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 2024, 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.

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
  • Protocol Code of Conduct for Business Partners
  • Protocol Compliance with the Regulations for the Defense of Competition
  • 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.

COBRA 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
  • Policy on Business Courtesies
  • Anti-corruption 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 the prevention, detection and action in situations of sexual harassment and harassment based on sex in IMESAPI S.A.
  • Policy on Prevention, Detection and Intervention against Workplace Mobbing
Anyone who has knowledge or suspects of any type of infraction, illegal action, inappropriate behavior, etc. may use, in addition to the internal report to the Corporate Compliance Officer, the following reporting channels enabled.
  • Digital Platform https://cobrais.integrityline.com
  • Phone line:
    • Spain: +34 910 477 636 (Ext 9756)
    • Mexico: +34 910 477 636 (Ext 9756)
  • Ordinary post to the attention of Corporate Compliance Officer, Vía de los Poblados, 9-11 Parque Empresarial Trianón – Edificio C – 28033 Madrid (Spain).
These channels are both a way of denouncing the breach of legislation and/or internal regulations, as well as of resolving a consultation that may arise in the development of the organization’s activity, ensuring always the confidentiality and the absence of retaliation for the filing of a complaint.

All those people who in good faith transmit their communications will be protected against any type of discrimination, retaliation or penalty due to them. False or defamatory complaints will be subject to disciplinary action in accordance with internal procedures, agreements and applicable legal regulations. Confidentiality of the identity of the whistle-blower will be guaranteed. The identity of the whistle-blower will not be disclosed to third parties, neither to the person reported nor to the management, except when disclosure is necessary to the relevant persons involved in any subsequent investigation or legal proceeding initiated as a result of the investigation carried out by the Compliance Management System. In accordance with the provisions of the applicable Personal Data Protection regulations, you are informed that the data collected through this Ethical Channel will be processed by COBRA GESTIÓN DE INFRAESTRUCTURAS, S.A.U. (hereinafter, COBRA) and its subsidiaries, in order to process the corresponding complaints and queries, in accordance with the provisions of the Corporate Compliance Program and internal regulations. The basis of legitimacy of this treatment is the consent of the interested party when voluntarily submitting the information. The data will be kept for the duration of the investigation and its deletion is not requested and, in any case, in compliance with the applicable statutory limitation periods. The information received may be transferred to the corresponding COBRA companies if necessary for the purpose of the investigation. You can consult the companies of COBRA in any official information register. Likewise, it is reported that, in any case, the interested party may at any time exercise the rights of access, rectification, deletion, portability, limitation or opposition by writing to the address calle Cardenal Marcelo Spínola, 10, 28016, Madrid (Spain).