This commitment to ethics and doing the right thing is not optional. No specific business circumstances can be used as justification for acting outside the law or for behaving in a way that goes against our values and ethical standards. The Elecnor Group applies the principle of zero tolerance to practices that contravene any provisions regarding ethics and integrity, in the expectation that the behaviour and actions of its professionals and the third parties with whom they interact will remain firmly aligned with the principles and values established in this Code, that is to say, in the regulations or legislations on which it is based and/or the policies or procedures that shape it. All of us in the Elecnor Group should accept and promote the values and principles established in this Ethical Code, with this responsibility being all the more significant for the members of the Board of Directors and executives, who should represent a benchmark and model to follow, and provide inspiration for the rest of the organisation.

Corruption and bribery hold economic development back, weaken democracy and are detrimental to social justice and the rule of law, seriously damaging the economy and society, and they often enable organised crime to operate more easily.

The Elecnor Group is fully committed to the fight against corruption and bribery in all its forms. The Anticorruption Policy of the Elecnor Group reiterates and reinforces this commitment and fosters the proper behaviour of employees in order to further the fight against bribery and corruption and ensure compliance with all anti-bribery and anti-corruption laws and other regulations, as well as with the guidelines from international bodies in this field, such as the OECD and the United Nations.

The Elecnor Group expressly forbids:

• Directly or indirectly offering, promising or giving bribes to any third party, whether in the public or private sphere.
• Directly or indirectly offering, promising or giving facilitation payments to initiate administrative processes or procedures.
• Directly or indirectly offering, promising or giving presents, gifts or courtesies to any third party, contravening the Policy on presents, gifts and courtesies.
• Directly or indirectly offering, promising or giving contributions for political purposes, in the name of the Elecnor Group.
• Obtaining favourable treatment through sponsorship or donations.
• Requesting, accepting or receiving any kind of unjustified benefit or advantage in order to unduly favour a third party in the acquisition or sale of products, procurement of services or in any other trade or business relationship.
• Establishing business relationships with third parties without complying with the minimum due diligence requirements regarding third party knowledge.

The Elecnor Group has the firm business commitment of ensuring strict compliance with competition law. One of its priorities is to develop a solid corporate culture of regulatory compliance reflected in the daily decision-making of all its directors, executives, or employees, as well as other individuals or legal entities acting on its behalf or representing it, helping them, within the scope of their responsibilities, to detect and avoid practices that may restrict competition.

In accordance with the Competition Law Policy of the Elecnor Group, it is expressly forbidden to:

• Make agreements or establish concerted or consciously parallel practices with competitors that could restrict competition between economic operators, e.g.: price fixing or other commercial terms, market or customer sharing, limitation or control of production, etc.
• Manipulate public or private tenders in an anti-competitive way through Temporary Business Associations or unjustified outsourcing, bid-rigging, support or courtesy bids, or any other means.
• Accept or arrange collective recommendations or decisions, issued or adopted by or on behalf of associations, which may restrict competition between economic operators.
• Exchange commercially sensitive information with competitors or third parties, e.g.: individualised, disaggregated data about strategic variables such as prices, discounts, quantities or sales volumes, present or future.
• Perform actions that could lead to exploitative abuse of a dominant position, e.g.: fixing unfair or discriminatory prices or commercial terms, unjustified refusal to supply or restricting supply.
• Perform acts of unfair competition that, due to being in the public interest, may be likely to affect the general interest, e.g.: deceitful or misleading conduct, aggressive practices, loss-leading, disclosure of trade secrets, illegal advertising, etc.

The Elecnor Group is fully committed to supporting, respecting and protecting human rights in all its areas of activity in accordance with its ethical principles and commitments concerning sustainability, in compliance with applicable national and international regulations, taking the main international standards and guidelines as a reference. 

The Human Rights Policy of the Elecnor Group establishes the principles that underpin this commitment. In line with this policy, the Group is firmly committed to: 

• Encouraging a culture of respect for human rights and activities aimed at raising awareness among professionals in this field.

• Guaranteeing non-discrimination on the grounds of sexual orientation or identity, gender, age, race, disability or any other personal or social circumstances likely to be subjected to discrimination, by fostering equal opportunities and respect for diversity.  

• Rejecting forced labour in all its forms, particularly regarding children.  

• Protecting the health and safety of its professionals. 

• Respecting local communities’ rights, with particular care and support for the most vulnerable groups.

• Rejecting corruption in all its forms. 

• Recognising employees’ freedom of association and assembly. 

Safeguarding confidentiality and stakeholders’ right to privacy, and guaranteeing respect for privacy and data protection regulations. 

Taking the necessary steps as soon as possible in the event of detecting a human rights violation. 

The Compliance System of the Elecnor Group is the main tool used by the organisation to ensure that its activities are carried out in accordance with the highest ethical standards and in full compliance with the law. It is designed and operated in line with best national and international practices. 

As proof of this fact and commitment, in January 2018, Elecnor became the first Spanish company in its sector to obtain certification under the UNE-ISO 37001 standard for “Anti-bribery Management Systems”, the first and most demanding international standard that can be certified for the implementation of compliance and anti-corruption management systems. 

Likewise, in February 2019, the organisation also obtained the certification of its Compliance System under the UNE 19601 standard for “Criminal Compliance Management Systems”, which is the main benchmark in Spain for designing and implementing systems for the prevention of criminal offences and risks, and is fully based on the highest international standards in this field. 

Furthermore, in June 2024, Elecnor became the first company to be certified under UNE 19603 for “Compliance Management Systems in the field of Free Competition”, a pioneering standard in this area, reinforcing its commitment to best Compliance practices in the field of competition law. 

The Elecnor Group has made a confidential channel available to its professionals and/or third parties with legitimate interests, whereby they can report and inform, in good faith, about conduct that is irregular or in breach of current legislation or the provisions in the Group’s Code of Ethics and Conduct, as well as express any doubts regarding this subject or suggest improvements to the existing internal systems of control.

All the professionals in the Elecnor Group have the obligation to immediately report any irregular practice, illegal or unethical behaviour of which they may have knowledge or have witnessed. This channel can be accessed via the following e-mail address: codigoetico@elecnor.com or by post at: Apartado de Correos nº 72-48008 (Bilbao, Vizcaya - Spain) (to the attention of: "Canal Ético").