2023 Norway Transparency Act Report Atkins Norway AS (942 064 853)

This report was prepared for Atkins Norway AS (“Atkins Norway” or the “Company”) and is made in accordance with the Act relating to enterprises» transparency and work on human rights and decent working conditions (the “Transparency Act”). Atkins Norway is registered at Lilleakerveien 6D, Oslo, 0283, Norway. Atkins Norway ultimate parent company is SNC-Lavalin Group Inc. (“SNC-Lavalin”) and is registered at 455 René-Lévesque West, Montreal, Canada, H2Z 1Z3.

2. Structure & Areas of Operations

The Company was established in Norway in 1987 and is one of the world’s leading design, engineering and project management consultancies. Across our services, we leverage our capabilities to meet the demands of the future for our clients in decarbonization and sustainable solutions by connecting people, data and technology. We harness our global scale to maintain a relentless focus on consistency, efficiency and operational excellence across our portfolio of services complemented by our regional delivery model.

3. Policies and Procedures

SNC-Lavalin (parent company of Atkins Norway) is a signatory to the UN Global Compact since 2015. The approach is aligned with the principles of the OECD Guidelines for Multinational Enterprises.

Code of Conduct

Our Code of Conduct sets the standards of how we work. The compliance with the Code of Conduct is mandatory for all personnel. The Code of Conduct articulates our values and includes a section dedicated to human rights. We aim to maintain high ethical standards in the conduct of our business.

Human Rights Policy

The Human Rights Policy sets out the expectations and guidelines with respect to human rights. We support and respect the protection of internationally recognized human rights, including the Universal Declaration of Human Rights; the Ten Principles of the United Nation Global Compact; the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work; the UN Guiding Principles on Business and Human Rights.

The Company prohibits all forms of modern slavery, forced labour and child labour. The Company permits workers to end, with appropriate notice, their employment; ensures workers maintain free access to their passports, identity papers, work permits, travel documents and other personal legal documents. The Company bears the full cost of recruitment and placement of personnel; prohibits compulsory and abusive overtime practices; pays wages regularly, directly and on time; respects the freedom of association and the rights to worker representation.

Suppliers and Counterparties

We commit to undertake business with integrity and expect our suppliers, subcontractors, and consultants to respect and adhere to our values and high ethical standards of conduct. The Supplier Code of Conduct and the Counterparty Code of Conduct summarizes the expectations and governing principles, including those related to human rights. The Suppliers and Counterparties with which we engage are expected to accept and adhere to our Supplier/Counterparty Code of Conduct.

Human Resources

We have human resources governance documents to protect our personnel/candidates and foster an equitable, diverse and inclusive culture. These include: the Human Resources Policy, Workplace Discrimination, Harassment and Violence Procedure and Equality, Diversity & Inclusion Commitment.

2023 Norway Transparency Act Report 1

4. Risk Assessments

The Compliance Risk Assessment (“CRA”) is designed to help us better understand risks that our business operations may face. The objective is to:

• Produce focused and actionable information when defining risk;
• Determine related remedial action within the organization; and
• Enable the senior leadership to periodically verify the progress of remedial actions.We determine the countries of focus using key risk indicators, including: the personnel headcount, Transparency International Corruption Perception Index, FCPA/UKBA Enforcement actions, revenue per country, Global Slavery Index, number of craft labourers. In each of the selected countries, we distribute a risk survey questionnaire to key managers with questions on bribery and corruption, antitrust, modern slavery, and lobbying. Then, the findings are summarized and discussed with the operational business and senior leadership. CRAs are undertaken every 18 months, to ensure we capture any new risks.

