SNC-Lavalin wishes to make a clarification about a Canadian Press article, which was notably published by the National Post, The Montreal Gazette, CTV News and City News.
In this article about the agreement between Elections Canada and SNC-Lavalin announced on September 8, the Canadian Press states that "The deal includes SNC-Lavalin hiring an in-house ethics watchdog, putting in place new compliance and governance policies to detect, curb and prevent ethically problematic practices, and updating its corporate code of conduct to specifically deal with political donations."
This implies that these measures are imposed on SNC-Lavalin following the agreement. This is not the case and it’s actually the other way around. These measures had already been put in place in the past few years, which is one of the factors taken into consideration by the Elections Canada commissioner to reach an agreement with SNC-Lavalin. This is outlined in the agreement https://www.cef-cce.gc.ca/content.asp?section=agr&document=aug3016&lang=e, which recognizes that SNC-Lavalin has:
- put in place compliance and governance policies to detect, curb and prevent ethically problematic practices;
- created and filled the position of Head of Compliance and Ethics, which is responsible for compliance, ethics and good governance within the Contracting Party, and reinforced the role and functions related to that position;
- updated its Code of Ethics and Business Conduct, which contains a clause that deals specifically with political contributions. This clause ensures that the Contracting Party will not reimburse any political contribution, either directly or indirectly, made to any Canadian federal political entity. It also contains a prohibition on making political contributions on behalf of the Contracting Party. Lastly, the Code prohibits the use of time, funds, assets, resources, or list of employees of the Contracting Party for political activities, and the soliciting of personnel of the Contracting Party for political contributions during working hours;
- implemented a policy on political contributions that provides that the Contracting Party may not reimburse or compensate directly or indirectly, in any manner, political contributions made by its employees;
- implemented an internal control and monitoring process in order to detect non-compliant practices; and
- prior to the Commissioner's investigation, put in place an internal administrative amnesty system for a period of approximately three months (which allowed the Contracting Party to identify some of the contraventions in question), as well as an ethics and compliance help line for employees and other individuals to report, confidentially and without fear of reprisal, any cases of non-compliance they may have witnessed.
To learn more about SNC-Lavalin’s ethics and compliance program, which is based on international best practices, visit.