1. Ferrovial

Ferrovial’s Compliance Program

Ferrovial’s Compliance Program distills our corporate values (Respect, Excellence, Integrity, Collaboration and Innovation), 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 and business ethics. The Board has delegated the day-to-day fulfillment of this responsibility to the Compliance Department, led by Ferrovial’s Chief Compliance Officer.

The Chief Compliance Officer reports periodically to the Audit and Control Committee and to the Board of Directors. The Chief Compliance Officer reports on the effectiveness of the program, including communications received through the Ethics Channel and the execution of the Training and Awareness Plan.

Risk-Based Program

Ferrovial conducts a bottom-to-top risk assessment throughout the Group on a periodic basis. Risks are assessed according to global best practices. The results of the assessment are presented to the Audit and Control Committee and to the Board and helps shape the continuous supervision and evolution of the Compliance Program. 

The Code of Ethics and Business Conduct

The Ferrovial Code of Ethics and Business Conduct is the core of the Compliance Program and reflects Ferrovial’s commitment to its corporate values (Respect, Excellence, Integrity, Collaboration and Innovation). To make its corporate values more effective, Ferrovial turns them into tangible policies and procedures, relying upon three key principles to do so: 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 framework of the Compliance Program.

The Anticorruption Policy

In the Anticorruption Policy, Ferrovial sets forth standards for the behavior of our employees, executives, directors, and the third parties with whom we 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 we interact. This expectation is put into practice through a suite of key policies and procedures such as the Due Diligence Procedure for the Integrity of Third Parties, the Procedure for Approving and Tracking Patronage, Sponsorship and Donation Projects, the Gifts & Hospitality Policy, the Lobbying & Political Contributions Policy and the Sanctions, Export Controls and Antiboycott Policy.

Training and Awareness Plan

Ferrovial’s employees and associates must be aware of and abide by the contents of the Code of Ethics and Business Conduct and the Company’s internal policies. The Compliance Department designs and implements a Training and Awareness Plan to train its employees, including part-time staff, in all jurisdictions where Ferrovial operates.

Ethics Channel

Ferrovial’ s Code of Ethics and Business Conduct mandates that any violations of the law or its policies be reported, under protection against any sort of retaliation. The Policy for the Ethics Channel and for dealing with Queries, Complaints and Reports allocates roles and responsibilities and sets forth principles for the management of any concern, doubt or grievance raised by any means. Specifically, Ferrovial promotes the Ethics Channel, a confidential (and anonymous, if so desired) reporting system that can be accessed via the intranet and the corporate web page.

Certifications 

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, SE, Sucursal in Spain is certified by AENOR (Asociación Española de Normalización y Certificación) under UNE 19601 «Criminal compliance management system» and UNE-ISO 37001 «Antibribery management system», and Ferrovial SE is certified under UNE 19602 «Tax compliance management system»

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