On August 1, 2019, Export Development Canada (EDC) announced a review of Bombardier’s compliance policies and procedures. The review was conducted with Bombardier’s cooperation and was supported by an independent assessment by law firm, McCarthy Tétrault. Today, EDC is announcing the completion of the review.
EDC initiated the review following leaked preliminary findings from the World Bank’s ongoing investigation into Bombardier Transportation’s 2013 contract with Azerbaijan Railways. While EDC was not involved in the transaction under investigation, it was concerned about the allegations released via media reports. The review examined Bombardier’s compliance and ethics policies, and information the company provided in relation to its procedures, controls, and training programs.
“As an important aerospace and transportation company that supports hundreds of supplier companies across the country and thousands of Canadian jobs, Bombardier has been a long-time customer of EDC. We take our mandate to support Canadian exporters as well as our commitments to responsible business seriously, which is why we supported this review. It was important for us to assess Bombardier’s compliance and ethics system as it stands today. The review has demonstrated to us that the company is moving in the right direction and is working towards having a best-in-class program,” said Carl Burlock, Executive Vice-President and Chief Business Officer, EDC.
The review confirmed that Bombardier’s executive management has prioritized making compliance and ethics central to the company’s culture. Recently, the company has made significant investments to strengthen its compliance and ethics program. In 2019, it developed new company-wide compliance and ethics policies that are benchmarked to world standards, which are in the process of being implemented by procedures, processes, and training for employees within all business units. Additionally, Bombardier has been building its Compliance and Ethics Team, allocating significant financial resources and hiring additional personnel to support the implementation of the new policies and related activities. The company is also currently undertaking an enterprise-wide compliance risk assessment and has committed to addressing any identified gaps.
The most significant area for improvement identified by the independent review was the need for Bombardier to strengthen the oversight role of its compliance function. EDC and Bombardier have discussed the review’s findings, and the company’s decision to implement improvement opportunities identified in the review. EDC and Bombardier will have regular engagements as the company undertakes these improvements.
“International trade is a bedrock of our economy and takes Canadian companies, and by extension EDC, to challenging business environments around the world. With its recent investments and actions, it’s clear that Bombardier recognizes the importance of having a strong compliance and ethics program to help identify and manage risks. We thank Bombardier for its cooperation with the review and for committing to working closely with EDC as it matures its compliance program,” said Burlock.
EDC’s priority is to ensure that we have the right processes in place to make responsible business decisions. We take a risk-based approach for all transactions that we consider supporting. Our decision to proceed with providing business support to any transaction, for any exporter, is contingent on whether the parties involved meet our requirements and expectations from a financial perspective and in relation to responsible and sustainable business practices.
