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Andreas Pohlmann, chief compliance officer of SNC-Lavalin Group: ‘To get out a compliance program in Montreal at the headquarters of SNC-Lavalin is easy. It becomes challenging when we go to the more difficult regions of this world.’CHRISTINNE MUSCHI/The Globe and Mail

KARL MOORE – This is Karl Moore of the Desautels Faculty of Management at McGill University, talking management for The Globe and Mail. Today, I am delighted to speak with Andreas Pohlmann, who is the chief compliance officer at Canadian [engineering] giant SNC[-Lavalin Group Inc.]

So Andreas, we look at it that ethics means different things around different parts of the world. How do you have a global approach to ethics in a global company, SNC?

ANDREAS POHLMANN We at SNC-Lavalin are globally operating and the experience tells us that in order to have our employees behave ethically and in line with legal regulations all over the world, we need one global compliance program.

That means that what we are doing at the time being is not establishing a Canadian compliance program, or a North American compliance program, but we are establishing a global compliance program for all of our associates all over the world, and that's the challenge. To get out a compliance program in Montreal at the headquarters of SNC-Lavalin is still easy. It becomes challenging when we go to the more difficult regions of this world, like Latin and South America, Africa, Eastern Europe and Southeast Asia. We have to get to the hearts and minds of our people and have them live up to our worldwide standards; otherwise, the compliance program would not be credible.

KARL MOORE – Where does the worldwide standard come from? Does it come from North America? Where does it come from?

ANDREAS POHLMANN– The worldwide standard, I would say, comes from especially the United States. The U.S. came up with the U.S. Foreign Corrupt Practices Act in 1977, after the Lockheed [bribery] affair and this USFCPA is now the standard for globally operating companies, like Siemens, like Daimler, like SNC-Lavalin. Others followed, like the U.K. Bribery Act of 2010-2011, and now the CFPOA [Corruption of Foreign Public Officials Act] in Canada and others more, Brazil in 2013…

KARL MOORE – So we have to give credit to the Americans for leading the way on this.

ANDREAS POHLMANN – I think at least they gave some guidance on how to deal with anti-corruption issues. The U.S. are far more advanced – I am a guest to Canada, so I have to be polite, but if I had to compare the United States with Canada, I would say the United States are 20 years ahead of Canada and 10 years ahead of Europe.

KARL MOORE – Why do you think the U.S. is ahead of the rest of the world, in this matter?

ANDREAS POHLMANN – Because they are already living with the USFCPA since 1977. They had the experience, they had to live up after the Lockheed affair, they enforced the USFCPA rigorously within their territory and beyond their territory. If I look back at 2007 to 2010, they even looked at Siemens. Siemens is a German company. Or take the latest example of BHP Billiton, an Australian company bribing in China and being prosecuted by the U.S. [Department of Justice]. So that shows you that the U.S. are really enforcing anti-corruption regulations all over the world.

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