The Statement of Claim alleges that, during the Class Period, unbeknownst to the Class members, SNC’s business was being conducted in an unlawful manner or otherwise in contravention of SNC’s internal policies. In particular, in December 2009 and July 2011, SNC entered into agreements with “agents” with respect to projects on which SNC was working, pursuant to which SNC made payments totaling US$56 million to those “agents”. Although SNC purports not to know the purpose of such payments, their purpose was to bribe foreign government officials for the procurement of business by SNC. In any event, the agreements and the payments there under violated SNC’s Agents Policy and Code of Ethics in numerous respects.

The above-mentioned violations of SNC’s internal policies were first disclosed to the Class members on February 28, 2012. On that day, SNC announced that it had initiated an Audit Committee investigation into $35 million of payments that were documented to construction projects to which they did not relate, and certain other contracts.

As a result of the disclosure of that information on February 28, 2012, the market value of SNC’s securities fell dramatically. In particular, upon the disclosure of the corrective information, the market price for SNC’s shares fell by approximately 21% on extraordinarily heavy trading volume. SNC’s shares closed at $48.37 on the TSX on February 27, 2012 and at $38.43 on the TSX on February 28, 2012.

SNC-Lavalin Group Inc. (SNC)
2763884; 78460T105; B10SMP9; B3FDTY1; CA78460T1057

SNC-Lavalin Group, Inc. (SNC)
BJ053T7