Ferrovial’s Compliance Program distills our key values into actionable policies and procedures that help guide how we conduct business and engage with the world around us.
Ethics and Compliance Begins at the Top
Ferrovial’s Board of Directors, through its Audit and Control Committee, supervises the Group’s Compliance Program. The Board has delegated the day-to-day fulfillment of this responsibility to the Compliance Department, led by Ferrovial’s Chief Compliance and Risk Officer (CCRO) who reports directly to the Audit and Control Committee. The CCRO has a team of qualified professionals and other resources to ensure the effectiveness of the Compliance Program.
Ferrovial conducts a bottom-to-top risk assessment throughout the Group on a periodic basis. Risks are assessed according to global best practices. As a Spanish company, Ferrovial also maintains a Crime Prevention model that meets all Spanish regulations. The results of the assessment are presented to the Audit and Control Committee and to the Board. They form the framework of the Compliance Program and help shape its continuous improvement.
The Corporate Code of Ethics
The Ferrovial Corporate Code of Ethics is the core of the Compliance Program. It reflects Ferrovial’s commitment to three central principles: ethical integrity, respect for the law and respect for human rights. These principles are at the foundation of Ferrovial’s global operations and are fundamental to the policies and procedures of the Compliance Program.
The Anticorruption Policy
In the Anticorruption Policy, Ferrovial sets forth standards for the behavior of Ferrovial employees, executives, directors, and the third parties with whom they engage, including a “zero-tolerance” approach to any practice that may be deemed corruption or the giving or acceptance of bribes. The policy mandates compliance with all applicable anti-corruption laws and urges that any violations of the Law or the policy be reported, under protection against any sort of retaliation.
Third Party Integrity
Ferrovial requires behavior according to the highest ethical standards not only for its executives, employees and directors, but also the third parties with whom it interacts. This expectation is put into practice through a suite of key policies and procedures such as Due Diligence for the Integrity of Third Parties, the Gifts & Hospitality Policy and the Lobbying & Political Contributions Policy, among others.
Compliance Requires Awareness
Ferrovial’s employees and associates must be aware of and abide by the contents of the Code of Ethics and the Company’s internal policies. The Compliance Department, with the support of other Company resources, designs and executes a training & awareness plan and measures the effectiveness thereof.
Ferrovial’ s Code of Ethics mandates that any violations of the Law or its policies be reported, under protection against any sort of retaliation. The Policy for the Ethical Channel and for dealing with Queries, Complaints and Reports allocates roles and responsibilities and sets forth principles for the management of any concerns, doubts or grievances raised by any means. Specifically, Ferrovial promotes the Ethics Channel, a confidential reporting system that can be accessed by telephone, postal service or via the internet.
Ferrovial’ s Compliance Program is designed to create a culture of compliance to ensure that business is conducted according to the highest standards of ethical integrity. Ferrovial is certified by AENOR, as follows: