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MODERN SLAVERY ANDHUMAN TRAFFICKINGSTATEMENT2022
SNC-L AVALIN MODERN SL AVERY AND HUMAN TR AFFICKING STATEMENTAt SNC‑Lavalin, we are committed topreventing modern slavery and humantrafficking in our operations. We arededicated to protecting our people fromany form of modern slavery and humantrafficking by promoting our core values:2
CONTENTSStructure, Operations and Supply Chain5Structure and Operations5Supply Chain8Risks8Compliance Risk Assessments8Craft Labour Workers8Recruitment Process8Actions11Policies and Procedures11Duty to Report13Due Diligence13Training and Awareness14Aligning with Global Initiatives and Best Practices14Effectiveness17Compliance Control Framework17Our Commitment173
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STRUCTURE,OPERATIONS ANDSUPPLY CHAINSTRUCTURE AND OPERATIONSFounded in 1911, SNC‑Lavalin is one of the world’s leadingprofessional services and project management organizations,dedicated to engineering a better future for our planet andits people. SNC‑Lavalin creates sustainable solutions thatconnect people, data and technology to design, deliver andoperate the most complex projects across the world.MarketsSNC‑Lavalin is strongly positioned with a leadingpresence across Canada, the United States, and theUnited Kingdom, as well as targeted operations inEurope, the Middle East, Asia-Pacific, and Latin America.SNC‑Lavalin has primary focus on the built and naturalenvironment across seven clearly defined end markets:TRANSPORTATIONRail and Transit,Road and Bridges,Aviation and PortsWATERWater Utilities,Industrial WaterUsers, Water ResourceManagementBUILDING &PLACESSocial Infrastructure,Commercial andResidential Property,Urban DevelopmentPOWER &RENEWABLESTransmission andDistribution, EnergyStorage, Hydropower,Renewable EnergyDEFENSEAerospace, Defense,SecurityINDUSTRIAL& MININGPharma, Agri-food, DataCentres, Industrial,Life Sciences, Miningand MetallurgyNUCLEARWaste Managementand Decommissioning,Reactor Support,New Build5
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ServicesWe deploy global capabilities locally to our clientsand deliver unique end-to-end services acrossthe whole life cycle of an asset, including:CONSULTING, ADVISORYAND ENVIRONMENTALSERVICESINTELLIGENTNETWORKS ANDCYBERSECURITYDESIGN RATIONS ANDMAINTENANCEPROJECT ANDCONSTRUCTIONMANAGEMENTAcross our services, we leverage our capabilitiesto meet the demands of the future for our clientsin decarbonization and sustainable solutionsby connecting people, data and technology. Weharness our global scale to maintain a relentlessfocus on consistency, efficiency and operationalexcellence across our portfolio of services complemented by our regional delivery model.We offer services individually or as aseamless, integrated partner, on smallprojects, long-term frameworks, and throughcollaborative roles on major projects.As a services business, everything we do isdriven by our people and ideas. They havecreated an inclusive, diverse and energizedwork environment and share an open culturefounded on our values: SAFETY, INTEGRITY,INNOVATION and COLLABORATION.Growth & Long-Term ValueWe create value through the breadth and depthof our capabilities, consistently delivering highquality services to our customers, and a clearinvestment plan that will enable organic andinorganic growth. In addition to consistentlydriving growth in our core markets and services,we have identified four key growth areas:› Engineering Services in the U.S.› Nuclear Waste Management andDecommissioning (mostly in the U.S.)› Major Projects with a focus oncollaborative contract models› Digital TransformationIn 2021 and as part of that strategy, SNC‑Lavalinannounced that it has closed the sale of itsResources Oil & Gas business, which markedanother important step in the journey thatbegan two years ago, when we first announcedour strategic direction to simplify and derisk our business. We believe the companystrategy has effectively reduced our risk ofmodern slavery and human trafficking.7
SNC-L AVALIN MODERN SL AVERY AND HUMAN TR AFFICKING STATEMENTSUPPLY CHAINOur ExpectationsThe Company acknowledges the importanceof ensuring that our suppliers deliver theirproducts and services in a responsible andethical manner to us and to our clients. We arecommitted to partnering with our supply chainin a manner consistent with our core values, andmost specifically relating to safety, integrity,quality and sustainability. For information onstandards demanded throughout our supplychain, please watch this short video.We recognize that there are risks regardingmodern slavery and human trafficking in oursupply chains. That environment is ever-changing,as our business spans, and fluctuates over manygeographies and industry sectors, and a newchain is created for each new project that