The following situations are some examples of actual, potential or
perceived conflicts of interest related to secondary employment and
conflicting/incompatible activities:
Performing activities or tasks that conflict or are otherwise incompatible
with one another within the course of our work at SNC-Lavalin (for
example, the person requisitioning the procurement of goods or services
is also the one approving the procurement transaction);
Engaging in secondary employment relationships that restrict our ability
to fulfill our duties at SNC-Lavalin;
Accepting a directorship for a third-party organization without first
disclosing to and obtaining the consent of our manager and Human
Resources or, as the case may be, the Board of Directors;
Owning (whether directly or indirectly) a significant financial interest
in an outside enterprise which does or seeks to do business with, or
is a competitor of, SNC-Lavalin (real estate and mineral interests are
particularly sensitive);
Participating (whether directly or indirectly) in outside business or
financial activities that compete or potentially compete with SNC-Lavalin;
Participating (whether directly or indirectly) in an outside business that
supplies services to or has business dealings with SNC-Lavalin where
there is the possibility of preferential treatment being received by virtue
of our position within SNC-Lavalin; and
Conducting business on behalf of SNC-Lavalin with a member of our
family, or a business organization with which we or a member of our
family has an association, which could be perceived as a conflict of
interest, unless such business dealings have been disclosed to our
manager and Human Resources or, as the case may be, the Board of
Directors prior to any arrangement, and a specific non-objection decision
has been given.
3.2 SNC-Lavalin permits the employment of individuals from the
same family or who have a personal relationship with another
employee, as long as there is no actual, potential or perceived
conflict of interest.
In this context, some examples of situations constituting actual, potential
or perceived conflict of interest are:
Reporting directly or indirectly to a family member or someone with
whom we have a personal relationship;
Exerting influence on another employee for the benefit or to the
detriment of a family member or someone with whom we have a
personal relationship; and
Acting as a direct or indirect supervisor of a family member or someone
with whom we have a personal relationship.
We recognize that SNC-Lavalin’s growth stems in part from the acquisition
of family-owned businesses. Family or personal relationships within such
businesses may perhaps give rise to actual, potential or perceived conflicts
of interest which, as a publicly traded corporation, we commit to mitigating
in a diligent manner.
Should we have any doubt as to whether our relationship with another
employee could constitute an actual, potential or perceived conflict of
interest, we are strongly advised to contact Ethics & Compliance, Human
Resources or Legal Affairs for further guidance.
In any case where our family or personal relationships give rise to actual,
potential or perceived conflicts of interest, it is our responsibility to
declare such conflicts and therefore are required to immediately complete
the disclosure form available on Infozone. Self-reporting of personal
relationships to Human Resources will be treated with the utmost
discretion and confidentiality.
Personal Relationships
in the Workplace
employment relationships with another business or any
directorship in another organization.
We may not initiate or continue such activities without the written
authorization of our manager and Human Resources. Board members
must disclose their non–SNC-Lavalin directorships or significant business
activities to the Vice-President and Corporate Secretary. Finally, we must
refrain from performing or being involved in activities incompatible with
our work at SNC-Lavalin.