Plan de Cumplimiento Corporativo

The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since March 30, 2017, which is periodically reviewed by external consultants of recognised prestige and which sets out, in an organised manner, the measures implemented to create an environment of prevention, detection and early management of risks. Among other things, this programme has a special focus on the fight against criminal and anti-competitive offences, ensuring the highest level of integrity in all business practices.

The organisation adheres to the VINCI Codes, which sets out the principles shared by all its employees and business partners and whose fundamental values are defined in the 5 reference documents listed below:

  • The Code of Ethics and Conduct, which sets out all the principles of business ethics to be applied in different circumstances and in all the countries in which the firm operates.
  • It is used in conjunction with the Anti-Corruption Code of Conduct, which sets out standards to prevent all acts of corruption, in particular by identifying risks in business processes and defining behaviour to be avoided.
  • The Human Rights Guide, which summarises potential risks and their impact on the business and defines a common set of guidelines for dealing with human rights issues.

These guidelines are based on the principles of the Universal Declaration of Human Rights (UDHR), the 8 core conventions of the International Labour Organisation (ILO) and the OECD Guidelines for Multinational Enterprises.

  • The Declaration on Fundamental and Essential Actions on Safety and Health at Work, which reflects the common will to achieve the goal of ‘Zero Accidents’. The declaration is the result of a constructive and regular social dialogue. As part of a policy of continuous improvement, it reaffirms that progress can only be made with all employees by promoting a culture of safety.
  • Environmental guidelines, which provide a framework designed to minimise the risks and impacts of activities on the environment. All companies must follow these guidelines so that policies and procedures can be improved and adapted to protect and preserve the environment wherever they operate. Each business unit is responsible for ensuring that similar efforts are made by business partners throughout the life of a project.

The Corporate Compliance Programme consists of the following documents:

  • VINCI, S.A. Regulations
  • Protocols of COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.
    • Framework Protocol
    • Regulatory Compliance Protocol
    • Protocol for Reporting Allegedly Irregular Events
    • Protocol for Activating the Corporate Defence Procedure
    • Protocol on Training Professionals in Regulatory Compliance Issues
    • Statute of the Regulatory Compliance Body – Protocol on the profile, experience and organic location of the Regulatory Compliance Body, the Corporate Compliance Officer and the Corporate Compliance Delegate
    • Protocol on Essential Policies
    • Catalogue of Prohibited Conduct and Parameters of Expected Behaviours
    • Code of Conduct for Business Partners 
    • Compliance Protocol for Competition Laws 
    • Management of relations with Public Administrations and Officials
    • Facilitation Payments

Any person who is aware of or suspects any violation, illegal action, inappropriate behavior, etc. may use, in addition to reporting to the Corporate Compliance Officer, the following enabled means:

    • Brasil +55 6 135 507 564
    • Chile +56 232 149 988
    • Spain+34 910 477 636
    • México +52 5 571 002 193
    • Perú +51 01 640 9418
    • If you choose this option, you will be asked for service code 9756 during the call.
  • Postal mail to the attention of the Corporate Compliance Officer, Calle Tres Forques, 147, 46014, Valencia (Spain).

These means are both a way of reporting any breach of legislation and/or internal regulations, and a means of resolving a query that may arise in the development of the organization’s activity, ensuring at all times the confidentiality of the matter discussed and the absence of retaliation for filing a complaint, in accordance with the provisions of Law 2/2023, regulating the protection of persons who report regulatory violations and the fight against corruption.

All persons who transmit their communications in good faith will be protected against any type of discrimination, retaliation or penalization for their actions. False or defamatory reports will be subject to disciplinary sanctions in accordance with the internal procedures, agreements and applicable legal regulations. The confidentiality of the identity of the whistleblower will be guaranteed. The identity of the whistleblower will not be disclosed to third parties, neither to the person reported nor to senior management, except when it is necessary to disclose it to the relevant persons involved in any subsequent investigation or legal procedure initiated as a result of the investigation carried out by the Regulatory Compliance Management System. In compliance with the provisions of the applicable regulations on the Protection of Personal Data, it is reported that the data collected through this Ethics Channel will be processed by ELECTRONIC TRAFIC, S.A. (hereinafter, ETRA) and its subsidiaries, for the purpose of processing the corresponding complaints and queries, in accordance with the provisions of the Corporate Compliance Program and internal regulations. The basis for legitimation of this processing is the consent of the interested party when voluntarily submitting the information. The data will be kept for the duration of the investigation and its deletion is not requested and, in any case, in compliance with the legal limitation periods that apply. The information received may be transferred to the corresponding ETRA companies if necessary for the purpose of the investigation. You can consult the ETRA companies in any official information registry. Likewise, you are informed that, in any case, the interested party may at any time exercise the rights of access, rectification, deletion, portability, limitation or opposition by writing to the address calle Tres Forques, 147, 46014, Valencia (Spain).