Corporate Compliance Programme

The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since 30 March 2017, which is periodically reviewed by external consultants of recognised prestige and which sets out, in an organised manner, the measures implemented to create an environment of prevention, detection and early management of risks. Among other things, this programme has a special focus on the fight against criminal and anti-competitive offences, ensuring the highest level of integrity in all business practices.

Grupo COBRA adheres to the VINCI Codes, which sets out the principles shared by all its employees and business partners and whose fundamental values are defined in the 5 reference documents listed below:

  • The Code of Ethics and Conduct, which sets out all the principles of business ethics to be applied in different circumstances and in all the countries in which the firm operates.
  • It is used in conjunction with the Anti-Corruption Code of Conduct, which sets out standards to prevent all acts of corruption, in particular by identifying risks in business processes and defining behaviour to be avoided.
  • The Human Rights Guide, which summarises potential risks and their impact on the business and defines a common set of guidelines for dealing with human rights issues.


These guidelines are based on the principles of the Universal Declaration of Human Rights (UDHR), the 8 core conventions of the International Labour Organisation (ILO) and the OECD Guidelines for Multinational Enterprises.

  • The Declaration on Fundamental and Essential Actions on Safety and Health at Work, which reflects the common will to achieve the goal of ‘Zero Accidents’. The declaration is the result of a constructive and regular social dialogue. As part of a policy of continuous improvement, it reaffirms that progress can only be made with all employees by promoting a culture of safety.
  • Environmental guidelines, which provide a framework designed to minimise the risks and impacts of activities on the environment. All companies must follow these guidelines so that policies and procedures can be improved and adapted to protect and preserve the environment wherever they operate. Each business unit is responsible for ensuring that similar efforts are made by business partners throughout the life of a project.


The Corporate Compliance Programme consists of the following documents:

  • Framework Protocol
  • Regulatory Compliance Protocol
  • Reporting of Alleged Irregularities Protocol
  • Corporate Defence Procedure Activation Protocol
  • Protocol on Regulatory Compliance Training
  • 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
  • Essential Policies Protocol
  • Catalogue of Prohibited Behaviours and Expected Behavioural Parameters
  • Code of Conduct for Business Partners
  • Antitrust Regulation Compliance Protocol
  • Management of Relations with Public Administrations and Civil Servants
  • Facilitation Payments
  • Sustainability Policy
  • Regulatory Compliance, Anti-bribery and Antitrust Compliance Policy
  • Prevention of Money Laundering and Terrorist Financing Policy
  • Anti-Corruption Policy
  • Policy on Professional Courtesies
  • Protection of Intellectual Property Rights Policy
  • Data Protection and Processing of Confidential and Sensitive Information Policy
  • Human Rights Due Diligence Policy
  • Protocol for Prevention, Detection and Action against Harassment in the Workplace
  • 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: +55 6 135 507 564

Chile: +56 232 149 988

Spain: +34 910 477 636

Mexico: +52 5 571 002 193

Peru: +51 01 640 9418

You will be prompted for service code 9756 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).