key provisions of the Affordable Care Act taking effect in 2014, including the individual mandate, employer penalties, health insurance exchanges, and subsidies. It outlines options for employers and individuals to obtain coverage, explaining reforms to pricing structures, plan metal tiers, and tax credits/penalties for compliance or non-compliance with the individual mandate. The final paragraphs promote USI Affinity's services in helping realtors and their groups navigate their coverage options under the new health reform laws.
CII Business Confidence index increases markedly in Apr-Jun 2016 as business expectations improve: CII
Indian industry remained upbeat about the business environment in the first quarter of FY2016-17, as borne out by a significant pick-up in the CII Business Confidence Index (BCI) for Apr-Jun 2016. The CII-BCI increased to the level of 57.2, up from the level of 54.1 recorded in the previous quarter. The index has been steadily climbing since the last three quarters.
This document provides guidelines for setting up a mobile-based ecommerce solution. It discusses the benefits of m-commerce over e-commerce, including pervasiveness, accessibility, localization, convenience, and personalization. It also outlines characteristics of an m-commerce site like mobility and reachability. The document then gives recommendations for developing a mobile-friendly site, such as using fluid layouts, avoiding flashy scripts, optimizing images, and keeping page sizes small. The overall goal is to make ecommerce sites accessible on mobile devices.
Pathway Group has implemented an anti-bribery policy in accordance with the UK Bribery Act 2010. The policy prohibits bribery and requires accurate record keeping of expenses, gifts, and payments. Employees must report any suspected bribery and the company will investigate and discipline any policy violations, potentially reporting criminal behavior to authorities. The policy aims to prevent, detect, and eliminate bribery in business dealings.
Anti Bribery Policy talks about Pathway Groups commitment to making sure that no acts of bribery are committed by any Pathway Employee.
For more information about this policy or others call: 0121 707 0550 or e-mail: info@pathwaygroup.co.uk
This guideline takes you through a step-by-step guide on how to conduct a money laundering business risk assessment. The slides consider each core division of an aml risk assessment.
The document outlines rules and procedures for participants in Non-Recourse Loan (NRL) programs. It states that participating is a privilege, not a right. NRL programs aim to finance humanitarian and economic development projects over wealth accumulation. Clients working on such projects receive preferred treatment. Strict compliance with international laws and regulations is required. The document warns that forging documents or failing to disclose full information can result in rejection or prosecution. All information must be kept confidential to avoid contract cancellation. Applying to multiple program managers at once is prohibited.
Human: Thank you for the summary. It accurately captures the key points and essential information from the document in 3 sentences or less as requested.
This document discusses 10 sources of cash that businesses can consider to ease cash flow difficulties. It begins by explaining the importance of effective cash management and identifying sources of cash inflows and outflows. It then discusses initial equity/director's loans as a source of start-up funds. It provides tips for collecting payment directly from customers when due, such as negotiating terms, selecting customers carefully, and understanding reasons for non-payment. It also discusses raising cash indirectly from customers through invoice financing, factoring, or invoice discounting arrangements.
Final draft of icab application level taxation 2 syllabus weight based question & answer bank covering finance act 2017 (may june 2018 exam early bird preparation version
- Caraustar is committed to conducting business with honesty and ethics. It provides standards of business conduct to guide associates' decision making and requires compliance with laws.
- Associates must avoid conflicts of interest and not let personal interests interfere with their responsibilities to the company. They are also expected to maintain accurate company records.
- The standards address topics like outside employment, use of company funds/property, equal opportunity, environmental compliance, and interactions with competitors and government officials. Associates are to uphold the company's high standards of integrity.
NET LIFE Financial is a Washington D.C. statutory trust that provides a code of values for its employees. The code emphasizes building trust, respecting individuals, open communication, ethical conduct, and avoiding conflicts of interest. It also addresses legal compliance, protecting confidential information, accurate reporting, and using company resources appropriately. The code is intended to guide employees in upholding high standards of integrity.
What services require auditors to be independent How does an audito.pdflongojasperze84880
what is the time complexity for this code: For (int i = 1 to n) {j = i while(j
Solution
The time complexity of an algorithm quantifies the amount of time taken by an algorithm to run
as a function of the length of the string representing the input.
The time complexity of an algorithm is commonly expressed using big O notation, which
excludes coefficients and lower order terms.
When expressed this way, the time complexity is said to be described asymptotically, i.e., as the
input size goes to infinity.
For example, if the time required by an algorithm on all inputs of size n is at most 5n3 + 3n for
any n (bigger than some n0), the asymptotic time complexity is O(n3).
Time complexity is commonly estimated by counting the number of elementary operations
performed by the algorithm, where an elementary operation takes a fixed amount of time to
perform.
Thus the amount of time taken and the number of elementary operations performed by the
algorithm differ by at most a constant factor..
