Ethics and Compliance
ETHICAL AND REGULATORY COMPLIANCE IS ESSENTIAL IN THE DEVELOPMENT OF ACTIVITIES
At COMSA Corporación we are committed to the development of a business activity based on a culture of ethical and regulatory compliance. Our mission as an organisation is to offer comprehensive infrastructure, engineering and services services, under the principles of professionalism, quality and innovation, thus meeting the needs of our clients and promoting an environment of human development within a framework of profitable and sustainable growth. For this reason, the group’s business strategy is aligned with the Global Compact and the Sustainable Development Goals.
Our Code of Ethics establishes the values, commitments and principles of action which, based on ethical and regulatory compliance, must guide the daily work of all members of the Group’s management bodies, executives and employees.
The ethical channel
The ethical channel is a communication tool that allows both the internal personnel of COMSA Corporación and the group’s companies and third parties to inform the Ethics Commission of any situation of non-compliance with the law, the Code of Ethics or the internal rules that develop it.
Policies and protocols
COMSA Corporación wants to foster a culture of regulatory compliance among all members of the Organisation and therefore its internal policies are based on the philosophy of zero tolerance towards behaviour that may involve non-compliance with legislation and the Group’s internal regulations and processes.
Consult here some of the main protocols and policies that make up COMSA Corporación’s Compliance Model, together with other specific documents applicable in the different jurisdictions where the Group operates.
COMSA Corporación ensures knowledge, understanding and compliance with the provisions of the Code of Ethics and the Protocols, Policies and other internal regulations that develop it, through its Ethics Commission, which has been set up and its members appointed by the Board of Directors and has autonomous powers of initiative and control in the performance of its duties.
Jorge Miarnau, chairman of the Board of Directors
Chairman of the Commission
Guillermo Lorenzo, Infrastructure, Enginnering and Services general director
Board Member
Manuel Fonseca, Economic and Finantial Services general director
Board Member
Santiago Sanjosé, director of Management Control Area
Board Member
Ignacio Ponz, director of People Area
Board Member
Carles Mases, Legal Department director
Ethics Commission Secretary
Ethics Channel and Harassment Channel
COMSA Corporación has set up an Ethics Channel which, supervised by the Head of the Internal Information System, allows all members of the Organisation, in good faith and safe from reprisals, to report any breaches of the law and any ethical or regulatory malpractice or non-compliance of which they may become aware. In fact, in accordance with the group’s internal regulations, reporting this type of situation through the Ethics Channel is one of the obligations incumbent on all members of the Organisation.
Thus, is made available the Whistleblowing Management System Policy (Ethics Channel), which defines the general principles that COMSA Corporación defends, promotes and adopts in the process of receiving, processing, recording, investigating and responding to the communications it receives through the Ethics Channel.
However, the specificities existing in other jurisdictions where the Group operates must be taken into account, as is the case of the companies in Colombia subject to SAGRILAFT/PTEE and the companies in Portugal subject to the General Regime for the Prevention of Corruption.
The Ethics Committee is also the body responsible for ensuring the proper functioning of the group’s Ethics Channel.
At COMSA Corporación, as stated in our Protocol for the prevention of sexual and gender-based harassment, we are also committed to the prevention and correct action in the event of any conduct of sexual and gender-based harassment at work. For this reason, we have a Harassment Channel, through which you can report possible situations of sexual and gender-based harassment in our workplaces. The Harassment Channel will be governed by the same principles as the Ethics Channel.
The ethical channel
The ethical channel is a communication tool that allows both the internal personnel of COMSA Corporación and the group’s companies and third parties to inform the Ethics Committee of any situation of non-compliance with the law, the Code of Ethics or the internal rules that develop it.
Communications may be anonymous and contain any doubts or queries regarding ethics and regulatory compliance. They will be received and analysed in a diligent, rigorous and confidential manner and will be treated in accordance with the Protocol established for this purpose, based on best practices, with the aim of responding to them and processing them in an orderly manner.
In order to ensure the confidentiality of the data and the object of the complaint, the documentation will be protected in accordance with the requirements established by the Data Protection regulations.