1. Ethics and Integrity
  2. Code of Business Ethics
  3. Volver

Ferrovial

Ferrovial - Integrated annual report 2013 / Code of Business Ethics

Ferrovial has a Code of Business Ethics, which was approved by the Board of Directors in 2004. It establishes the basic principles and commitments that all companies in the group, its employees and executives, and all other entities linked to Ferrovial or to any of its group companies in which it has a dominant position, must respect and comply with in the exercise of their activities.

The principles are as follows:

  • Respect for the law. Ferrovial’s business and professional activities shall be carried out in strict compliance with the laws in force in every country where it operates.
  • Ethical integrity. The business and professional activities of Ferrovial and its employees shall be based on the value of integrity and carried out in accordance with the principles of honesty, avoidance of every form of corruption and respect for the individual circumstances and needs of all parties involved.
  • Respect for Human Rights. All actions of Ferrovial and its employees shall scrupulously respect the Human Rights and Civil Liberties enshrined in the Universal Declaration of Human Rights.

These principles are a guarantee of integrity for Ferrovial and reflect the company’s commitment to the main intergovernmental and international initiatives:

  • The ILO (International Labor Organization) Tripartite Declaration.
  • The OECD (Organization for Economic Cooperation and Development) Guidelines.
  • The United Nations Universal Declaration of Human Rights.
  • The Principles of the United Nations Global Compact, to which Ferrovial has made a special commitment, and which form the basis of its Corporate Responsibility policy.

At present, the Code is enforced in all the countries where Ferrovial operates and applies to the whole workforce. In addition, some companies recently acquired by Ferrovial have their own codes of ethics already in force, which are complemented by the Corporate Code.

The full version of the Code of Business Ethics is available on the Ferrovial website in Spanish and in English and on the various corporate intranets.

40 internal audits have been conducted on compliance with the Code of Ethics in all Ferrovial businesses and corporate areas, covering aspects of the financial statements, processes, internal controls, regulatory issues (System of Internal Control over Financial Reporting, SICFR) and Information Systems.

Each audit issues recommendations which are submitted to those responsible for the audited area in order to strengthen the control and reporting mechanisms. Compliance then takes place in a previously agreed timeframe, resulting in satisfactory implementation indices.

Since 2013, foreign employees from companies owned or partly controlled by Ferrovial whose systems are managed by their own Information Systems departments can send complaints to the (internal) mailbox.

Training continued to be offered in 2013 through the online campus, with the aim of strengthening knowledge of the basic principles of behavior for Ferrovial professionals and providing information on the policies, protocols and procedures that the company makes available to all its employees:

  • Code of Corporate Ethics
  • Crime Prevention Protocol (including a non-exhaustive catalog of prohibited conduct)
  • Fraud Prevention Procedure
  • Harassment Prevention Protocol
  • Regulations for balancing work and personal life (Iguala Plan)
  • Health and Safety Policy
  • Information Security Policy
  • Quality and Environment Policy
  • Travel expenses regulations
  • Control and Risk Management policy

The courses are taken by new hires and employees who did not take them previously. These courses are aimed at structural personnel in Spain.

Courses
Course Employees 2013Hours 2013Total employeesTotal hours
Code of Business Ethics (since 2010) 149 51 4,614 4,643
Crime Prevention (since 2011) 644 233 4,499 2,511
Occupational Safety (since 2010) 98  146  513  1,101 
Safety starts with you (since 2010) 99  81 2,283  2,335 

Suggestion Box 

Ferrovial has had a Suggestion Box since 2004, where employees can leave their comments and/or criticisms. This box is for internal use and can be accessed via the corporate intranet. All the suggestions are analyzed by a Committee made up of members of Ferrovial’s Senior Management. 24 suggestions were received in 2013, broken down as follows:

As of the date of publication of this report, 92% of the communications had been closed (processed or rejected).

Whistleblowing Channel 

In 2009, the “Whistleblowing Channel” was set up to complement the internal channels available since 2005. Its aim is to ensure compliance with the Code of Ethics and company procedures and protocols, and to report irregularities, non-compliance and unethical or illegal conduct. This channel is accessible to both employees and external stakeholders. In other words, any person with a well-founded suspicion or knowledge of a violation of the Code of Ethics can file a report (anonymous or not) via the corporate website.

All the complaints give rise to an investigation by the Complaints Box Managing Committee.

The committee is made up of the Director of Internal Audits and the General Director of Human Resources. It meets at least once a month at the request of the Director of the Internal Audit Department. When the situation calls for it, urgent meetings may also be convened by any member of the Managing Committee, or any other Ferrovial department. This committee is responsible for taking measures to improve compliance and resolve incidents or doubts as to interpretation.

An emergency procedure has been established for any complaints whose contents call for immediate action. In such cases, the Internal Audit Department, as the unit responsible for the Complaints Box, must decide whether an urgent meeting of the Managing Committee is required, or whether to set in motion the procedures that the company has established for addressing the reported problem.

In 2013 there were 52 complaints (68% up on the figure for the previous year).

Of all the complaints received, 27 were related to Human Rights issues: harassment, working conditions and conflicts of interest.

The Complaints Box procedure is available to third parties on the intranet and the corporate website. It is approved by the Chairman and accepts all associated liabilities, as well as guaranteeing absolute confidentiality and anonymity if the whistleblower so requests.