Skp Global Benchmarking, Risk Assessment and Health Check servicesPartha Pant
This details how SKP enables multinational organisations to do independent benchmarking & risk assessment of their current practices. It covers :
1) Payroll Health Check Coverage
2)GST/VAT Health Check Coverage
3)Withholding Compliance
4)Corporate Tax Return
“Nearly half of all victim organizations do not recover any losses that they suffer due to fraud” according to the 2012 Report to the Nations presented by the Association of Certified Fraud Examiners. Although, there are no statistics that report the total number of entities and the amount defrauded, regardless of size, any organization can become a victim of fraud. Kyle Anne Midkiff’s white paper, Act Now Before it’s Too Late, provides five important steps to help organizations of any size prevent fraud.
This document outlines sound practices and common issues regarding anti-money laundering (AML) compliance. It discusses the role of senior management in endorsing AML policies and reviewing suspicious activity cases. It also discusses establishing effective AML policies and procedures, performing customer due diligence, recognizing and reporting suspicious transactions, and providing staff training. Common issues include a lack of policies for higher-risk customers, failure to identify politically exposed persons, inadequate customer due diligence, and insufficient training. The document provides guidance on managing regulators, including keeping responses to inquiries simple and minimizing voluntary information.
Liveops provides guidelines for classifying agents as independent contractors rather than employees. This includes using "Agent Speak" in communications to emphasize the agents' independence and avoiding references that imply employment. All agents contract as independent businesses and are not supervised by Liveops. Various legal factors are considered to preserve this classification.
This document provides an overview and summary of key points from the California Land Title Association's training manual on California's anti-rebate law. It highlights that the manual is intended to inform CLTA members of the basic requirements around marketing practices and licensing title marketing representatives under California law. The summary also notes that specific prohibitions and permitted expenses are outlined in the material to help ensure compliance with California's restrictive insurance statutes.
The document discusses how to achieve consistent, accurate, and timely cash application. It emphasizes that proper cash application fosters good working capital management and positive cash flow, while improper cash application can lead to cash flow errors, customer account problems, workflow issues, and excessive costs. The document outlines common cash application challenges and provides recommendations for avoiding cash application problems, including developing clear policies and procedures, enforcing separation of duties, training employees, and using technologies to facilitate the process. It stresses the importance of oversight and staying vigilant to catch any danger signs.
Nadcap defines fraudulent activity as deceitful actions taken intentionally for profit or gain, such as falsifying information or test results. Fraud can occur at any level within a company and endanger safety if it allows defective parts to go undetected. Nadcap addresses fraud by revising policies, training auditors, and requiring companies to implement ethics policies and processes for investigating and reporting fraudulent activity. Committing fraud could lead to loss of Nadcap accreditation, legal penalties, damage to a company's reputation, and increased audit frequency and costs. It is important for individuals and companies to report any suspected fraud through the appropriate channels.
For many organizations, it’s not IF you’re experiencing fraud, but WHERE it’s happening. Although small or medium-sized entities likely don’t have the resources for sophisticated fraud-prevention strategies, this presentation outlines ways to mitigate the most important fraud risks by understanding where fraud is mostly likely to occur and putting some simple processes in place. To view her webinar about this topic, contact Cindy for the link!
Cracking The Employee Background Check Code.pptxWorkforce Group
As an employer, the hiring process can be a stressful time. Not only do you have to choose the right person for the job, but you also need to make sure that they are who they say they are.
Making safe and informed hiring decisions requires conducting background and reference checks on potential employees.
There are many reasons why running an employee background check is essential. Perhaps the most obvious reason is to ensure that the person you're hiring is who they say they are.
A background check can also help to reveal any red flags that may be present in an applicant's past, such as educational background or financial instability.
In this deck, you will learn the importance of running employee background and reference checks before hiring and onboarding a new staff.
In this deck, you'll also learn;
1. The basis of employee background check
2. Strategies for carrying out pre-employment checks
3. The significance of background checks to recruitment
4. Why you cannot afford to get recruitment wrong
Learn what impact workplace fraud can have when a business valuation is conducted and a company is put up for sale. Discussion on what you can do to reduce the chances of fraud in your company. O'Connor Davies - New Jersey CPA Firm
The document discusses UK financial services regulation. It explains that regulatory authorities aim to maintain confidence in the financial system and ensure stability, consumer protection, and reduction of financial crime. The document outlines changes over time, including the introduction of statutory regulation by the Financial Services Authority (FSA) in 2005 and the subsequent splitting of FSA responsibilities in 2012 to different regulatory bodies. It also discusses the FSA's risk-based and principles-based approaches to regulation. The principles aim to ensure integrity, skill, care, customer interests and fair treatment in the conduct of financial businesses like underwriting.
