Dragados Offshore has Corporate Compliance Program (CCP) in force, in accordance with the UNE 19601 (2017) and ISO 37001 (2016) regulations, in order to enhance its Business Ethics culture and respect to the law, and that it is an integral and permanent part of all its business processes.

The final objective is to prevent the commission of any infraction or unlawful behaviour. For this purpose Dragados Offshore has adopted some measures based on the prevention, monitoring and control, and the application of an appropriate sanction regime to allow an active and effective fight against the commission of crimes in the performance of their activities.

In this context and in order to meet this objective, Dragados Offshore's Corporate Compliance Programme consists of the following documents:

Management Procedures of VINCI, S.A.

1. Manifesto ››
2. Code of Ethics and Conduct ››
3. Anti-corruption Code of Conduct ››
4. Guide on Human Rights ››
5. Environmental Guidelines ››
6. Guide for Users of Information System
7. General Cybersecurity Policy
8. Essential and fundamental actions concerning Occupational Health and Safety ››

Protocols of COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.

Framework Protocol
Regulatory Compliance Protocol
Protocol for Reporting Suspected Irregular Activities
Corporate Defence Procedure Activation Protocol
Protocol on Training of Professionals in Regulatory Compliance Issues
Statute of the Legal Compliance Body- Protocol on the profile, experience and organic location of Legal Compliance Body, Corporate Compliance Officer and the Corporate Compliance Delegate
Protocol for Core Policies
Catalogue of Forbidden Conducts and Expected Behaviours
Code of Conduct for Business Partners ››
Protocol for Compliance with Competition Standards ››
Protocol for Management of the relations with Public Administrations and Civil Servants
Protocol for Facilitation Payments

Internal System Regulations of COBRA SERVICIOS, COMUNICACIONES Y ENERGÍA, S.L.U.

DRAGADOS OFFSHORE DOCUMENTS

1. Regulatory Compliance, Anti-Bribery and Behaviours Against the Defence of Competition Policy ››
2. Rules of Ethics and Behaviour of the Employees of Dragados Offshore ››
3. Crime Prevention Plan
4. Procedures for the Crime Prevention Plan
Complaints Management
Sanctions Management
Criminal. Bribery and Competition Risk Evaluation
Anticorruption Procedure
Professional Courtesies
Mobbing
Money Laundering and Terrorism Financing Prevention
Information Technology Rules
Protection of Industrial and Intellectual Property Rights
Treatment of Confidential Information and Sensitive Business Information
Due Diligence with Business Partners
Compliance with Defence of Competition regulations
Due Diligence on Human Rights

An email address has been set up infocompliance@dragadosoffshore.es to provide information and solve any doubts about the CCP.

Any person with knowledge or justified suspicion of any type of infraction or illicit behaviour, may inform via the following channels enabled:
Digital Platform: https://cobrais.integrityline.com
Phones:
Spain:+34 900 535 362
Mexico:+52 8 006 070 025
If choose this channel, it will be required to enter a code of service 22656 during the call.
Ordinary mail to the attention of the Internal Corporate Compliance Officer, Dragados Offshore, S.A.U., Bajo de la Cabezuela, S/N, Puerto Real 11510, Cádiz.

All those people who in good faith transmit their communications will be protected against any type of discrimination, retaliation or penalty due to them. False or defamatory complaints will be subject to disciplinary action in accordance with internal procedures, agreements and applicable legal regulations. Confidentiality of the identity of the whistle-blower will be guaranteed. The identity of the whistle-blower will not be disclosed to third parties, neither to the person reported nor to the management, except when disclosure is necessary to the relevant persons involved in any subsequent investigation or legal proceeding initiated as a result of the investigation carried out by the Compliance Management System. In accordance with the provisions of the applicable Personal Data Protection regulations, you are informed that the data collected through this Ethical Channel will be processed by DRAGADOS OFFSHORE S.A.U., in order to process the corresponding complaints and queries, in accordance with the provisions of the Corporate Compliance Program and internal regulations. The basis of legitimacy of this treatment is the consent of the interested party when voluntarily submitting the information. The data will be kept for the duration of the investigation and its deletion is not requested and, in any case, in compliance with the applicable statutory limitation periods. The information received may be transferred to the corresponding COBRA companies if necessary for the purpose of the investigation. You can consult the companies of COBRA in any official information register. Likewise, it is reported that, in any case, the interested party may at any time exercise the rights of access, rectification, deletion, portability, limitation or opposition by by sending a communication to the following e-mail address dpd@dragadosoffshore.es