Code of ethics

Since then, and as contemplated by the bylaws of the Association, being a member of SEOPAN requires a commitment to comply with the Code, which revolves around five fundamental areas: to always act in accordance with ethical principles in all interactions; to preserve the safety and health of workers; to promote quality, environmental and social responsibility; to promote research, development and innovation (R&D&I); and to ensure greater transparency and fairness in the goal of creating value for its shareholders.

The diversification, growth and internationalisation processes of our associated companies over the last few years have led them to develop their activities in diverse environments and cultures, which has made it necessary to renew the Code in order to integrate the new values and principles of behaviour that are shared by the Association.

Updating the Code has been done with the purpose of unifying and strengthening the identity, culture and standards of conduct of SEOPAN and all its associated companies, since we firmly believe that a uniform code on shared principles will help to create value for all interest groups.

Our commitment is to respect and enforce the Code, always applying it to all of our commercial, labour, social and environmental actions. Respect for the principles of this Code will help us to progress and grow. Our reputation and our future as a leading sector depends largely on our commitment to behaving with integrity, ethics and transparency in our business activity.

PURPOSE

The purpose of this Code of Ethics is to establish the values, principles and standards of conduct that should guide the behaviour of SEOPAN and the companies it is comprised of.

This document is set as a starting point and affects our activity as a whole, whose conduct and actions must be generally based on respect for fundamental values such as honesty, integrity, transparency and safety. In compliance with the law, SEOPAN will encourage all of its supplier companies or collaborating entities to adapt their behaviour to standards of conduct that are similar to those defined in this Code of Ethics.

SCOPE OF APPLICATION

This Code is addressed to all administrators, managers and employees of SEOPAN and the companies it is comprised of, regardless of the type of contract that determines their professional relationship, the position they occupy or the geographical scope in which they conduct their work.

When establishing business relationships with other companies or professionals, one of the selection criteria to take into account will be whether they have assumed behavioural and management principles similar to those set forth in this document in the fields of ethics, safety and health of workers, quality, environmental protection, the push for R&D&I, the creation of value for shareholders and society, the fight against corruption, the confidentiality of information and the use of and protection of companies’ resources and assets.

REGISTRATION IN THE REGISTER OF INTEREST GROUPS

SEOPAN has registered in the Special Register of Interest Groups, created by the National Commission on Markets and Competition (CNMC in Spanish), for which it makes the following commitments:

1. To respect the institutions and people with whom it interacts in the development of its activity.
2. To act transparently. To inform CNMC staff with whom it interacts, whatever the scenario or means by which they communicate, that it is acting as an interest group and that it is registered in the CNMC Register of Interest Groups and, where appropriate, in any other similar list.
3. To provide information regarding the identity of the person or organisation it represents, and the objectives and purposes represented. To guarantee the accuracy and up-to-date nature of the information that is registered.
4. To not disseminate information of a confidential nature that it may come into contact with in the exercise of its activity. To accept that part of the information provided to the CNMC could be made public.
5. To act with integrity and honesty in the development of its activity and in its relationships with CNMC personnel, and to not carry out any activity that could be qualified as dishonest or unlawful.
6. To not put the aforementioned CNMC personnel in any situation that could generate a conflict of interest.
7. To not influence or try to influence decision-making in a dishonest way or obtain or try to obtain information dishonestly or through inappropriate behaviour.
8. To not encourage, by any means, the CNMC’s public employees to violate the law or the rules of behaviour established in the codes of conduct and, consequently, to not give any gift of value or offer any favour or service that could jeopardise the full execution of public functions.
9. To inform the people or organisations whom it represents of the existence of these Principles of Action and the obligations that they include, and to not represent conflicting or adverse interests without the informed consent of the affected persons or organisations.
10. To not abusively use its membership as a means of publicity, nor imply that appearing in the Register puts it in a special situation or with special privilege in the eyes of the public authorities.

STANDARDS OF CONDUCT

Ethics and Integrity

SEOPAN’s associated companies commit to always acting in accordance with ethical principles in their relationships.

– With their employees: respecting individual rights and freedoms included in the Universal Declaration of Human Rights, providing them with equal opportunities, without any discrimination based on race, sex, religious beliefs, political or union ideology, nationality, language, age, sexual orientation, marital status and social origin.

They will offer their employees the possibility of participating in ongoing training and union activities. The basis for developing the careers of employees from SEOPAN’s associated companies will be the objective assessment of their professional merits, within a framework of non-discrimination.

