Code of Ethics and Conduct

Our Code of Ethics and Conduct includes guidelines for the professional and personal conduct that the Board of Directors of Sacyr, S.A. considers necessary to create value for our shareholders, investors, employees, Group companies, and other stakeholders.

This Code is the basis and foundation of the Sacyr Group Regulatory Compliance Model for Criminal Prevention and Competition Defence and its implementing regulations.The oversight of the Model correct functioning corresponds to the Audit Committee, which has the support of the Regulatory Compliance Unit for its executive management.

We provide convenient access to this Code of Ethics and Conduct in order to ensure that not only our employees, executives, and directors, but also our clients, suppliers, partners and all other stakeholders understand and share the values, commitments and standards that guide our actions.

Compliance policies

The commitments we assume under our Code of Ethics and Conduct are developed in the Group’s internal regulation, which is also part of our Regulatory Compliance Model for Criminal Prevention and Competition Defence.

The main policies for the development of our Code of Ethics and Conduct are as follows:

Ethics Channel

The Ethics Channel is a corporate tool intended to facilitate the secure and confidential formulation, by employees or by third parties, of any query regarding the scope and applicability of the Code of Ethics and Conduct and, in general, of the Group's Regulatory Compliance Model, as well as to report situations of infringement of this Code of Ethics and Conduct, of the Compliance Model in general or of the applicable internal or external regulations, especially potential conducts related to corruption, anticompetition or constitutive of criminal offence that can be detected.

Among other behaviors, you can communicate cases of fraud, corruption, anti-competitive practices or violations in the prevention of money laundering.

According to our Harassment Prevention and Complaints Management Protocol reflects, we are committed to prevention and correct action in the event of possible sexual, workplace and gender-based harassment at work. For this reason, we have this Ethics Channel, through which you can report possible situations of harassment or discriminatory acts in our workplaces.

The Regulatory Compliance Unit is the body responsible for the operation of the Ethics Channel, as well as for the analysis of the complaints and queries formulated through this channel, safeguarding the confidentiality and rights of those affected and ensuring the protection of the complainant.

Basic privacy information

The Sacyr S.A. Board of Directors is responsible for the processing of your personal data within the framework of the comprehensive management of the Internal Information System and the Ethics Channel that you will access.

We will process your personal data with the sole purpose of investigating the facts communicated and adopting the appropriate measures within the framework of current legislation in this regard. If you prefer, you can send us an anonymous complaint through our Ethics Channel, which will be investigated in accordance with the provisions of Law 2/2023, of February 20^th, regulating the protection of persons who report breaches of Union Law.

Likewise, we inform you that we will obtain the data that you provide us through the Ethics Channel or through third parties in the event of public disclosure, and if applicable, we will process the information contained in said disclosure.

You can exercise your rights of access, rectification, deletion, opposition, purpose limitation and portability with respect to the personal data you have provided by writing an email to protecciondedatos@sacyr.com.

You can contact our Data Protection Officer at dpo@sacyr.com or obtain additional information on how we process your data in the Sacyr Ethics Channel here