Ethics and Compliance
ETHICAL AND REGULATORY COMPLIANCE IS ESSENTIAL IN THE DEVELOPMENT OF ACTIVITIES
COMSA Corporación considers it essential to develop its activity based on ethical and regulatory compliance criteria. The group first approved its Code of Ethics in 2011 and since then, it has been revised on several occasions by the Board of Directors. The purpose of this document is to establish the values, commitments and principles of action that should guide the daily work of all members of the Group’s management bodies, executives and employees.
You can consult COMSA Corporación’s Code of Ethics here.
Furthermore, in accordance with Law 2/2023 of 20 February (“Whistleblower Protection Act”), the Whistleblowing Management System Policy (Ethics Channel) is made available to you, which defines the general principles that COMSA Corporación defends, promotes and adopts in the process of receiving, processing, recording, investigating and responding to communications received through the Ethical Channel, which you can access at the bottom of this page.
COMSA Corporación ensures knowledge, understanding and compliance with the provisions of the Code of Ethics and the Protocols, Policies and other internal regulations that develop it, through its Ethics Commission, which has been constituted and its members appointed by the Board of Directors and has autonomous powers of initiative and control in the development of its functions. The Ethics Commission is also the body responsible for ensuring the proper functioning of COMSA Corporación’s ethics channel.
Consult here some of the main protocols and policies of COMSA Corporation’s Compliance Model together with other specific documents applicable to the various jurisdictions in which the Group operates.
Jorge Miarnau, chairman of the Board of Directors
Chairman of the Commission
Guillermo Lorenzo, Infrastructure, Enginnering and Services general director
Board Member
Manuel Fonseca, Economic and Finantial Services general director
Board Member
Santiago Sanjosé, director of Management Control Area
Board Member
Ignacio Ponz, director of People Area
Board Member
Carles Mases, Legal Department director
Ethics Commission Secretary
The ethical channel
The ethical channel is a communication tool that allows both the internal personnel of COMSA Corporación and the group’s companies and third parties to inform the Ethics Commission of any situation of non-compliance with the law, the Code of Ethics or the internal rules that develop it.
The ethical channel
The ethical channel is a communication tool that allows both the internal personnel of COMSA Corporación and the group’s companies and third parties to inform the Ethics Committee of any situation of non-compliance with the law, the Code of Ethics or the internal rules that develop it.
Communications may be anonymous and contain any doubts or queries regarding ethics and regulatory compliance. They will be received and analysed in a diligent, rigorous and confidential manner and will be treated in accordance with the Protocol established for this purpose, based on best practices, with the aim of responding to them and processing them in an orderly manner.
In order to ensure the confidentiality of the data and the object of the complaint, the documentation will be protected in accordance with the requirements established by the Data Protection regulations.