SNC Lavalin : Human rights policy

HUMAN RIGHTS POLICY

	Document No.:	1I-APO-006
Governance Owner: Chief ESG and Integrity Officer
Version:	01
Approved by: Executive Committee	Approval Date:	2022-12-19
	Revision Date:	2022-12-19
Issued by: Integrity
Issuance Date:	2023-01-11

Purpose

The purpose of this policy is to provide SNC-Lavalin's expectations and guidelines with respect to human rights, labour standards and anti-corruption.

Revision Index

Version

Date

Revision Details

01

2022-12-19

Initial version

Users must always verify that they use the most current version available on the Governance Documents section of the intranet.

SNC-Lavalin Policy - HUMAN RIGHTS

1. Scope

The scope of this policy is defined in the Global Glossary.

2. Audience

This policy applies to all SNC-Lavalin personnel.

3. Definitions

All terms in bold and italic are defined in the Global Glossary.

4. Human Rights

4.1. International Standards

We support and respect the protection of internationally recognized human rights.

1. As a signatory of theUN Global Compact since 2015, SNC-Lavalin is committed to carrying out business in compliance with the:
2. • Universal Declaration of Human Rights;
   • Ten Principles of the United Nation Global Compact;
   • International Labour Organization's Declaration on Fundamental Principles and Rights at Work;
   • UN Guiding Principles on Business and Human Rights.
3. Guided by the Constitution of Canada, the United Nations Declaration on the Rights of Indigenous Peoples and the recommendations of Canada's Truth and Reconciliation Commission, SNC-Lavalin is committed to establish and maintain mutually respectful and meaningful relationships between Indigenous communities, our clients and our company. For additional guidance, refer to our Commitment to Indigenous Peoples.

4.2. Human Rights Abuses

We will not be knowingly complicit of human rights abuses.

1. SNC-Lavalinpersonnel must not knowingly commit, participate, provide assistance or encouragement to, human rights violations.
2. When local laws allow behaviour that is not permitted by ourCode of Conduct or governance documents, our Code of Conduct and governance documents prevail.
3. SNC-Lavalinpersonnel must disclose any concerns, complaints or allegations of known or suspected wrongdoing or misconduct, including suspected human rights abuses. For additional guidance, refer to Reporting Work Instruction.
4. No reporter shall suffer retaliation or adverse employment consequences, when coming forward in good faith with their concerns. Any retaliation made against a reporter is a material breach and may lead to disciplinary actions up to and including employment termination.

Users must always verify that they use the most current version available on the Governance Documents section of the intranet.

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SNC-Lavalin Policy - HUMAN RIGHTS

5. Labour Rights

5.1. Freedom of Association

We uphold the freedom of association and the effective recognition of the right to collective bargaining, where local laws permit.

1. SNC-Lavalin respects the freedom of association.
2. SNC-Lavalin respects the right to worker representation.

5.2. Forced Labour

We work towards the elimination of all forms of modern slavery and forced labour.

1. SNC-Lavalin prohibits all forms of modern slavery and forced labour (including prison labor, indentured labor, bonded labor, military labor, modern forms of slavery and any forms of human trafficking).
2. SNC-Lavalin permits workers to end, with appropriate notice, their employment.
3. SNC-Lavalin ensures workers maintain free access to their passports, identity papers, work permits, travel documents and other personal legal documents.
4. SNC-Lavalin bears the full cost of recruitment and placement.
5. SNC-Lavalin prohibits compulsory and abusive overtime practices.
6. SNC-Lavalin pays wages regularly, directly and on time.

For additional guidance, refer to the Human Resources Policy.

5.3. Child Labour

We work towards the effective abolition of child labour:

1. SNC-Lavalinprohibits child labour in any form.

5.4. Discrimination

We work towards the elimination of discrimination in respect of employment.

1. SNC-Lavalinpersonnel must be treated and are expected to treat everyone with respect and dignity and must not be subjected or subject anyone to bullying, intimidation, violence, corporal punishment or physical, sexual, psychological, and verbal harassment or abuse.
2. SNC-Lavalin prohibits discrimination based on beliefs, national or ethnic origin, culture, religion, political convictions, age, mental or physical disability, sex, sexual orientation, gender identity, partnership status, pregnancy, maternity, or any other grounds prohibited by laws.

For additional guidance, refer to the Work Related Discrimination, Harassment and ViolenceProcedure.

Users must always verify that they use the most current version available on the Governance Documents section of the intranet.

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SNC-Lavalin Policy - HUMAN RIGHTS

6. Anti-Corruption

6.1. Bribery and Corruption

We work against corruption in all its forms, including extortion and bribery.

1. SNC-Lavalin prohibits corruption and bribery in all their forms.
2. SNC-Lavalinpersonnel must never accept, request, offer, promise, give or authorize a bribe, kickback, payment or anything that can be considered as such (gifts, entertainment, employment, contracts or benefits of any kind) to or from any third party with the intent to obtain an improper or unfair advantage, retain business or influence that third party's actions.

For additional guidance, refer to the Code of Conduct and Compliance Procedure.

7. Counterparties

SNC-Lavalin promotes integrity and the highest ethical standards in all aspects of its business and wants to work with counterparties who share its values. SNC-Lavalin must not knowingly do business with counterparties who do not adhere to the principles put forward in this policy, regardless of local legislation and customs. For additional guidance, refer to the Counterparty Code of Conduct.

8. Role and Responsibilities

1. SNC-LavalinPersonnel
   All SNC-Lavalin personnel must:
2. 1. Familiarise themselves and act in accordance with this policy and our Commitment to Equality, Diversity & Inclusion.
   2. Be an advocate and actively support equality, diversity and inclusion.
   3. Engage with their colleagues to create an inclusive workplace and ensure psychological safety.
   4. Proactively challenge inappropriate behaviour and report breaches of this policy.
3. Managers

All managers must:

1. Ensure that the decisions they make affecting employment, training, promotion, reward and career development are based only on an individual's skills, talents and ability.
2. Ensure that SNC-Lavalinpersonnel are familiar with this policy and aware of their responsibilities.
3. Proactively address any inappropriate behaviour.

9. Exceptions and Deviations

To request an exception or deviation from this policy, please consult the Deviation Process Work Instruction and use the Deviation Tool.

10. Guidance

For questions or further information with respect to this policy, please contact the Regulatory Compliance Manager.

Users must always verify that they use the most current version available on the Governance Documents section of the intranet.

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SNC-Lavalin Policy - HUMAN RIGHTS

Related documents & regulations (if applicable)

Commitment to Indigenous Peoples

Commitment to Equality, Diversity & Inclusion

Code of Conduct

Counterparty Code of Conduct

Human Resources Policy

Compliance Procedure

Work Related Discrimination, Harassment and Violence Procedure

Discipline and Performance Management Procedure

Reporting Work Instruction

Universal Declaration of Human Rights

Ten Principles of the United Nation Global Compact

International Labour Organization's Declaration on Fundamental Principles and Rights at Work

UN Guiding Principles on Business and Human Rights

United Nations Declaration on the Rights of Indigenous Peoples

Users must always verify that they use the most current version available on the Governance Documents section of the intranet.

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