Corporate Compliance Programme

The organisation approved its first Corporate Compliance Programme on 30 March 2017, which is periodically reviewed by external advisors of recognised prestige, describing in a structured manner the measures that have been put in place in order to create an environment of prevention, detection and early management of risks.

A culture of compliance and zero tolerance has therefore been adopted with regard to any behaviour, whether by a member of the organisation or a business partner, contrary to relevant legislation and generally accepted ethical principles.

The Corporate Compliance Programme consists of the following documents:

presentacion-cumplimiento-corporativo-image

VINCI regulations

  1. Manifesto
  2. Code of Ethics and Behaviour
  3. Anti-Corruption Code of Conduct
  4. Human Rights Guide
  5. Environmental Guidelines
  6. Information Systems User Guide
  7. General Cybersecurity Policy
  8. Fundamental and unavoidable measures in Occupational Health and Safety

Protocolos de Cobra Servicios, Comunicaciones y Energía

  1. Framework Protocol
  2. Regulatory Compliance Protocol
  3. Reporting of Alleged Irregularities Protocol
  4. Corporate Defence Procedure Activation Protocol
  5. Protocol on Regulatory Compliance Training
  6. Statute of the Regulatory Compliance Body: Protocol on the profile, experience and organic location of the Regulatory Compliance Body, the Head of Corporate Compliance and the Corporate Compliance Delegate
  7. Essential Policies Protocol
  8. Catalogue of Prohibited Behaviours and Expected Behavioural Parameters
  9. Code of Conduct for Business Partners
  10. Antitrust Regulation Compliance Protocol
  11. Management of Relations with Public Administrations and Civil Servants
  12. Facilitation Payments

Cobra Servicios, Comunicaciones and Energy Internal Instructions

COBRA Crime Prevention Plan and associated documentation

  1. Regulatory Compliance, Anti-bribery and Antitrust Compliance Policy
  2. Prevention of Money Laundering and Terrorist Financing Policy
  3. Anti-Corruption Policy
  4. Policy on Professional Courtesies
  5. Protection of Intellectual Property Rights Policy
  6. Data Protection and Processing of Confidential and Sensitive Information Policy
  7. Human Rights Due Diligence Policy
  8. Protocol for Prevention, Detection and Action against Harassment in the Workplace
  9. Protocol for Prevention, Detection and Action against Sexual Harassment

In addition to reporting to the Corporate Compliance Officer, any person who has knowledge of or suspects any infringement, illegal action, inappropriate behaviour, etc. may use the following means:

Digital platform
brazil-flag-image Brazil: +55 08 008 870 132
chile-flag-image Chile: +56 800 914 868
spain-flag-image Spain: +34 900 535 362
mexico-flag-image Mexico: +52 8 006 070 025
peru-flag-image Peru: +51 080 071 556

You will be prompted for service code 22656 during the call.

Mail to the attention of the Corporate Compliance Officer, Calle Cardenal Marcelo Spínola, 10, 28016, Madrid (Spain).

These resources are both a means of reporting any breach of legislation and/or internal regulations, as well as a means of resolving a query that may arise in the course of the organisation's activities, ensuring at all times that the matter addressed will be confidential and the absence of reprisals for submitting a complaint.

All persons who send communications in good faith will be protected against any discrimination, retaliation or penalisation on the basis of their communications. False or defamatory allegations will be subject to disciplinary sanctions in accordance with internal procedures, agreements and applicable legal regulations. The identity of the whistleblower is guaranteed to remain confidential. The identity of the whistleblower shall not be disclosed to third parties, to the person reported or to senior management, except where disclosure is necessary to relevant persons involved in any subsequent investigation or legal proceedings initiated as a result of the investigation carried out by the Compliance Management System. Pursuant to the provisions of applicable regulations on Personal Data Protection, we inform you that data collected through this Ethics Channel will be processed by COBRA INSTALACIONES Y SERVICIOS, S.A.U. and its subsidiaries, for the purpose of processing the corresponding complaints and queries, in accordance with the provisions of the Corporate Compliance Programme and internal regulations. Legitimacy for this processing is based on the data subject’s consent by voluntarily submitting the information. Data shall be kept for the duration of the investigation and until their deletion is requested and, in any case, in compliance with applicable legal limitation periods. Information received may be passed on to the relevant companies if necessary for the purpose of the investigation. You can consult the COBRA Group company in any official information register. In any case, the data subject may at any time exercise their rights of access, rectification, deletion, portability, limitation or opposition by sending an email to dpd@grupocobra.com or by writing to Cardenal Marcelo Spínola, 10, 28016, Madrid (Spain).

Garantizando un fuerte compromiso
con la ética, la integridad y la transparencia
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