Detection measures identify misconduct, compliance gaps and violations. This is done through:

  • Effective controls
  • Resources and skills for global deployment of compliance investigations
  • Regular ethics and compliance audits
  • Regular compliance reviews
  • Yearly risk assessments
  • An external review and assessment of the program

Compliance Investigations

Competent, comprehensive and confidential – our expert compliance investigations team is world-class.

Our 16-member compliance investigation team investigates compliance violations and is separate from the internal audit function. They work in nine languages (Arabic, Cantonese, English, French, Greek, Italian, Mandarin, Portuguese, Spanish) and are located in Montreal, Toronto, Ivry-sur-Seine (France), Al-Khobar (Saudi Arabia), Abu Dhabi (UAE), Dubai (UAE) and London (UK).

Investigation reports are presented to the Ethics & Compliance Committee, which determines disciplinary sanctions and further preventive measures.

Compliance Reviews

Regular reviews and communications are key to making sure we’re on track.

Our compliance officers receive regular reports on key performance indicators that assess our program’s efficiency. They then hold regular reviews with top and middle management, both within sectors, corporate functions and by region.


Compliance Control Framework

Our compliance control framework monitors the effectiveness of our ethics and compliance program.

A control framework is a network of internal controls and testing procedures designed to ensure that risks are properly mitigated. It involves continuous testing of the effectiveness of all the elements of the program. There are ten areas of focus.

Ethics and Compliance Reporting Line

Our reporting line is an independent, confidential and anonymous way to report ethical and compliance concerns.

Our Ethics & Compliance Reporting Line is operated by an external service provider. Employees anywhere in the world can report misconduct without fear of retaliation, at any time. This can be done online or by telephone (

Channels for Reporting Misconduct and Seeking Advice

When in doubt about an issue, we can either ask someone or tell someone.

Employees can use various channels to report any suspected misconduct or for asking advice.

  • The Compliance Consultation Center (
  • Their immediate supervisor
  • Human Resources Vice-President of their Business Unit
  • Corporate Contacts in Global Human Resources
  • Legal Affairs
  • Internal Audit
  • Ethics and Compliance Reporting Line (