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Values. Corporate Responsibility

Canal Valores - Responsabilidad Corporativa

Compliance

Code of Conduct

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The Code of Conduct includes the guidelines of professional and personal behavior that the Board of Directors of Sacyr, S.A. considers necessary for acquiring an added value for its shareholders, its employees and for the Group companies through which the Group operates, as well as for the remaining stakeholders.

This Code is the basis and foundation of the Sacyr Group Regulatory Compliance and Criminal Prevention Model, as well as to its development regulations. The Code is applicable to all subsidiaries or majority-owned companies with respect to which Sacyr, S.A. exercises effective control, either directly or indirectly, as well as to the Sacyr Foundation.

Likewise, the Code of Conduct applies to all board members, executives and employees of all the Group companies detailed above, as well as to the patrons and members of its Foundation.

Sacyr is committed to the proper dissemination of its Code of Conduct, with the objective that all employees, executives and directors noted above, but also all third parties who may interact with the Group (customers, suppliers, partners, etc.), have the chance to know and share the values, commitments and standards of conduct described in our Code of Conduct and that should guide our behavior.

Regulatory Compliance Unit

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In order to ensure the effectiveness of the Code of Conduct and, in general, of the Regulatory Compliance Model, Sacyr has established the Regulatory Compliance Unit, which is the corporate body of executive and autonomous nature, composed of top representatives from various areas of the Group (Human Resources, Risk Management, Legal Advice, Internal Audit, Financial, Communication and of the Business Areas) and that operates under the exclusive dependence of the Audit Committee of the Board of Directors of Sacyr, S.A.

The Regulatory Compliance Unit has the necessary authority, resources and means to implement and enforce all the internal control measures that are considered adequate to detect, prevent and avoid the commission of violations of regulations of any kind that result applicable (especially of those of a criminal nature), but also to avoid the violation of the commitments assumed in our Code of Conduct, as well as for the convenient reaction and remediation in the event that these infractions have occurred.

Advice and Complaint Line

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The Advice and Complaint Line codigoconducta@sacyr.com is a corporate tool intended to facilitate the secure and confidential formulation of any query regarding the scope and applicability of the Code of Conduct and, in general, of the Group's Regulatory Compliance Model, as well as to report situations of infringement of this Code of Conduct, of the Compliance Model in general or of the applicable regulations, especially those of a criminal nature.

The Regulatory Compliance Unit is the body responsible for the operation of the Advice and Complaints Line, as well as for the analysis of the complaints and queries formulated through this channel, and for this last purpose the Unit may request the collaboration of other bodies, departments, areas, people or Group companies.

Harassment Complaint Line

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As part of the commitment to prevent and act against possible behaviors of sexual work place, or gender-based harassment at our workplaces, the Sacyr Group has a second Complaint Line, in this case, a specific Complaint Line against Harassment denunciacoso@sacyr.com that coexists with the General Advice and Complaint Line.

In this way, any inappropriate conduct that could involve a situation of harassment or discriminatory act towards any employee of the Group may be communicated through this Line, as well as through the General Advice and Complaint Line.

As in the case of the General Advice and Complaint Line, the Regulatory Compliance Unit is the body responsible for the receipt, treatment and operation of the Harassment Complaint Line. However, as the harassment situations and discriminatory acts are particularly sensitive cases, a Harassment Prevention Committee (HPC) has been created. The Regulatory Compliance Unit may delegate the instruction of the harassment complaints to this Committee, which is made up of three women that belong to the areas of Regulatory Compliance, Legal Advice and Human Resources who have received the specific training necessary to deal with these cases.

Personal Data Protection

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In compliance with the General Data Protection Regulation (GDPR) and the current Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, the Sacyr Group has developed policies related to this matter and has implemented a whole series of technical and organizational measures with the objective of minimizing the risks associated with the processing of personal data and guaranteeing the protection of the rights in this area, both of its employees and of related third parties..

As part of the measures adopted, the Sacyr Group has appointed a Data Protection Officer (DPO), as provided by the GDPR, as a figure that exercises, among others, the function of supervising compliance with regulations, informing and advising on matters of data protection and serves as a point of contact with the Control Authority. Likewise, a Security and Privacy Committee has been set up to address the security and privacy of information from an integrated and joint perspective.

You can contact the DPO at the following address: dpo@sacyr.com

You can exercise your rights regarding personal data protection at the following address: protecciondedatos@sacyr.com

For more information about Sacyr's data protection policy click here

Prevention of money laundering

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The Sacyr Group is firmly committed and works decisively to prevent money laundering and terrorist financing. In this sense, as an obligated subject of the regulations in this area based on some of the activities carried out in the Group, it has developed a control model that allows compliance with current regulations in this area.

The Sacyr Group has enabled a specific channel sacyr.prevencionbc@sacyr.com to report any possible breach of the Money Laundering and Terrorist Financing Prevention Regulations, or of the policies and procedures in this matter implemented by the Sacyr Group, as well as to pose any query about it.