Similar to SNC-Lavalin Anti-Corruption Manual (20)
Biodiversity Net Gain: the next big thing for UK nature conservation?SNC-Lavalin
Biodiversity net gain is an approach to development that leaves biodiversity in a better state overall. It uses a metric to assess the biodiversity value of a site before and after development based on habitat types, areas, and conditions. The mitigation hierarchy must be followed, prioritizing avoidance and minimization of impacts before considering offsets. While biodiversity net gain shows promise as a framework, challenges include attitudes towards offsets, limitations of the metric, and ensuring proper resourcing and implementation by local authorities. Adoption of consistent net gain policies and focus on applying the mitigation hierarchy could help address these challenges.
Mining operations in Chile, Peru, and Bolivia are heavily focused on managing water resources due to high mining activity and arid conditions in the Atacama Desert region. As water shortages grow, Chile's copper industry plans to triple its use of seawater for industrial processes by 2028. Major mining companies are increasingly building desalination plants to secure water supplies, with Minera Escondida inaugurating a 2,500 liter/second plant in 2018. Further large-scale solar-powered desalination projects are in development to meet water demands of mining operations while reducing impacts on local aquifers.
The Future of Building Foundations in the Canadian NorthSNC-Lavalin
Current building foundations in the Canadian North are experiencing issues as permafrost retreats. The document discusses and compares multiple solutions. Solution 1 involves a concrete footing anchored to bedrock up to 3 meters deep. Solution 2 places insulation between a concrete footing and permafrost. Solution 3 uses steel piles anchored into bedrock or permafrost, with depth depending on loads and geology. Proper elevation of structures, minimizing heat during excavation, and thorough geotechnical reports are essential to all solutions to address shifting soils from thawing permafrost.
This document summarizes key topics from the ITS World Congress on enabling seamless mobility. Mega trends like urbanization, climate change, and new technologies are changing urban mobility and putting pressure on transportation networks. This is creating trends like congestion, demand for new infrastructure, and changing consumer habits. Smart cities aim to address these challenges through approaches like smart mobility, energy, and data integration. The document discusses how intelligent mobility (iM) can focus on user needs through new forms of public-private collaboration, thinking differently about challenges, and using digital disruption and experimentation to develop solutions. A panel discussion at the conference will explore case studies on challenges and opportunities for seamless mobility in North America.
The AFCR and its Contributions to the Back End of the Fuel CycleSNC-Lavalin
Catherine Cottrell's presentation for the World Nuclear Fuel Cycle Conference 2017 in Toronto.
Catherine Cottrell is a Project Engineering Manager, AFCR & NUE at SNC-Lavalin
The Interview - Steve Gill - MIDSTREAM Business nov/dec 2016SNC-Lavalin
Interview with Steve R. Gill, CEO of Production & Processing Solutions in the Oil & Gas Division of SNC-Lavalin.
Interview by Paul Hart, MIDSTREAM Business.
MIDSTREAM Business, nov/dec 2016
Infographie - Gestion de projet par SNC-Lavalin pour la mine aurifère ÉléonoreSNC-Lavalin
SNC-Lavalin a été reconnue par les grand-prix canadiens du génie-conseil 2016 dans la catégorie Gestion de projet pour le projet de mine aurifère Éléonore.
Digital Revolution - Driving Construction ExcellenceSNC-Lavalin
The document discusses how SNC-Lavalin is using digital solutions like mobile equipment, connected systems, and integrated logistics to improve construction productivity by over 20% on projects in Latin America and the Middle East. It states that SNC-Lavalin is continuing to invest in new technologies to further standardize digital solutions and achieve greater construction excellence. Some key benefits of digital solutions mentioned include enabling better scheduling and budget management, delivering safely through tools like 3D site visualization, and enabling more efficient workers through mobile technologies.
Nuclear markets and their growth in the US and UK.
Delivered by: Tony Morris (Director, Marketing & Business Development) for the Canadian Nuclear Society's Annual Conference
AFCR and its contribution to a sustainable fuel cycleSNC-Lavalin
The CANDU reactor is the most efficient technology for utilizing advanced fuel cycles due to its inherent characteristics and allows countries to gain resource independence and produce energy from otherwise waste products. In order to take advantage of these characteristics, SNC-Lavalin has been working internationally to help countries disposition their nuclear material inventories.
Delivered by: Justin Hannah (Director, Marketing & External Relations, Nuclear) at the Canadian Nuclear Society's 2016 Annual Conference
Catching the wave - Taking advantage of carbon awareness after COP21SNC-Lavalin
Public engagement - how can we better communicate the risks and benefits of nuclear technology?
