The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since 1 June 2015, 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.
- Manifesto
- Code of Ethics and Conduct
- Anti-corruption Code of Conduct
- Guide on Human Rights
- Environmental Guidelines
- Guide for Users of Information System
- General Cybersecurity Policy
- Essential and fundamental actions concerning Occupational Health and Safety
- 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 COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.
- SICE TyS Group Crime Prevention Plan and its Policies
- 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 and Business Courtesies Policy
- 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 Prevention, Detection and Action against Harassment at Work
- Protocol for Prevention, Detection and Action against Sexual Harassment, Gender-Based Harassment and Sexual Violence
Any person who is aware or legitimately suspicious about any type of unlawful act or offence can disclose this through the following channels enabled:
- Digital Platform https://cobrais.integrityline.com
- Telephone line - If choose this channel, it will be required to enter a code of service 9756 during the call.
- 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
- Postal address Canal de Formulación de Denuncias, SICE TyS Group, Calle de la Granja, 72, (Pol. Ind.) – 28108 Alcobendas. Madrid. Spain.
The previous disclosure systems can also be used as a resource to resolve any questions referring to the Corporate Compliance Program itself.
