The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since 26 February 2019, 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.
1. Manifesto ››
2. Code of Ethics and Conduct ››
3. Anti-corruption Code of Conduct ››
4. Guide on Human Rights ››
5. Environmental Guidelines ››
6. Guide for Users of Information System
7. General Cybersecurity Policy
8. 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.
DRAGADOS OFFSHORE DOCUMENTS
1. Regulatory Compliance, Anti-Bribery and Behaviours Against the Defence of Competition Policy ››
2. Rules of Ethics and Behaviour of the Employees of Dragados Offshore ››
3. Crime Prevention Plan
4. Procedures for the Crime Prevention Plan
Complaints Management
Sanctions Management
Criminal. Bribery and Competition Risk Evaluation
Anticorruption Procedure
Professional Courtesies
Mobbing
Money Laundering and Terrorism Financing Prevention
Information Technology Rules
Protection of Industrial and Intellectual Property Rights
Treatment of Confidential Information and Sensitive Business Information
Due Diligence with Business Partners
Compliance with Defence of Competition regulations
Due Diligence on Human Rights
An email address has been set up infocompliance@dragadosoffshore.es to provide information and solve any doubts about the CCP.
Any person with knowledge or justified suspicion of any type of infraction or illicit behaviour, may inform via the following channels enabled:
Digital Platform: https://cobrais.integrityline.com
Phones:
Spain:+34 900 535 362
Mexico:+52 8 006 070 025
If choose this channel, it will be required to enter a code of service 22656 during the call.
Ordinary mail to the attention of the Internal Corporate Compliance Officer, Dragados Offshore, S.A.U., Bajo de la Cabezuela, S/N, Puerto Real 11510, Cádiz.