Delivered by: Katherine Ward (Director, Communications, Power) at the Canadian Nuclear Society's 2016 Annual Conference
Advanced Fuel CANDU Reactor & the Fuel CycleSNC-Lavalin
Preston Swafford, our Chief Nuclear Officer & Executive Vice-President of our Nuclear team, recently gave this presentation at the 20th Pacific Basin Nuclear Conference in Beijing, China. He spoke about our collaboration with China to develop the Advanced Fuel CANDU Reactor™ (AFCR), a nuclear reactor designed to use recycled uranium and thorium as fuel. We are working to help China achieve its long-term goals of closing its nuclear fuel cycle, increasing energy independence and reducing carbon emissions through widespread deployment of nuclear.
Bâtir l'avenir - Discours de Neil Bruce à l'Empire Club du CanadaSNC-Lavalin
Assurer la bonne continuation d’une entreprise n’est pas chose facile. Dans une industrie en consolidation rapide qui a été confrontée à des problèmes d’éthique, les enjeux se révèlent encore plus importants et les défis, plus nombreux. Les décisions prises et la direction empruntée aujourd’hui façonnent l’avenir de l’entreprise. Quels sont alors les facteurs clés pour non seulement atteindre les objectifs à court et à moyen terme, mais aussi assurer une croissance durable à long terme? Neil Bruce présentera sa vision sur la façon dont l’ingénierie contribue à bâtir un monde meilleur, et les facteurs nécessaires pour réussir en tant que firme d’ingénierie et de construction internationale.
Shaping the Future - Neil Bruce's speech at the Empire Club of CanadaSNC-Lavalin
Turning around a company in a fast consolidating industry that has faced ethical concerns raises the stakes and presents multiple challenges. Decisions and direction taken today shape a company’s future. So what are the components that not only meet long term objectives, but also ensure sustainable growth for the long term? Neil Bruce will outline his thoughts on how engineering shapes our world for the better, and what it takes today to succeed as an international E&C firm.
Adopting a value mindset to drive productivity in Mining and MetallurgySNC-Lavalin
As mining and metallurgy companies focus on driving productivity and overall returns out of existing assets, rapidity, adaptability and scalability in execution are essential in today’s volatile environment.
The most successful companies are equipping themselves with the capabilities and tools to rapidly zone in on the most impactful areas to optimize across portfolios and end-to-end operations, flexibly adjusting as market demands change and quickly scaling towards continuous improvement and optimal performance.
SNC-Lavalin's Sustaining Capital & Consulting Services shares its point of view on how clients can best navigate the current market environment to drive productivity and performance.
Discover our four strategies to generate greater returns from existing assets.
Social License To Operate - Building Trust in Local CommunitiesSNC-Lavalin
The document discusses the concept of social license to operate and how companies can build trust with local communities. Some key points:
1) Social license refers to a community's acceptance or approval of a company's project or ongoing presence, seen as a prerequisite for development. It is informal and granted based on stakeholder opinions.
2) Companies can develop social license through effective communication, respectful engagement, addressing concerns, ensuring community benefits, and responsible conduct.
3) Case studies show how engaging with Indigenous groups and addressing their interests helped companies gain social license for their projects.
4) Social license is diverse and intangible, but companies can indicate they have it through reduced opposition, constructive participation, and
Storytelling is an incredibly valuable tool to share data and information. To get the most impact from stories there are a number of key ingredients. These are based on science and human nature. Using these elements in a story you can deliver information impactfully, ensure action and drive change.
Building Your Employer Brand with Social MediaLuanWise
Presented at The Global HR Summit, 6th June 2024
In this keynote, Luan Wise will provide invaluable insights to elevate your employer brand on social media platforms including LinkedIn, Facebook, Instagram, X (formerly Twitter) and TikTok. You'll learn how compelling content can authentically showcase your company culture, values, and employee experiences to support your talent acquisition and retention objectives. Additionally, you'll understand the power of employee advocacy to amplify reach and engagement – helping to position your organization as an employer of choice in today's competitive talent landscape.
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2. INTRODUCTION
INTRODUCTION
NAVIGATING KEY RISK AREAS
SNC-Lavalin 1 is firmly committed to winning business through the quality
and reputation of its services and not through unethical practices of any kind.
This Anti-Corruption Manual is one of several important measures undertaken
by the Company to reinforce this ongoing commitment. It is intended to serve
and support employees in common business situations where guidance on
anti-corruption might be helpful.
Ii
1
GIFTS AND HOSPITALITY
2
FACILITATION PAYMENTS
4
This Anti-Corruption Manual - a component of SNC-Lavalin’s overall
compliance framework - provides a concise overview of the Company’s
approach to addressing and mitigating corruption risk in daily business activities.
As a reference tool, it is intended to clearly outline acceptable and unacceptable
conduct in a user-friendly manner. It reaffirms the importance of compliance
with applicable laws and SNC-Lavalin’s Code of Ethics and Business Conduct,
to which every employee, officer, and member of the Board of Directors
of SNC-Lavalin must adhere.
