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Corporate Compliance Program

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.

Manifesto
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
Protocol for Prevention, Detection and Action against Harassment at Work
Protocol for Prevention, Detection and Action against Sexual Harassment, Gender-Based and Sexual Violence

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.