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Corporate Compliance Program

ENYSE has a Corporate Compliance Program in force which focuses on the promotion of a real ethical corporate culture, and underlines its commitment to compliance and respect of the current legislation.

In this regard, ENYSE is acting clearly and actively in the fight against crime within the corporate activities that carries out, having established technical, organizational and staff procedures, plus monitoring and control processes, 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, ENYSE has internally published the following mandatory documents for all staff, also required for all partners, suppliers and/or associates:

- VINCI, S.A. normative

  • Manifest
  • Ethic and Behaviour Code
  • Anticorruption Code of Conduct
  • Human Rights Guide
  • Environmental Guidelines
  • IT Users Guide
  • Cybersecurity General Policy
  • Fundamental and inescapable measures on the matter of Health & Safety at Work

- General Protocols of COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.

  • Framework Protocol of the Corporate Compliance Program
  • Regulatory Compliance Protocol
  • Protocol for Reporting Suspected Irregular Activities
  • Corporate Defence Procedure Activation Protocol
  • Protocol on Training of Professionals in Regulatory Compliance Issues
  • Protocol on the profile, expertise and organizational location of the 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 Defence of Competition Standards
  • Protocol for management of the relations with Public Administrations and Servants
  • Protocol on Facilitation Payments

- Internal Regime  instructions of COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.

- Crime Prevention Plan of ENYSE and its Policies

  • Policy for Corporate Compliance, Anti-bribery Compliance and conducts against the right of the Defence of the Competition
  • Policy on Professional Courtesies
  • Policy on Prevention of Money Laundering and Terrorism Financing
  • Anticorruption Policy
  • Policy on Data Protection and treatment of Confidential and Sensitive Information
  • Policy on Due Diligence on the matter of Human Rights
  • Policy on Prevention, Detection and Intervention against Workplace Mobbing

The design of the Corporate Compliance Program contains and applies some best practices for preventing criminal risks and promoting ethical corporate behaviour, aligned with the requirements of the Criminal Code and other applicable legislation in force.

Any person who is aware or legitimately suspicious about any type of unlawful act or offence can disclose it directly to the Corporate Compliance Responsible, or through the following channels:

  • Digital platform: https://cobrais.integrityline.com
  • Postal address At/Responsable de Cumplimiento Corportativo, Calle Valportillo II, 8, Pol. Ind. Alcobendas, 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. At all times, the confidentiality of the subject will be granted, as well as the absence of retaliation upon any given disclosure.

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 ENCLAVAMIENTOS Y SEÑALIZACIÓN FERROVIARIA ENYSE, S.A.U. (hereinafter, ENYSE) 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 ENYSE companies if necessary for the purpose of the investigation. You can consult the companies of ENYSE 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 Valportillo II, nº 8 bis, 28108 Alcobendas, Madrid (Spain).