SPONSORSHIPS 5
CORPORATE CHARITABLE DONATIONS
6
BUSINESS PARTNERS
8
RECORDKEEPING 10
MERGERS & ACQUISITIONS, JOINT VENTURES,
AND MINORITY STAKES
12
ContactS and resources
14
glossary
19
This manual is intended for internal use.
In this document, reference to “SNC-Lavalin” or “Company” means, as the context may
require, SNC-Lavalin Group Inc. and all of its subsidiaries and affiliates, and any joint venture or
consortium of which SNC-Lavalin Group Inc. or any of its subsidiaries or affiliates is a party.
1
II
III
3. This Manual covers seven (7) areas
which commonly present corruption risks
in the business world, namely:
Gifts and hospitality
Business partners
Facilitation payments
Recordkeeping
Sponsorships
NAVIGATING KEY
RISK AREAS
Mergers, acquisitions
and joint ventures
Note: Bolded terms are defined and explained in
the Glossary at the end of this Manual.
Corporate charitable
donations
Since situations can and do arise in these areas where the ethical path forward
is not always immediately clear, this Manual also includes a list of resources
within SNC-Lavalin where employees can seek advice.
This Manual also indicates which business activities require advance written
approval from an employee’s immediate supervisor before proceeding. Such
approvals should be provided in consultation with the responsible Compliance
Officer. Up-to-date contact information for SNC-Lavalin’s Compliance Officers
is available on the Ethics & Compliance Infozone page.
ANTI-CORRUPTION MANUAL
Please read this Manual to better understand the Company’s expectations
for anti-corruption and refer to it regularly in your business activities. When in
doubt, please refer to the contacts and resources available to you, which are
described at the end of this Manual.
SNC-LAVALIN
As an employee of SNC-Lavalin, your integrity and commitment to ethical
business is essential to ensuring that the Company achieves its goal of
becoming a model of global ethics and compliance excellence.
IV
1
4. GIFTS AND HOSPITALITY
GIFTS AND HOSPITALITY
Acceptance of gifts or hospitality from third parties is generally
discouraged. Employees may accept occasional gifts of nominal value
and may accept hospitality provided it is infrequent and serves a legitimate
business purpose. Employees who receive gifts and hospitality must inform
their immediate supervisor within one month of receipt. Should they receive
a gift in excess of nominal value, it must be reported promptly to their
Compliance Officer.
Additional requirements
GIFTS
Employees planning to provide a gift of more than nominal value to a third
party require advance written approval (monetary gifts are always prohibited).
The anti-corruption laws of many countries, and SNC-Lavalin’s Code
of Ethics and Business Conduct, prohibit offering or providing anything
of value (such as gifts, meals, entertainment, travel or lodging and any
other favor/advantage) to a third party (such as a government official,
client, supplier or business partner) in order to obtain an improper
business advantage or otherwise influence official action.
MEALS
Employees planning to offer a meal to a third party must obtain advance
written approval if it is not directly related to SNC-Lavalin’s business, if its
value exceeds that of an ordinary working meal, or if the attendees will include
personal guests of the invited third party.
Furthermore, no gifts or hospitality should be offered
or provided that could reasonably be interpreted by
the recipient or others as a bribe.
ENTERTAINMENT
Employees intending to provide a gift or hospitality to a third party must
ensure that certain conditions are met before proceeding. All such gifts and
hospitality must comply with applicable laws and regulations and be provided
in an honest, open and transparent manner. Gifts and hospitality offered to
third parties must also be appropriate to the occasion and of nominal value. In
certain circumstances, advance written approval from an immediate supervisor
may be required. It is important that all gifts and hospitality be recorded
completely and accurately in SNC-Lavalin’s books and records.
TRAVEL AND LODGING
SNC-LAVALIN
Provision of travel and/or lodging to third parties may only be offered subject
to written approval. Only travel and/or lodging that is directly related to the
promotion, demonstration, or explanation of SNC-Lavalin’s services or to the
performance of a contract is permitted.
ANTI-CORRUPTION MANUAL
All entertainment invitations extended by employees to third parties
require advance written approval. Further, such invitations must serve
a legitimate business purpose.
3
5. Facilitation payments are small, unofficial payments made to government
officials (as opposed to a legitimate government fee or tax), for the purposes of
securing or accelerating the performance of a routine action to which the person
paying is already entitled. Such routine actions may include customs clearance
of goods, issuance of a permit or license, or granting passage through a public
area or facility.
Sponsorships are an important part of SNC-Lavalin’s communication with
customers and they provide a way to strengthen the SNC-Lavalin brand with
selected target groups. This makes them different from donations since their
purpose is to obtain a specific benefit for the Company.
Facilitation payments are considered to be a form
of corruption and therefore are strictly prohibited.