– With their customers, suppliers and subcontractors: adequately satisfying their expectations, through the use of the most appropriate construction processes and quality management systems at all times, with a resolve to anticipate and be aware of their needs.

Relationships will be established with suppliers and subcontractors based on reciprocal collaboration and mutual respect and, especially, on proven trust and on the quality of the products and services provided.

– With their shareholders: seeking to provide them with long-term profitability and ensuring transparency in management and good corporate governance.

– With Public Administrations: acting with transparency, integrity and honesty in their interactions with the personnel from Public Administrations, avoiding any situation that could generate a conflict of interests, neither influencing nor attempting to influence decision-making in a dishonest way or through inappropriate behaviour.

– With society as a whole: to whose general welfare and economic development the activities of SEOPAN’s associated companies must contribute to. These associates are aware of the compatibility of their financial results, taking into consideration the impact of their activities at a social, economic and environmental level.

The Safety and Health of Workers

The objective of offering optimal working conditions, with the implementation and maintenance of occupational safety and health management systems, will respond not only to national and EU legal requirements, but also to the best techniques that are available at any given time.

The prevention of occupational hazards will mainly rely on the training provided to both the company’s own staff and that of subcontractors, with the active collaboration of unions. Likewise, employees must be responsible in using the equipment assigned to them when carrying out any risky activity and will share their knowledge and any practices among their colleagues and subordinates that are related to the prevention of risks to safety and health.

Quality and Environment

SEOPAN’s associated companies clearly set out their commitment to take action in the following areas:

• To guide their clients in order to continuously improve the competitiveness and quality of their products and services, involving their suppliers and subcontractors in this approach.
• To incorporate environmental criteria in all construction processes, including in the initial planning, the management of construction operations, and when the time comes to abandon the locations. Specific objectives in this area include the systematic adaptation to applicable regulations, the effort to minimise environmental impact, the application of efficiency criteria to solve problems in this area, the training of personnel and an effective bond with suppliers and subcontractors.
• Likewise, the companies commit to carrying out R&D&I activities that improve the relevant environmental management processes.

R&D&I and New Technologies

• The companies commit to strengthening their R&D&I efforts, including technology, in their strategies to search for competitiveness, organising themselves internally for innovation and adapting their human resources to this new way of competing.
• At the same time, innovation is also viewed as a basic tool, capable of being geared at meeting the ethical, cultural, environmental and social demands of the domestic and international markets, and of their closest clients.
• The use of modern information and management systems offered by new technologies is a basic element when it comes to improving business competitiveness.

Transparency and Creation of Value for Shareholders

SEOPAN’s associated companies would like to acknowledge the importance of their shareholders in the development of their activities, pledging to foster and consolidate the trust that has been placed in them. To do so, they must provide them with transparent and truthful information, regardless of their relevance or position, which allows them to form an accurate picture of their activities, strategy, and economic, social and environmental performance.

Corruption and Bribery

• Under no circumstance will SEOPAN’s professionals resort to unethical practices to influence the will of people outside the company in order to obtain any type of benefit. They will also remain alert so that there are no instances in which other people or organisations use these practices as part of their interaction with the company.
• Companies must comply with all laws against money laundering, in the fight against corruption and the financing of terrorism, for which due diligence (identification of the client), information and internal control measures established for this purpose will be applied, and they will collaborate with the competent authorities to the greatest extent possible.

Privacy of Personal Data and Confidential Information

SEOPAN’s associated companies request information of a personal or business nature from their workers, clients and third-parties, which is necessary for proper business management and for compliance with current legislation. Non-public information is considered to be reserved and confidential, therefore the necessary mechanisms will be applied to properly process it and to preserve its integrity, availability and confidentiality. The professionals from the Association and from its companies who have access to this information, as a result of their duties, will protect it and ensure its confidentiality.

Use and Protection of Assets and Resources

SEOPAN’s associated companies provide their employees with the necessary resources in order to carry out their professional activity and provide the means for the adequate protection thereof, thus each professional is responsible for the correct use and protection of the provided assets and resources.

ACCEPTANCE AND COMPLIANCE

This Code establishes the principles and commitments of business ethics of SEOPAN’s associated companies and those of third parties whose characteristics so require. If the organisation’s employees observe circumstances that, based on their knowledge and understanding, represent a breach of the previous principles of conduct, they should immediately notify the company through their immediate superior or the body designated for this purpose.

VALIDITY

The Code of Conduct will enter into force on the day of its approval by the Association’s General Assembly of Members and must be communicated to all of SEOPAN’s associated companies and will be valid for as long as the General Assembly does not approve its termination.