We are FCC - Nº7

The Compliance System of the FCC Group is the model used by the organisation to ensure that all the Group’s companies and all its em- ployees behave in accordance with certain principles set out in its Code of Ethics and Conduct, and that the company does not commit any cri- minal offence. The Model is made up of a set of rules and procedu- res and bodies responsible for their application. The high-level body entrusted with the promotion and supervision of the FCC Group’s Compliance Model is the Compliance Committee, which is chaired by the corporate Compliance Officer. The figure of the Complian- ce Officer has recently become very important in the business world, as a result of the reform of the Spani- sh Criminal Code, which introduces the criminal liability of the individual. Companies may face criminal sanc- tions if their legal representatives, managers, employees, suppliers or subcontractors commit any crime for the benefit of the company. The implementation of appropriate procedures and controls to reduce the risk of committing crimes, the development of a culture of zero to- lerance for possible legal breaches and the collaboration of the entire organization in the periodic verifica- tion that the established controls are adequate and effective, will allow this system to be an attenuating factor in unwanted situations of pos- sible crimes, helping the continuity of the company in the development of its activity and giving employees greater legal certainty in making bu- siness decisions. For this reason, all employees in the organisation are responsible for knowing, complying with and enfor- cing the Group’s code of ethics and conduct, as well as collaborating in the identification of risks of crime, applying the procedures established in the Compliance Model and veri- fying compliance with the controls designed to reduce the risks of legal non-compliance. Specifically, the persons indicated in the organization as being res- ponsible for risk controls will certify, every six months, their compliance through an IT tool implemented by the organization for this purpose. Javier López-Galiacho, Director of Corporate Responsibility and Compliance for the FCC Group The FCC Group reminds all its mem- bers of everyone’s commitment to the application of the highest stan- dards of integrity and ethical and regulatory compliance in their busi- nesses. The FCC Group is and must continue to be synonymous with absolute integrity and the highest level of ethical conduct, fighting corruption in all its manifestations. For this reason, the company, at the proposal of the CEO and with the fa- vourable report of the Appointments and Remuneration Committee at its meeting held on 11 September, the FCC Group has appointed Javier López-Galiacho, Director of Corpo- rate Responsibility and Compliance for the FCC Group. The main mis- sion of the post will be to implement the FCC Group’s Criminal Preven- tion Model, as Corporate Complian- ce Officer, combining this work with Corporate Responsibility manage- ment. Its functions include the dis- semination of the Prevention Model, the identification of risks, the defini- tion and monitoring of the relevant controls and the treatment of com- plaints and investigations relating to crimes and breaches of the Code of Ethics and Conduct received. In each of the Group’s businesses, the figure of the Business Com- pliance Officer is established, under the hierarchical dependence of the Board or equivalent decision-ma- king body of the business, and func- tional of the Corporate Compliance Officer, whose main task is to assist the Corporate Compliance Officer in the implementation of the Complian- ce Model. Likewise, in order to pro- vide support in matters of Criminal Prevention and Compliance in each business, the Business Complian- ce Committees have been set up, made up of the Compliance Officer and the Director of Legal Advice and the Human Resources Director of the business itself. The FCCGroup implements a Compliance system in the Company and reinforces its commitment to integrity Javier López-Galiacho. F C C G R O U P 8 F C C G R O U P