AtkinsRealis Group Inc

Lobbying Governance

AI Extracted Evidence Snippet Source

### C12.3f

(C12.3f) What processes do you have in place to ensure that all of your direct and indirect activities that influence policy are consistent with your overall climate change strategy?

The Global Head of Sustainability (equivalent to a CSO), ensures that policies relating to climate change and other sustainability issues are consistent across all our activities.

The Global Head of Sustainability, along with the Corporate Government Relations representatives responsible for Canada and Ontario report to the Executive Vice President of Strategy, Marketing and External Relations (SMER). The Corporate Government relations representatives are responsible to ensure that SNC-Lavalin's policies and overall strategic objectives are effectively communicated to governments across Canada, inclusive of climate change policy and strategy. The Corporate Government relations representative for Canada ensures coordination with government relations representatives in business sector specific geographies across the company. The EVP of SMER ensures continuity between Sustainability and Government and External Relations.

https://www.atkinsrealis.com/en/media/download-center/report/cdp-report-2020

**4.** **Responsible Governance**

The Governance, Ethics and Sustainability Committee (GESC) of the Board of AtkinsRéalis receives quarter by quarter reports on payments made to representatives and sponsors from the Chief ESG and Integrity Officer. The GESC also annually reviews the specific report of the Executive Vice-President, Strategy, Growth and Government Relations on AtkinsRéalis' Political Action Committee (PAC) activities and ballot initiatives in the United States.

The Executive Vice-President, Strategy, Growth and Government Relations is responsible for reporting on lobbying and political participation to the GESC.

**5.** **Lobbying by AtkinsRéalis**

AtkinsRéalis maintains registrations for in-house lobbyists as required by law and regulation in the jurisdiction. Most such activity takes place in Canada (federally, Quebec and Ontario), in the United States (nationally and in some states/counties). AtkinsRéalis' Vice-President of Government Relations provides guidance and best practices to the Company's business sectors as regards communications with officials and politicians and reporting obligations.

In Canada, we communicate with government in a way that is fully consistent with the federal Lobbying Act and other applicable laws and regulations. Per Canadian federal and provincial laws, the most senior officer in the Company (the CEO) is responsible for ensuring that employees who lobby are informed of their obligations under the federal Lobbying Act and of their duty to abide by the principles of the Lobbyists' Code of Conduct.

On a monthly basis, AtkinsRéalis files reports certified by the CEO on our federal lobbying activities and any other reportable activities.

https://www.atkinsrealis.com/~/media/Files/A/atkinsrealis/download-centre/en/report/lobbying-and-political-activities-2022-en.pdf

**4. Responsible Governance**

The Governance, Ethics and Sustainability Committee (GESC) of the Board of AtkinsRéalis receives quarter by quarter reports on payments made to representatives and sponsors from the Chief ESG and Integrity Officer. The GESC also annually reviews the specific report of the Executive Vice-President, Strategy, Growth and Government Relations on AtkinsRéalis' Political Action Committee (PAC) activities and ballot initiatives in the United States.

The Executive Vice-President, Strategy, Growth and Government Relations is responsible for reporting on lobbying and political participation to the GESC.

**5. Lobbying by AtkinsRéalis**

AtkinsRéalis maintains registrations for in-house lobbyists as required by law and regulation in the jurisdiction. Most such activity takes place in Canada (federally, Quebec and Ontario), in the United States (nationally and in some states/counties). AtkinsRéalis' Vice-President of Government Relations provides guidance and best practices to the Company's business sectors as regards communications with officials and politicians and reporting obligations.

In Canada, we communicate with government in a way that is fully consistent with the federal Lobbying Act and other applicable laws and regulations. Per Canadian federal and provincial laws, the most senior officer in the Company (the CEO) is responsible for ensuring that employees who lobby are informed of their obligations under the federal Lobbying Act and of their duty to abide by the principles of the Lobbyists' Code of Conduct.

On a monthly basis, AtkinsRéalis files reports certified by the CEO on our federal lobbying activities and any other reportable activities.

