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Code of Conduct and Ethical Channel

The purpose of the Code of Conduct is to establish the values that should guide the behaviour of all persons in the Company.

This code, approved in 2007 and amended in 2011 and 2016, is the core of the Company's ethics and compliance model and seeks to guide relations between employees; actions by the latter vis-à-vis customers, shareholders, suppliers and service providers; and relations with public and private institutions and with society in general.

ACCIONA has a Code of Conduct Committee whose mission is to oversee compliance with the Code, and an Ethics Channel by which irregular conduct in connection with the Code can be reported.

This extremely important initiative provides all employees with an effective tool for raising queries and notifying possible breaches of the Code of Conduct.

The Rules of Procedure in connection with the Code of Conduct provide rules for action by employees and the Company in the event of situations that conflict with or breach the ACCIONA Group's Code of Conduct. They also establish the necessary preventive measures to identify, assess and control risks of breach of the Code.

The Ethical Channel is the instrument ACCIONA makes available to employees, suppliers, customers and collaborators so they can communicate any doubts, questions or the occurrence of any irregularity related to the Code of Conduct and anticorruption regulations. Any questions of irregularities can be communicated to canal-etico@acciona.com

 

Anti-corruption and anti-bribery measures

Commitment to the fight on corruption and bribery, and free competition

During 2015, the Group made significant progress in the implementation of the model. As a further step in ACCIONA's aim to follow the best Corporate Governance practices, the Company has established a compliance function with the creation of a new Unit that reports directly to the Executive Chairman and the Auditing Committee of the Board of Directors.

ACCIONA  openly expresses its support and respect for the fundamental tenets of the fight on corruption, as laid out in the United Nations Convention against Corruption. It further pledges to make every effort to combat all forms of corruption, including extortion or the instigation of criminal offences, bribery, clash of interests, influence-peddling, falsification of documents, money laundering, use of insider information and fraud:

The Board of Directors of ACCIONA has approved a crime prevention and anti-bribery policy. Its goal is to send all directors, executives and employees, and third parties related to the Group, a resounding message against any form of criminal activity, particularly corruption, in our operations. The commitment by all of ACCIONA's people to ethics and integrity, respecting the rules, is also set out in the Code of Conduct and in the Anti-corruption Rules.

As a Company governed by ethics and corporate transparency, ACCIONA  rejects all kinds of unfair competition:

Similarly, the Code of Conduct lays out guidelines for conduct and anti-corruption and anti-bribery measures, and it calls on employees to comply with current law. Without exception, ACCIONA  will not tolerate any attempt to bribe the Company, any of its employees or vice versa. In addition, and among other ethical principles, the Code of Conduct promotes free competition.


ACCIONA Group Anti-corruption Guidelines

The ACCIONA Group undertakes to conduct its business with integrity. This means avoiding any form of corruption and fulfilling all the applicable laws and other regulations against bribery and corruption and to follow the recommendations of international organisations such as the OECD and the United Nations. The Group is also a signatory of the United Nations Global Compact, under which we have made a commitment to combat corruption and bribery worldwide.

 

This commitment on the part of ACCIONA is set out in our Code of Conduct, our Anticorruption Policy, as well as in the Anti-corruption Guidelines approved by the Group Board of Directors. These guidelines provide compliance guidelines to prevent misconduct, being applicable and compulsory for employees and third parties with which ACCIONA works (including agents, brokers, consultants and suppliers).

 

This is translation of a duly approved Spanish-language document, and is provided for informational purposes only. In the event of any discrepancy between the text of this translation and the text of the original Spanish-language document which this translation is intended to report, the text of the original Spanish-language shall prevail.

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