Commitment to ethics, integrity and regulatory compliance

Since our beginnings, at the Elecnor Group we have upheld our unswerving commitment to assuming the highest ethical standards in the development of our business activity, a commitment that is consubstantial with the business culture and philosophy of the Group, and the solid values on which we base our way of doing business and our relationship with our environment.

The Code of Ethics and Conduct and the Compliance Policy of the Elecnor Group form the basis of our culture of ethics and compliance and should act as guidelines regarding personal and professional behaviour for all of us who are part of this organisation, as well as for all the other people and companies that collaborate and have a relationship with the Elecnor Group in the course of our activities.

This commitment to ethics and doing the right thing is not optional. No specific business circumstances can be used as justification for acting outside the law or for behaving in a way that goes against our values and ethical standards.

The Elecnor Group applies the principle of zero tolerance to practices that contravene any provisions regarding ethics and integrity, in the expectation that the behaviour and actions of its professionals and the third parties with whom they interact will remain firmly aligned with the principles and values established in this Code, that is to say, in the regulations or legislations on which it is based and/or the policies or procedures that shape it. All of us in the Elecnor Group should accept and promote the values and principles established in this Ethical Code, with this responsibility being all the more significant for the members of the Board of Directors and executives, who should represent a benchmark and model to follow, and provide inspiration for the rest of the organisation.

COMMITMENT AGAINST CORRUPTION

Corruption and bribery hinder economic development, weaken democracy, and are detrimental to social justice and the rule of law, causing serious harm to the economy and society, and in many cases facilitating organized crime operations.

The Elecnor Group is fully committed to the fight against corruption and bribery in all its forms. The Elecnor Group's Anti-Corruption Policy reaffirms and reinforces this commitment and outlines the expected behavior of employees to promote the fight against bribery and corruption and ensure compliance with all anti-bribery and anti-corruption laws and other regulations, as well as the recommendations of international organizations in this matter, such as the OECD and the United Nations.

The Elecnor Group strictly prohibits:

Directly or indirectly offering, promising or giving bribes to any third party, whether in the public or private sphere.

Obtaining favourable treatment through sponsorship or donations.

Directly or indirectly offering, promising or giving facilitation payments to initiate administrative processes or procedures.

Requesting, accepting or receiving any kind of unjustified benefit or advantage in order to unduly favour a third party in the acquisition or sale of products, procurement of services or in any other trade or business relationship.

Directly or indirectly offering, promising or giving presents, gifts or courtesies to any third party, contravening the Policy on presents, gifts and courtesies.

Establishing business relationships with third parties without complying with the minimum due diligence requirements regarding third party knowledge.

Directly or indirectly offering, promising or giving contributions for political purposes, in the name of the Elecnor Group.

Anti-bribery Management Systems

Management System for Criminal Compliance

UNE 19603 (Compliance Management System in the field of Free Competition)

Defence of free competition

The Elecnor Group has a firm business commitment to ensure rigorous compliance with competition defence rules, making it a priority to develop a solid corporate culture of regulatory compliance that is reflected in the daily decision-making of all its directors, managers, or employees, as well as other natural or legal persons acting on its behalf or representing it, enabling them, within their respective roles and responsibilities, to detect and prevent practices that could be restrictive of competition.

In accordance with the Elecnor Group's Competition Defence Policy, it is strictly prohibited:

Make agreements or establish concerted or consciously parallel practices with competitors that could restrict competition between economic operators, e.g.: price fixing or other commercial terms, market or customer sharing, limitation or control of production, etc.

Exchange commercially sensitive information with competitors or third parties, e.g.: individualised, disaggregated data about strategic variables such as prices, discounts, quantities or sales volumes, present or future.

Manipulate public or private tenders in an anti-competitive way through Temporary Business Associations or unjustified outsourcing, bid-rigging, support or courtesy bids, or any other means.

Perform actions that could lead to exploitative abuse of a dominant position, e.g.: fixing unfair or discriminatory prices or commercial terms, unjustified refusal to supply or restricting supply.

Accept or arrange collective recommendations or decisions, issued or adopted by or on behalf of associations, which may restrict competition between economic operators.

Perform acts of unfair competition that, due to being in the public interest, may be likely to affect the general interest, e.g.: deceitful or misleading conduct, aggressive practices, loss-leading, disclosure of trade secrets, illegal advertising, etc.

Protection of Human Rights

The Elecnor Group is fully committed to the support, respect, and protection of human rights in all its areas of operation in accordance with its ethical principles and sustainability commitments, complying with applicable national and international regulations, and taking the main international standards and recommendations as a reference.

The Elecnor Group's Human Rights Policy establishes the principles on which this commitment is based. In accordance with it, the Group is firmly committed to:

Encouraging a culture of respect for human rights and activities aimed at raising awareness among professionals in this field.

Respecting local communities’ rights, with particular care and support for the most vulnerable groups.

Guaranteeing non-discrimination on the grounds of sexual orientation or identity, gender, age, race, disability or any other personal or social circumstances likely to be subjected to discrimination, by fostering equal opportunities and respect for diversity.

Safeguarding confidentiality and stakeholders’ right to privacy, and guaranteeing respect for privacy and data protection regulations.

Rejecting forced labour in all its forms, particularly regarding children.

Rejecting corruption in all its forms.

Recognising employees’ freedom of association and assembly.

Taking the necessary steps as soon as possible in the event of detecting a human rights violation.

Protecting the health and safety of its professionals.

Elecnor Group Compliance System

The Elecnor Group's Compliance System is the organization's main tool to ensure that its activity is carried out in accordance with the highest ethical standards and full compliance with the law, and it is designed and operates in accordance with national and international best practices.

As confirmation of this fact and commitment, in January 2018 Elecnor became the first Spanish company in its sector to obtain certification in the UNE-ISO 37001 standard for "Anti-bribery management systems", the first and most demanding certifiable international standard for articulating compliance management systems and fighting corruption.

Likewise, in February 2019, the organization also obtained the certification of its Compliance System under the UNE 19601 standard for “Criminal Compliance Management Systems”, the main reference in Spain for designing and articulating crime and criminal risk prevention systems and fully inspired by the highest international standards in this field.

Furthermore, in June 2024, Elecnor was the first company to be certified in UNE 19603 for “Competition Law Compliance Management Systems”, a pioneering standard in this area, reinforcing its commitment to best Compliance practices in the field of competition law.

Ethics Channel

The Elecnor Group makes available to its professionals and/or third parties with a legitimate interest a confidential channel through which they can communicate and report in good faith on irregular conduct or conduct contrary to current legislation or the provisions established in its Code of Ethics and Conduct, as well as communicate any doubts on this matter or propose improvements to existing internal control systems.

All Elecnor Group professionals have the obligation to immediately report any irregular, illicit, or unethical practice of which they may have knowledge or be witnesses. Access to this channel can be made through this link or by post to PO Box nº 72-48008 (Bilbao, Vizcaya - Spain) (Attention: "Canal Ético").

GO TO ETHICAL CHANNEL