For the year 2022, AtkinsRéalis had 35 reportable communications with designated public office holders at the federal level.

At the national level, AtkinsRéalis' lobbyist registration can be found at the website of the Office of the Commissioner of Lobbying of Canada: https://www.lobbycanada.gc.ca/ [...] In the United States, we communicate with government in a way that is fully consistent with the Lobbying Disclosure Act and other applicable federal, state and local law and regulation. The Lobbying Disclosure Act of 1995, as amended by the Honest Leadership and Open Government Act of 2007, requires all active registrants to file quarterly activity reports with the Clerk of the U.S. House of Representatives and Secretary of the U.S. Senate. In addition, the amended act requires active lobbying registrants and individual lobbyists to file a semi-annual report of certain contributions along with certification that the filer understands the gift and travel rules of both the House and Senate. Registrants and each of their lobbyists who were active for all or part of the semi-annual reporting period must file separate reports detailing their contributions, including Federal Employee Compensation Act, honorary, Presidential Inaugural Committee, Presidential Library and certain payments for event costs. At the federal level, a full list of our reportable communications can be found at the Office of the Clerk for the U.S. House of Representatives regarding the Lobbyist Disclosure Act and Registry: https://lobbyingdisclosure.house.gov/ [...] In the United Kingdom, the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act requires the registration of consultant lobbying. In addition to statutory registration, individual lobbyists or lobbying organizations can register at the UK Lobbying Register, which aims to promote transparency and professional standards in this industry. In addition, UK government departments publish online quarterly reports detailing ministerial meetings with interest groups and hospitality received by ministers and their advisers. Details of meetings between officials and outside groups are not published. This includes the list of civil servants who must publish details of hospitality and expenses. The codes of conduct that apply to government ministers, Members of Parliament and civil servants include strict requirements on how they must deal with lobbyists, including the registration of interests as well as gifts, benefits or hospitality that they receive.

https://www.atkinsrealis.com/~/media/Files/A/atkinsrealis/download-centre/en/report/lobbying-and-political-activities.pdf

Support SNC-Lavalin's CEO as well as other SNC-Lavalin's employees are registered in the Office of the Commissioner of Lobbying of Canada's registry and at the Office of the Clerk for the U.S. House of Representatives. Among the subject discussed with federal representatives, the following issues were raised: › Efficient approval processes for major energy projects; › Recommendations on Federal policy regarding nuclear power development in Ontario; › Infrastructure funding at the federal level; › Support for energy work plans that include Candu nuclear power new builds in China and Argentina; › Engagement in the selection process of Ontario Power Generation pertaining to choice of technology toward a small module reactor (SMR) nuclear project; › Support for an SMR development fund to be introduced by the Government of Canada. [...] The Global Head of Sustainability (equivalent to a CSO), ensures that policies relating to climate change and other sustainability issues are consistent across all our activities. The Global Head of Sustainability, along with the Corporate Government Relations representatives responsible for Canada and Ontario report to the Executive Vice President of Strategy, Marketing and External Relations (SMER). The Corporate Government Relations representatives are responsible to ensure that SNC-Lavalin's policies and overall strategic objectives are effectively communicated to governments across Canada, inclusive of climate change policy and strategy. The Corporate Government Relations representative for Canada ensures coordination with government relations representatives in business sector specific geographies across the company. The EVP of SMER ensures continuity between Sustainability and Government and External Relations.

https://www.atkinsrealis.com/en/media/download-center/report/cdp-report-2021

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Our engagement activities mostly pertaining to our home country are summarized in our lobbying and political report, which is published annually, usually in October. Please see: https://www.snclavalin.com/~/media/Files/S/SNC-Lavalin/download-centre/en/report/lobbying-and-political-activities-2021-en.pdf

CDP Questionnaire Response 2022

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Our engagement activities are summarized in our lobbying and political report, please see: https://www.snclavalin.com/~/media/Files/S/SNC-Lavalin/download-centre/en/report/lobbying-and-political-activities-2021-en.pdf

CDP Questionnaire Response 2023