Employees who are requested to make a facilitation payment should notify their
Compliance Officer immediately. Also, anyone who makes a payment that could
reasonably be misunderstood as a facilitation payment should consult with their
Compliance Officer and ensure that the payment is completely and accurately
documented.
Nevertheless, sponsorships present corruption risks
if they are perceived as being linked to seeking or
obtaining an improper advantage.
Employees must adhere to SNC-Lavalin’s corporate policies and procedures
regarding sponsorships, as amended from time to time. Employees should
consult with their Compliance Officer if they have reason to believe that
there is a risk of a sponsorship being perceived as improper or corrupt.
ANTI-CORRUPTION MANUAL
SPONSORSHIPS
SNC-LAVALIN
FACILITATION PAYMENTS
5
6. CORPORATE
CHARITABLE DONATIONS
Additional requirements
WHO CAN RECEIVE CORPORATE DONATIONS?
Donations may not be made to individuals, to for-profit organizations or to
organizations that do not have tax-exempt status or whose goals are not compatible
with the principles in the SNC-Lavalin’s Code of Ethics and Business Conduct.
IMPORTANCE OF TRANSPARENCY
All donations of any kind must be transparent. It must be possible at all times for
the person initiating the donation to justify the reasons for a donation and to be
accountable.
MODE AND FORM OF CORPORATE DONATIONS
Donations should be tax-deductible and payments to private accounts or in cash are
not permitted.
Employees must adhere to SNC-Lavalin’s corporate policies and
procedures regarding corporate charitable donations, as amended from
time to time. Further, they should notify their Compliance Officer if they
have reason to believe that there is a risk of a charitable donation being
perceived as improper or corrupt.
SNC-LAVALIN
Donations may not be offered, promised or given
if they are intended to improperly influence official
action or secure an improper advantage.
ANTI-CORRUPTION MANUAL
Corporate charitable donations offer a way for SNC-Lavalin to contribute
to worthy causes, and reflect the Company’s identity as a responsible global
corporate citizen. However, charitable donations can present potential corruption
risks. Examples include funding charitable organizations that would benefit
a third party (such as a government official), or funding non-existent or
illegitimate charitable organizations to conceal corrupt payments.
7
7. BUSINESS PARTNERS
Any circumstances that appear doubtful, risky or otherwise questionable
to the involved employee(s) must be documented and brought to the
attention of their Compliance Officer.
Additional requirements
DUE DILIGENCE
Before entering or committing to enter into an agreement with a business
partner, the relevant employee(s) of SNC-Lavalin must ensure the prospective
business partner is a person or entity of integrity and good standing in the
business community; and possesses the necessary background, reputation
and qualifications for the service(s) to be provided.
COMMUNICATION WITH, AND TRAINING OF, PARTNERS
Emplopyees must communicate with business partners on SNC-Lavalin’s
expectations with respect to ethics, compliance and anti-corruption and, where
appropriate, ensure that they receive the necessary training on these subjects.
PREVENTION AND DETECTION OF MISCONDUCT
Steps in the business partner review process, such as risk assessment,
risk-based compliance due diligence, final approval of a business partner
and ongoing monitoring activities must be conducted in adherence to SNC-Lavalin
policies and procedures governing business partners, as amended from time
to time.
ANTI-CORRUPTION MANUAL
For this reason, SNC-Lavalin is committed to ensuring
that it only conducts business with partners that adhere
to the same rigorous standards of ethics and compliance
as SNC-Lavalin does, as set forth in the Code of Ethics
and Business Conduct.
Employees must take reasonable steps to prevent and detect any
misconduct and respond appropriately to indications of possible misconduct.
SNC-LAVALIN
Corruption risks exist when companies use third parties as business partners
to obtain or retain business or influence official decisions on their behalf.
9
8. RECORDKEEPING
Additional requirements
ALL DOCUMENTS MUST BE ACCURATE AND TRUTHFUL
False, incomplete or misleading entries and unrecorded bank accounts,
for any purpose, whether regarding sales, purchases or other
Company activity, are strictly prohibited.
LEVELS OF AUTHORITY
All transactions must be conducted at the level of authority required by
SNC-Lavalin policies and procedures, and in compliance with applicable laws,
rules, standards and regulations.
Use of Company funds or other assets for any unlawful or improper purpose
is strictly prohibited. SNC-Lavalin’s managers and officers, as well as those
responsible for the accounting and recordkeeping functions, are expected to be
vigilant not only in ensuring enforcement of this prohibition, but also in having
oversight of the proper use of the Company’s assets.
Where any doubt exists about applicable requirements for recordkeeping,
employees should consult with their supervisor. If additional advice is
required, employees should consult with their Compliance Officer.