weembark upon. Depending on the requirementsof each project, participants in these supplychains might include, subcontractors, equipmentand material suppliers, labor brokers, and avariety of specialized service providers.RISKSCOMPLIANCERISK ASSESSMENTSIn 2021, the ad-hoc risk assessments todetermine where our operations presented ahigher risk of modern slavery were includedto our Compliance Risk Assessment (“CRA”)process. The CRA is questionnaire-based todetermine salient risks. Corrective and preventivemeasures are discussed with managementand implementation is monitored by theIntegrity team. The KPI analysis for selectingjurisdictions included the Global Slavery Index.8CRAFT LABOUR WORKERSWe understand the risk of using craft labourworkers, especially migrant workers. Thesale of the Resources Oil & Gas businesssignificantly reduced our exposure torisks related to craft labour workers.RECRUITMENT PROCESSIt is well documented that the recruitmentprocess, including the use of recruitment orplacement agencies, may be a risk in termof modern slavery. We engage and work incollaboration with our recruitment or placementagencies to ensure no fees or costs of anykind are charged, no documents are withheld,no underage people are recruited, etc.
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ACTIONSPOLICIES AND PROCEDURESTo ensure the transparency of the process,the company makes all governancedocuments available to all employeesand main integrity-related governancedocuments available to the general publicCode of ConductOur Code of Conduct sets the standardsof how we work. This important documentarticulates our values and includes a sectiondedicated to modern slavery. We aim tomaintain high ethical standards in the conductof our business. As a result, compliance withthe Code of Conduct is mandatory for allpersonnel: it is a condition of working with us.Compliance ProcedureConsidering that our personnel are the front-lineagents in the application of our Integrity value, wehave a Compliance Procedure operationalizingthe principles laid out in our Code of Conduct.These principles relate to anti-corruption andbribery, facilitation payments, antitrust, politicalcontributions, gifts and hospitality, duty to reportand how we deal with business partners.Suppliers and CounterpartiesWe commit to undertake business with integrityand expect our suppliers, subcontractors,and consultants to respect and adhere to ourvalues and high ethical standards of conduct.The Supplier Code of Conduct and theCounterparty Code of Conduct summarizesSNC‑Lavalin’s expectations and governingprinciples, including those related to humanrights, modern slavery and human trafficking.Suppliers and Counterparties we engage withare expected to accept and adhere to ourSupplier/Counterparty Code of Conduct.ProcurementWe strive to be competitive, yet fair and ethical inour business practice. To ensure the effectivenessof the process, the company has implementeda procurement policy that our personnel mustfollow. The policy communicates SNC‑Lavalin’sprocurement principles and rules and contributesto create and maintain effective supply chainmanagement capabilities, processes, andsystems. Relevant governance documents includethe Purchasing Management Procedure, VendorIntegrity Verification Procedure and ProjectRisk Identification work instruction which setout the necessary precautions to be taken toavoid modern slavery and human trafficking.11
SNC-L AVALIN MODERN SL AVERY AND HUMAN TR AFFICKING STATEMENTHuman ResourcesWe also have human resources governance documentsto protect our personnel and candidates from modernslavery and human trafficking. These include: theHuman Resources Policy and Workplace Discrimination,Harassment and Violence Procedure. We have updatedthe Human Resources Policy to reflect our position onmodern slavery and human trafficking which includes:› Prohibiting human rights abuses, and any activitiesthat encourage modern slavery, human trafficking,child labour, bonded labour, or forced labourand requiring our suppliers to do the same;› Permitting workers, the choice to end, withappropriate notice, their employment;› Ensuring workers maintain free access to their identitydocuments thereby allowing freedom of movement;› Ensuring freedom of association;› Bearing the full cost of recruitment and placement;› Prohibiting compulsory and abusive overtime practices;› Paying wages regularly, directly and on time; and› Respecting the right to worker representation.SustainabilityWe put sustainability at the heart of our corporate andproject activities and business strategy. For that reason,every year we commit in our Sustainability Policy Statementto conduct business activities in a way that is beneficialto society and global and local economies. Therefore,our sustainable business strategy is aligned with the UNSustainable Development Goals. We help clients addressthe global, local, social, environmental and economicimpacts, opportunities and risk associated with our projects12
