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Paterson, the company said in a statement, will report directly to the chief executive and his duties will include overseeing the ethics and compliance sections of the multi-national company. Two weeks after attending the anti-corrup- tion conference, SNC-Lavalin announced that Card was stepping down in a "smooth transition", with chief operating offi cer Neil Bruce taking over the top spot. Despite the ongoing efforts of the top executives to wipe away the negative per- ceptions about SNC-Lavalin as a result of the allegations and the criminal charges, the task is likely to remain a diffi cult one for some time (the company declined requests for comment about its new compliance and ethics practices). However, the problems at SNC-Lavalin have likely served as a cautionary tale for other large companies — especially those with operations in multiple countries, about the need to be able to conduct cross-border internal investigations that are effective and independent. Uncovering internal wrongdo- ing, before allegations come to the attention of regulators or law enforcement, is critical and will ultimately save companies both money in the long term and its reputation, say lawyers who are experienced in this area. "superhospital" project in Montreal. Other former executives have been charged related to dealings in Bangladesh and Libya. Finally, in February of this year, the RCMP charged SNC-Lavalin and a subsidiary criminally, alleging nearly $50 million was paid out in bribes and there was a fraud of almost $130 million in business dealings in Libya. After the charges against the company were announced by the RCMP, the compa- ny issued a news release that stated the "al- leged reprehensible deeds" were by former employees who left the company long ago. In the statement, the company added that it had been co-operating with the authorities for the past three years. Card was named the chief executive at SNC-Lavalin in the fall of 2012. At the anti-corruption conference in Malaysia, he warned that innocent parties could be harmed if the company faces future sanctions, such as restrictions on bidding for government contracts in Canada. In an interview with CBC radio at the conference, Card stated that the 40,000 employees at SNC-Lavalin had already been "injured in the process" and that the company now has the tools to conduct its business "cleanly" and in a transparent fashion. Part of the restructuring of the company has included a revamped compliance process that has been posted online and the hiring of several new executives, including Hartland Paterson, who assumed his role as general counsel in September, after many years as general counsel with CAE Inc. My view is that the market will punish you mercilessly, if they don't think they can trust the information you have released publicly. ALEXANDER COBB, Osler Hoskin & Harcourt LLP '' ''

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