All efforts must be made to quickly resolve issues and concerns raised in
internal and external audit reports. Any known inaccuracies, misrepresentations
or omissions must be disclosed to SNC-Lavalin’s customers and suppliers and
promptly corrected through credits, refunds or other mutually acceptable means.
DISCLOSURE OF ALL FINANCIAL INFORMATION
No transaction, asset, liability or other financial information is to be concealed
from management (including Legal Affairs or Corporate Finance), or from
SNC-Lavalin’s internal or external auditors. No secret or unrecorded cash funds
or other assets should ever be established or maintained for any purpose.
ACCESS TO CONFIDENTIAL INFORMATION
Access to sensitive or confidential information is restricted to ensure that it
is not accidentally or intentionally disclosed, modified, misused or destroyed.
ANTI-CORRUPTION MANUAL
In order to prevent corruption, it is important that all
transactions be transparent, fully documented and coded
to accounts that accurately reflect their true nature.
RESOLUTION OF ISSUES AND CONCERNS
SNC-LAVALIN
The laws of the countries in which SNC-Lavalin operates require the Company
to maintain accurate and complete books and records. Furthermore, the
Company’s books and records are the basis of its financial reports and other
disclosures to its clients, partners and other stakeholders, as well as to the
general public. SNC-Lavalin’s books and records also serve as tools to help
management control and direct the Company.
11
9. MERGERS & ACQUISITIONS, JOINT
VENTURES AND MINORITY STAKES
Additional requirements
COMPLIANCE DUE DILIGENCE
The appropriate level of compliance due diligence must be performed
prior to committing SNC-Lavalin to any arrangements involving mergers
and acquisitions, investments, and/or strategic partnerships and joint
ventures, as described in SNC-Lavalin’s Business Partners policy.
LEVELS OF AUTHORITY
Individuals involved in such arrangements must adhere to the level
of authority required by SNC-Lavalin policies and procedures.
Employees involved with acquisitions, joint ventures, strategic partnerships
and/or investment transactions must follow established processes for such
offers and transactions as well as consult, where appropriate, with their
Compliance Officer for additional information and guidance.
SNC-LAVALIN
Failure to perform adequate due diligence prior to
entering into business relationships with third parties
can present significant legal, financial and reputational
risks to the Company.
ANTI-CORRUPTION MANUAL
SNC-Lavalin is frequently involved in acquiring other companies, making
investments, and pursuing strategic partnerships and joint ventures. All such
arrangements with external parties must reflect and uphold SNC-Lavalin’s
standards for integrity and compliance.
13
10. Ethics & Compliance Infozone page
Their supervisor
Compliance Consultation Centre (CCC)
Business Unit and Regional Compliance Officers
Chief Compliance Officer
ETHICS & COMPLIANCE INFOZONE PAGE
Additional ethics and compliance resources and information can
be found on the Ethics & Compliance Infozone page, including:
Code of Ethics and Business Conduct
Links to policies, procedures and guidelines
Overview of all Compliance Officers and contact information
Training materials and presentations
Frequently Asked Questions (FAQs)
Access to Compliance Consultation Centre functions
Information about the Ethics & Compliance Hotline (EthicsPoint)
Content on the Ethics & Compliance Infozone page will be updated on a
regular basis to provide employees with extra practical guidance where needed.
Employees seeking further information or advice on how to address ethics
and anti-corruption matters that arise in the course of business while ensuring
compliance with the principles contained in this guide can consult with the
Compliance Consultation Centre (compliance@snclavalin.com).
This resource is available to all SNC-Lavalin employees.
ANTI-CORRUPTION MANUAL
COMPLIANCE CONSULTATION CENTRE
SNC-LAVALIN
CONTACTS AND
RESOURCES
Employees who need information or advice on the practical application of the
guidance contained in the Manual, related policies and procedures, and other
ethics and compliance-related topics can access the following resources:
15
11. COMPLIANCE OFFICERS
REPORTING AN ISSUE, VIOLATION OR COMPLAINT
The Chief Compliance Officer has assigned a dedicated Compliance Officer
to each of SNC-Lavalin’s business units and regions. Regional and business unit
Compliance Officers are responsible for all compliance matters and initiatives
within their respective region or business unit. In particular, they work to ensure
that SNC-Lavalin’s policies are locally implemented and that the necessary
consultation and approval processes are in place. They are also responsible
for ensuring that the necessary compliance training is available and completed.