DUTY TO REPORTDUE DILIGENCEAt SNC‑Lavalin, all our personnel, suppliers andcounterparties have a duty to report any known orsuspected violation of our Code of Conduct or anygovernance documents, as well as any violationof applicable laws, rules or regulations. Theserequirements are set out in our Code of Conduct,Compliance Procedure and Supplier Code of Conduct.At SNC‑Lavalin, we expect third parties we work withto adhere to business principles and values similar toour own and to comply with all applicable laws andregulations. Before making any commitments towardsthird parties, we take steps to appropriately evaluatethe relationship and mitigate any associated risks bycarrying out risk-based due diligence and checks:The various reporting channels are set out in ourReporting Work Instruction. One such channel, theReporting Line, is an independent, confidential, andanonymous reporting line operated by an externalservice provider. The reporting line allows anyone toreport ethical and compliance concerns, including anyconcerns about modern slavery and human trafficking.The line is available for both SNC‑Lavalin personnel andthird parties who may potentially witness a violationby our personnel or anyone working on our projects.The line is staffed by individuals speaking a variety oflanguages, to facilitate communication and reportingin any region of the world. We make sure our personnelcan disclose, without fear of retaliation, concerns,complaints or allegations of known or suspectedwrongdoing or misconduct, regardless of the localnorms and culture. We review all reported matters andinvestigate when required, within a reasonable timeframe.› The Vendor Integrity Verification process isan integral part of SNC‑Lavalin’s Integrityprogram. We use multiple screening tools anddatabases to ensure vendors are ethical througha rigorous screening, including an ongoingmonitoring process on our business partners.› All clients for international projects undergo anIntegrity Check. If there are any findings a prior reviewand endorsement by an Integrity Officer is required,as well as approval up to the Sector President.› Our Integrity Checks verify if a third party is listedon any national or international risk and compliancedatabases and watchlists (including deniedand sanctions lists), has a history of corruption,collusion, fraud or labor/human right violations orrelated issues through adverse media and publiclyavailable information research, whether it is astate-owned entity/politically exposed person, orappears on SNC‑Lavalin’s Reference List before wedecide whether to proceed with engaging them.› A uniform risk assessment of business partnersperforming intermediary functions betweenSNC‑Lavalin and third parties is a companywiderequirement. Based on a set of defined risk indicators– such as the risk of corruption in the country in whichthe work is undertaken – a risk rating (basic, standardor enhanced) is specified for each transaction. Therisk rating determines the subsequent action (e.g.,due diligence, approval requirements and mandatorycontractual clauses) taken regarding business partners.› Counterparties/Suppliers are required to acceptintegrity-related contractual provisions and adhereto our Counterparty/Supplier Code of Conduct.› In high-risk areas, we ensure our contracts withemployment agencies stipulate that it is prohibitedto require employees to pay recruitment fees.In addition, as part of our onboarding process inthese areas, we verify with craft labour workersthat they were not asked to pay such fees.13
SNC-L AVALIN MODERN SL AVERY AND HUMAN TR AFFICKING STATEMENTTRAINING AND AWARENESSEvery year, SNC‑Lavalin personnel atall levels are required to complete amandatory certification process to ensurethat our Code of Conduct is understood andproperly applied to our daily activities.For our craft and general labor workforce, weensure awareness of our Code of Conduct andvalues by providing information by various meanssuch as onboarding presentations and posters.Pictograms have specifically been developedto aid understanding and knowledge of theprinciples covered by the Code of Conduct. Themodern slavery and human trafficking toolbox(which includes posters and a facilitation guide)provides our workforce with a summary of ourmodern slavery and human trafficking principles,giving real life examples and advising how toreport any suspected or known violations.To ensure a good understanding of the risksof modern slavery and human trafficking inour supply chains and business, we provideadditional training for personnel in keypositions. Our training actively explains humantrafficking, how to recognize it, and