Regulatory Compliance

Culture of Prevention and Zero Tolerance.

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The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since 7 July 2021, 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:

  • Framework Protocol
  • Regulatory Compliance Protocol
  • Protocol for Reporting Alleged Irregularities
  • Protocol for Activating the Corporate Defence Procedure
  • Practitioner Compliance Training Protocol
  • Statute of the Regulatory Compliance Body – Protocol on the profile, experience and organisational location of the Regulatory Compliance Body, the Corporate Compliance Officer and the Corporate Compliance Assistant Officer
  • Essential Policies Protocol
  • Catalogue of Prohibited Behaviours and Expected Behavioural Parameters
  • Code of Conduct for Business Partners
  • Antitrust Regulations Compliance Protocol
  • Management of relations with Government Agencies and Civil Servants
  • Facilitation Payments

  • Regulatory Compliance, Anti-bribery and Antitrust Compliance Policy
  • Prevention of Money Laundering and Terrorist Financing Policy
  • Anti-Corruption Policy
  • Policy on Professional Courtesies
  • Industrial and Intellectual Property Rights Protection Policy
  • Data Protection Policy and processing of Confidential and Sensitive Information
  • Human rights due diligence policy
  • Protocol for Prevention, Detection and Action against Harassment in the Workplace
  • Protocol for Prevention, Detection and Action Against Sexual Harassment

TRANSPARENCY AND INTEGRITY

Those who have information and/or suspicions of any offence, inappropriate conduct, etc., must report to the Corporate Compliance Officer and may use any of the following authorised channels.

DIGITAL PLATFORM

All communications will be treated in strict confidence

https://cobrais.integrityline.com

TELEPHONE LINE

  • Brazil:+55 08 008 870 132
  • Chile:+56 800 914 868
  • Spain:+34 900 535 362
  • Mexico:+52 8 006 070 025
  • Peru:+51 080 071 556

During the call, service code 22656 will be requested.

POSTAL ADDRESS

COBRA IS Group
Calle Cardenal Marcelo Spínola, 10,
28016, Madrid (España)
For the attention of the Corporate Compliance Officer.

These channels are used both to report possible breaches of legislation and/or internal regulations, and to resolve queries related to the organisation’s activity, guaranteeing the confidentiality of the information processed and ensuring that no reprisals will be taken for whistleblowing.

All persons who make reports in good faith will be protected against any discrimination, retaliation or criminalisation based on their whistleblowing reports. False or defamatory allegations will be trigger disciplinary action in accordance with internal procedures, agreements and applicable legal regulations. The confidentiality of the whistleblower’s identity shall be guaranteed. The identity of the whistleblower shall not be disclosed to third parties, to the person reported or to senior management, unless disclosure is required to parties involved in any subsequent investigation or legal proceedings initiated as a result of the investigation conducted by the Compliance Management System. We hereby inform you that under the applicable Personal Data Protection regulations, the data collected through this channel will be processed by COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA and its subsidiaries, in order to process the corresponding complaints and queries, as established in the Corporate Compliance Programme and internal regulations. The basis of the legitimacy of this processing is the data subject’s consent when they voluntarily submit the information. The data shall be retained for the duration of the investigation and for as long as their deletion is not requested and, in any case, in accordance with the applicable legal limitation periods. The information received may be disclosed to the relevant companies if necessary for the investigation. You can check the company codes of COBRA IS in any official information register. Likewise, data subjects may at any time exercise their rights of access, rectification, deletion, portability, limitation or opposition by sending an e-mail to dpd@grupocobra.com or in writing to the address: Calle Cardenal Marcelo Spínola, 10, 28016, Madrid (Spain).