Corporate Compliance Programme

The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since 30 March 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.

Grupo COBRA 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 regulations

1. Manifesto
2. Ethics and conduct
3. Anti-Corruption Code of Conduct
4. Human Rights Guide
5. Environmental Guidelines
6. Information Systems User Guide
7. General Cybersecurity Policy
8. Fundamental and unavoidable measures in Occupational Health and Safety

Protocolos de Cobra Servicios, Comunicaciones y Energía

1. Framework Protocol
2. Regulatory Compliance Protocol
3. Reporting of Alleged Irregularities Protocol
4. Corporate Defence Procedure Activation Protocol
5. Protocol on Regulatory Compliance Training
6. Statute of the Regulatory Compliance Body: Protocol on the profile, experience and organic location of the Regulatory Compliance Body, the Head of Corporate Compliance and the Corporate Compliance Delegate
7. Essential Policies Protocol
8. Catalogue of Prohibited Behaviours and Expected Behavioural Parameters
9. Code of Conduct for Business Partners
10. Antitrust Regulation Compliance Protocol
11. Management of Relations with Public Administrations and Civil Servants
12. Facilitation Payments

Cobra Servicios, Comunicaciones and Energy Internal Instructions

COBRA Crime Prevention Plan and associated documentation

1. Regulatory Compliance, Anti-bribery and Antitrust Compliance Policy
2. Prevention of Money Laundering and Terrorist Financing Policy
3. Anti-Corruption Policy
4. Policy on Professional Courtesies
5. Protection of Intellectual Property Rights Policy
6. Data Protection and Processing of Confidential and Sensitive Information Policy
7. Human Rights Due Diligence Policy
8. Protocol for Prevention, Detection and Action against Harassment in the Workplace
9. Protocol for Prevention, Detection and Action against Sexual Harassment