Corporate Compliance Programme

Corporate Compliance Programme

The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since July 4th, 2018, 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:

Management procedures of VINCI, S.A.

 

Protocols of COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.

  • Framework Protocol
  • Regulatory Compliance Protocol
  • Protocol for Reporting Suspected Irregular Activities
  • Corporate Defence Procedure Activation Protocol
  • Protocol on Training of Professionals in Regulatory Compliance Issues
  • Statute of the Legal Compliance Body- Protocol on the profile, experience and organic location of Legal Compliance Body, Corporate Compliance Officer and the Corporate Compliance Delegate
  • Protocol for Core Policies
  • Catalogue of Forbidden Conducts and Expected Behaviours
  • Code of Conduct for Business Partners
  • Protocol for Compliance with Competition Standards
  • Protocol for Management of the relations with Public Administrations and Civil Servants
  • Protocol for Facilitation Payments

 

Internal System Regulations of MAETEL INSTALACIONES Y SERVICIOS INDUSTRIALES, S.A.

MAETEL Crime Prevention Plan and its associated documentation.

  • Criminal, Anti-Bribery Compliance and Behaviours Against to the Defence of the Competition Policy
  • Policy on Prevention of Money Laundering and the Financing of Terrorism
  • Anti-corruption Policy
  • Policy on Business Courtesies
  • Policy on Intellectual and Industrial Property Rights
  • Data Protection and Confidential and Sensitive Information treatment Policy
  • Corporate Due Diligence regarding Human Rights Policy
  • Protocol for the prevention, detection, and action against Workplace Harassment
  • Protocol for the prevention, detection, and action against Sexual Harassment

 

Any person who has knowledge or suspicion of any violation, illegal action, inappropriate behavior, etc. You may use, in addition to reporting to the Head of Corporate Compliance, the following authorized means:

Digital platform: https://cobrais.integrityline.com

Telephone line:

Brazil:   +55 6 135 507 564

Chile:    +56 232 149 988

Spain:   +34 910 477 636

Mexico: +52 5 571 002 193

Peru:     +51 01 640 9418

If you choose this method, you will be prompted for service code 9756 during the call.

Postal mail to the attention of the Head of Corporate Compliance, calle Cardenal Marcelo Spínola, 8, 4D 28016, Madrid (Spain). These means are both a means of reporting any breach of legislation and/or internal regulations, as well as a means for 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.

Without prejudice to the existence of different channels for communicating complaints, all of them will be managed by the Head of Corporate Compliance according to the internal procedures related to the Ethical Channel and as established in the Privacy Policy.

 

All the people who have good faith transmit their notifications, protected against any type of discrimination and penalty due to the complaints made. False or defamatory complaints will be subject to disciplinary sanctions in accordance with the applicable internal procedures, conventions and legal norms. This system will confirm that the identity of the complainant is kept confidential. The identiy of the complainant is not disclosed to third parties, neither to the person denounced nor to the executive officers, except that its disclosure is necessary to the relevant persons involved in any subsequent investigation or judicial proceedings initiated as a result of the investigation carried out by the internal complaints system. In accordance with the applicable regulations on the Protection of Personal Data, interested parties are informed of the personal data that are collected through this necessary Ethical Chabbel processed by MAETEL INSTALACIONES Y SERVICIOS INDUSTRIALES, S.A (hereinafter MAETEL) with the purpose of transmitting the corresponding complaints and inquiries, in accordance with the provisions of the Corporate Compliance Programme, and internal MAETEL regulations. The basis of legimization of this treatment is the consent f the interested party by 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 statuory limitation periods that result from the application. Personal data may be tranferred to MAETEL companies if necessary, for th epurpose of the investigation, processing and/or resolution. Likewise, it is informed that, in any case, the interested party may at any time exercise the rights of access, rectification, deletion, portability and limitation or opposition by writing to the address Parque Empresarial Plaza, Calle Bari 33, Ed. 3, Planta 3ª, 50197 (Zaragoza). 

Maetel