5. Third Party Due Diligence

The Company expects third parties with whom we work to adhere to business principles and values similar to our own and to comply with all applicable laws and regulations. Before making any commitments to third parties, we take steps to evaluate the relationship and mitigate any associated risks by carrying out risk- based due diligence and checks:

• The Vendor Integrity Verification process is an integral part of the Company’s Integrity program. We use multiple screening tools and databases to ensure vendors are ethical through a rigorous screening, including an ongoing monitoring process on our business partners.
• All clients for international projects undergo an Integrity Check. If there are any findings a prior review and endorsement by the Integrity team. Our Integrity Checks verify if a third party is listed on any national or international risk and compliance databases and watch lists (including denied and sanctions lists), has a history of corruption, collusion, fraud or labor/human right violations or related issues through adverse media and publicly available information research, whether it is a state- owned entity/politically exposed people, or appears on a Reference List before we decide whether to proceed with engaging them.
• A uniform risk assessment of business partners performing intermediary functions on our behalf is a companywide requirement. Based on a set of defined risk indicators – such as the risk of corruption in the country in which the work is undertaken – a risk rating (basic, standard or enhanced) is specified for each transaction. The risk rating determines the subsequent action (e.g., due diligence, approval requirements and mandatory contractual clauses) taken regarding business partners.
• Counterparties/Suppliers are required to accept integrity-related contractual provisions and adhere to our Counterparty/Supplier Code of Conduct.
• In high-risk areas, we ensure our contracts with employment agencies stipulate that it is prohibited to require employees to pay recruitment fees. In addition, as part of our on-boarding process in these areas, we verify with craft and general labour workers that they were not asked to pay such fees.

6. Grievance Mechanism

All our personnel, suppliers and counterparties have a duty to report any known or suspected violation of our Code of Conduct or any governance documents, as well as any violation of applicable laws, rules or regulations. These requirements are set out in our Code of Conduct, Compliance Procedure and Supplier Code of Conduct. The various reporting channels are available as per our Reporting work instruction. One such channel is an independent, confidential, and anonymous reporting line operated by an external service provider.

The reporting line allows anyone to report ethical and compliance concerns, including any concerns about human rights. The line is available for both personnel and third parties who may potentially witness a violation. The line is staffed by individuals who speak a variety of languages, to facilitate communication and reporting in any region of the world.

We make sure our personnel can disclose, without fear of retaliation, concerns, complaints or allegations of known or suspected wrongdoing or misconduct, regardless of the local norms and culture. We review all reported matters and investigate when required, within a reasonable timeframe.

7. Training and Awareness

Every year, our personnel at all levels are required to complete a mandatory certification to ensure that our Code of Conduct is understood and properly applied to our daily activities, including on human rights. The Company training curriculum includes training on: Anti-corruption, Antitrust and Competition, human trafficking, business partners, gifts & hospitality, etc.

On our website, we have a short video on our Supplier Code of Conduct which includes a portion on human rights and the Duty to Report. The video is available in four languages (English, French, Spanish and Portuguese).

8. Effectiveness

Monitoring the effectiveness of our actions is a key element to ensure we are reducing the risk. We review all reported matters and investigate when required, within a reasonable timeframe. We keep track of all our employees’ mandatory training sessions: ensuring it is completed on time and following up when necessary. We have audit processes to flag, identify and address potential weaknesses or risks. We believe these are key elements to spread the message, set the tone and to ensure any suspected act of human right abuses is dealt with accordingly.

We use the Compliance Control Framework (“CCF”) to test and monitor the internal controls that comprise its Integrity Program. Led by the Compliance Investigations team, the CFF tests the integrity program key controls. These controls are sampled and tested to determine whether the Integrity Program is being effectively implemented.

For each control procedure of the CCF, we assess the design (i.e., whether the control mitigates the compliance risk identified) and its operating effectiveness (i.e., whether the control operates as planned). To assess the controls operating effectiveness, the control procedures are tested on a sample basis, consistent with our Internal Audit department’s methodology. Testing is performed by obtaining documentation supporting the occurrence of the control procedure and sample sizes are determined based on control frequency.

9. Approval

This report relates to our financial year that ended on December 31, 2022, and was approved by Atkins Norway Managing Director, Lars Magnus Eriksson.