The SICE TyS Group has a Corporate Compliance Program in force, focusing on the promotion of a real ethical corporate culture, and underlining its commitment to compliance and respect of current legislation.
In this regard, the SICE TyS Group is acting clearly and actively in the fight against crime in the corporate activities which it carries out, having implemented resources technical, organizational, staff, monitoring and control, as well as an appropriate penalty system to try to avoid any type of offences or unlawful acts in its business activity.
In this context and to achieve this objective, the SICE TyS Group has internally published the following mandatory documents for all staff, also required for all business partners:
- Management Procedures of VINCI, S.A.
- Code of Ethics and Conduct
- Anti-corruption Code of Conduct
- Guide on Human Rights
- Environmental Guidelines
- Guide for Users of Information System
- General Cybersecurity Policy
- 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.
- SICE TyS 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
- Anti-corruption and Business Courtesies Policy
- Policy on Intellectual and Industrial Property Rights
- Data Protection and Confidential and Sensitive Information treatment Policy
- Corporate Due Diligence regarding Human Rights Policy
- Policy for the Prevention, Detection and Action against Harassment
The design of the Corporate Compliance Program contains and applies some best practices for preventing criminal and competitive risks, promoting ethical corporate behavior aligned with the requirements of the Criminal Code, Competition Regulations and other applicable legislation in force.
Any person who is aware or legitimately suspicious about any type of unlawful act or offence can disclose this through the following channels enabled:
- Digital Platform 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
- If choose this channel, it will be required to enter a code of service 22656 during the call.
- Postal address Canal de Formulación de Denuncias,SICE TyS Group, Calle de la Granja, 72, (Pol. Ind.) - 28108 Alcobendas. Madrid. Spain.
The previous disclosure systems can also be used as a resource to resolve any questions referring to the Corporate Compliance Program itself.