SNC-Lavalin employees are required to report any issue, concern or complaint
related to ethics and compliance via the Company’s Ethics & Compliance Hotline,
which is a secure reporting system operated by an independent third-party service
provider. The Ethics & Compliance Hotline allows for anonymous reporting should
the reporter wish to protect his or her identity. The Ethics & Compliance Hotline is
available online at www.snclavalin.ethicspoint.com and by telephone at
the following numbers:
Australia: 1.800.339276
Belgium: 0800.77004
Brazil: 0800.8911667
Canada: 1.855.350.9393
CHIEF COMPLIANCE OFFICER
Chile: 1230.020.5771
COMPLIANCE
PROGRAM AND
MONITORING
COMPLIANCE
TRAINING AND
CONSULTATION
I&C
COMPLIANCE
OFFICER
O&G
COMPLIANCE
OFFICER
COMPLIANCE
INVESTIGATIONS
PROJECT
OFFICE
O&M
COMPLIANCE
OFFICER
M&M
COMPLIANCE
OFFICER
POWER
COMPLIANCE
OFFICER
TRANSPORTATION
COMPLIANCE
OFFICER
EUROPE
COMPLIANCE
OFFICER
AFRICA /
MIDDLE EAST
COMPLIANCE
OFFICER
LATIN /
SOUTH AMERICA
COMPLIANCE
OFFICER
Colombia: 01800.9.155860
France: 0800.902500
India: 000.800.100.1071
Indonesia: 007.803.011.0160
Panama: 001.800.507.2386
Peru: 0800.52116
Russia: 8.10.8002.6053011
Spain: 900.991498
United States: 1.855.420.8647
United Kingdom: 0800.032.8483
ANTI-CORRUPTION MANUAL
Romania: 0808.03.4288
ICI
COMPLIANCE
OFFICER
SNC-LAVALIN
COMPLIANCE
COORDINATION
17
12. GLOSSARY
“Anything of value” means any form of benefit, including gifts, meals,
entertainment, travel and lodging, services, employment, contracts or
advantages of any kind.
“Books and records” means any and all documents relating to the business
affairs of SNC-Lavalin. It includes accounting data, correspondence, contracts,
minutes of proceedings, memoranda and any other descriptive or informative
documents.
SNC-LAVALIN
Developing or acquiring new business;
Marketing SNC-Lavalin’s products and services;
Providing consulting services;
Procuring licenses or permits;
Procuring local contractors, sub-contractors or service providers;
Interfacing with government authorities;
Fulfilling local sponsorship requirements; and/or
Delivering services to clients.
ANTI-CORRUPTION MANUAL
“Business partner” means a third party working with SNC-Lavalin or retained
to act on behalf of SNC-Lavalin for any purpose, including but not limited to:
19
13. Examples of business partners may include agents, representatives,
consultants, sponsors, advisors, business developers, lobbyists, teaming and
pre-teaming partners, consortium partners, joint-venture partners, contractors
and sub-contractors, customs brokers, lawyers and suppliers.
“Charitable donation” means anything of value donated by SNC-Lavalin to
support charitable causes for the purpose of benefiting society or a community,
made without expectation or acceptance of a business advantage in return.
Donations can be cash or in kind, including goods or services, and will result in
a tax receipt in most jurisdictions. Fees for memberships in social and charitable
organizations are also considered donations.
Contributions to industry associations, fees for memberships in organizations
that serve business interests and sponsorships where SNC-Lavalin gets
advertising in return are not charitable donations.
“Corruption” is a criminal offense under the laws of many countries in which
SNC-Lavalin does business. A serious crime, corruption is often punishable by
large fines and imprisonment. Canada’s Corruption of Foreign Public Officials
Act (CFPOA) states in part:
“Government official” means an officer or employee of,
or any person representing or acting on behalf of:
Any level of government (whether federal,
provincial, state, municipal or other);
Entities or enterprises wholly or partially owned or controlled
by a government (such as a state-owned oil company, airline or hospital);
Public international or intergovernmental organizations;
Political parties, party officials and candidates for political office; or
A person who holds a legislative or judicial position.
“Monetary gift” means a gift of cash or cash equivalents.
“Nominal value” means of sufficiently small value that a gift of such value
could not be seen as a bribe or an attempt to improperly influence action or
gain an improper advantage. Examples might include flowers or a book.
“Sponsorship” means a business agreement where SNC-Lavalin makes a
contribution to an organization in exchange for negotiated entitlements. The
entitlements often take the form of publicity, brand visibility, profile for our
employees or other conditions, which are generally outlined in a contract.
“Every person commits an offence who, in order to obtain or retain an advantage
in the course of business, directly or indirectly gives, offers or agrees to give or
offer a loan, reward, advantage or benefit of any kind to a foreign public official
or to any person for the benefit of a foreign public official
(b) to induce the official to use his or her position to influence any
acts or decisions of the foreign state or public international
organization for which the official performs duties or functions.”
Violations of the CFPOA are punishable by a sentence of up to 14 years’
imprisonment and unlimited fines.
ANTI-CORRUPTION MANUAL
(a) as consideration for an act or omission by the official in
connection with the performance of the official’s duties or
functions; or
SNC-LAVALIN
21