Prevention, detection, and proactive risk management
The organization takes on significant commitments to comply with the highest standards of corporate ethics, implementing a Corporate Compliance Program since July 7, 2021, which is periodically reviewed by renowned external advisors. This program systematically includes the implemented actions to establish an environment of prevention, detection, and proactive risk management. This program specifically focuses on fighting violations, including criminal offenses and anti-competitive practices, among other matters, ensuring the highest level of integrity in all its business practices.
Dragados Offshore is aligned with the VINCI regulations, which establish the shared principles for all employees and business partners. These fundamental values are defined in the following 5 reference documents:
- The Code of Ethics and Conduct, which establishes all principles of business ethics to be applied in various circumstances and in all the countries where it operates.
- Used in conjunction with the Anti-Corruption Code of Conduct, which includes standards for preventing acts of corruption, particularly by identifying risks in business processes and defining behaviors to be avoided.
- The Human Rights Guide, which summarizes possible risks and their implications for businesses, and defines a shared set of guidelines on how to address human rights issues. These guidelines are based on the principles of the Universal Declaration of Human Rights (UDHR), the 8 fundamental conventions of the International Labour Organization (ILO), and the OECD Guidelines for Multinational Enterprises.
- The Declaration on Essential and Fundamental Actions in Occupational Health and Safety, which reflects a shared commitment to achieving the “Zero Accidents” goal. The declaration is the result of constructive and regular social dialogue.
- The Environmental Guidelines, which provide a framework designed to minimize the risks and impacts of activities on the environment. All companies must follow these guidelines to improve and adapt actions and procedures to protect and preserve the environment in all operational locations.
The Corporate Compliance Program is composed of the following documents:
- Manifesto
- Code of ethics and conduct
- Anti-Corruption Code of Conduct
- Guide on Human Rights
- Environmental Guidelines
- User’s Guide to Information Systems
- General Cybersecurity Policy
- Essential and fundamental actions regarding occupational health and safety
- 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
- Protocol for the management of relations with Public Administrations and Civil Servants
- Protocol on Facilitation Payments
- Sustainability Policy
- Regulatory Compliance, Anti-Bribery and Antitrust Compliance Policy
- Code of Ethics and Conduct for Dragados Offshore Employees
- Crime Prevention Plan
- Procedures of the Crime Prevention Plan
- Whistleblower Management Procedure
- Sanctions Management Procedure
- Criminal, Bribery and Antitrust Risk Assessment Procedure
- Anti-Corruption Procedure
- Procedure on Professional Courtesies
- Workplace Harassment Action Procedure
- Procedure for the Prevention of Money Laundering and Terrorist Financing
- Information Systems Code of Conduct Procedure
- Procedure on the Protection of Industrial and Intellectual Property Rights
- Procedure on the Handling of Confidential and Sensitive Business Information
- Business Partner Due Diligence Procedure
- Procedure on Compliance with Antitrust Regulations
- Human Rights Due Diligence Procedure
Transparency and integrity
Any person who has knowledge or well-founded suspicion of any type of infraction or illegal action, can report it through the following authorized means.