proposescompliance strategies to use internally andthroughout the supply chains. Every memberof our board of directors has completed it aspart of their onboarding. It is also available toall our employees and each manager may, attheir discretion, assign it to their employees.In addition, we have on our website a short videoon our Supplier Code of Conduct which includesa portion on human rights and the Duty toReport. The video is available in four languages(English, French, Spanish and Portuguese).14ALIGNING WITH GLOBALINITIATIVES ANDBEST PRACTICESIn late 2015, we joined the United Nations GlobalCompact (UNGC), the world’s largest corporatesocial initiative, with more than 9,000 businessand 3,000 non-business participants in more than160 countries. Joining the UNGC underscoresour commitment to putting our extensive knowhow and resources to work to meet the world’ssustainability challenges. It also signals ourintention to align our strategies and operationswith the UNGC’s ten Principles on human rights,labor, environment and anti-corruption.For a second year, on World Day AgainstTrafficking in Persons, we took the opportunityto reiterate internally our commitment toprevent modern slavery and human traffickingin our operations. We shared a reading listand an animated video on our intranet
My passport isbeing detainedwithout myconsent.What should I do?SPEAKUP!Modern slavery and humantrafficking are strictlyprohibited.If you want to report something or needadvice, talk to any one of the following:› Your supervisor› Your Human Resources representative› Your security or health, safety and environment representative› Your Integrity Officer› Legal Affairs› The SNC-Lavalin Reporting Line15
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EFFECTIVENESSMonitoring the effectiveness of our actionsis a key element to ensure we are effectivelyreducing the risk of modern slavery.As previously mentioned, we undertake toreview all reported matters and investigatewhen required, within a reasonable timeframe.We keep track of all our employees’ mandatorytraining sessions: ensuring it is completed ontime and following up when necessary. We haveaudit processes to flag, identify and addresspotential weaknesses or risks. We believe theseare key elements to spread the message, setthe tone and to ensure any suspected act ofmodern slavery is dealt with accordingly.COMPLIANCECONTROL FRAMEWORKSNC‑Lavalin has used its Compliance ControlFramework (“CCF”) to test and monitor theinternal controls that comprise its IntegrityProgram. The CCF is carried out by membersof the Compliance Investigations team (“CI”).CI identifies main risks we face that are relatedto integrity and holds discussions with relevantstakeholders to identify the key controls thatdirectly respond to those risks. These controlsare sampled and tested by the review team todetermine whether the Integrity Program isbeing implemented effectively in practice.OUR COMMITMENTAt SNC‑Lavalin, we are committed to preventingmodern slavery and human trafficking in ouroperations. We are dedicated to protecting ourpeople from any form of modern slavery andhuman trafficking by promoting our core values:Safety, Integrity, Collaboration and Innovation.We do not tolerate any form of forced labour,slavery or human trafficking in any part of ourbusiness. As a signatory to the UNGC, we arecommitted to implementing internationallyrecognized best practices. This includes adheringto the sixth principle that addresses workingconditions and human rights. Our Code of Conductand Supplier Code of Conduct specifically prohibithuman trafficking as well as child and forcedlabor. All personnel must abide by our Code ofConduct. In fact, they must undergo mandatoryannual certification on the Code, followed byan exam that they need to pass to continueworking with us. In terms of our operations, oursustainable business strategy is aligned with theUN Sustainable Development Goals. Our missionis to do business while taking into considerationthe economic, social and environmental realitiesin different countries around the world.17
This statement relates to our financial yearthat ended on December 31, 2021 and ismade in accordance with the UK ModernSlavery Act 2015 and the AustralianModern Slavery Act 2018 (Cth). It applies toSNC‑Lavalin Group Inc. and all its subsidiaries.IAN L. EDWARDSPresident and CEOBOARD OF DIRECTORSSNC‑Lavalin Group Inc.REPORTING ENTITY:SNC‑Lavalin Group Inc.455 boul. René-Lévesque OuestMontreal, Québec, Canada, H2Z 1Z3
announced that it has closed the sale of its Resources Oil & Gas business, which marked another important step in the journey that began two years ago, when we first announced our strategic direction to simplify and de‑ risk our business. We believe the company strategy has effectively reduced our risk of modern slavery and human trafficking.
