Compliance processes

Quality & Environment Department

The quality, environmental and occupational safety management systems are continually being assessed and audited internally. The scope of the audit plans affects both central services and the production centres. In all cases, central services audit both the business areas and the corporate sphere, with the cooperation of qualified technicians who know the business but are independent of the production line.

Internal audit

The Audit Department, which reports directly to the Chairman and is at the disposal of the Board of Directors through the Audit and Control Committee, contributes to managing the risks the Group faces in meeting its objectives.

The Audit Department continually analyses the control procedures and systems, organization models and management variables of the main areas of Grupo Ferrovial, including the projects within the various business lines and aspects of the various support departments. The conclusions are then reported to the heads of the areas assessed and the Group's Senior Management, including, where appropriate, recommendations for specific actions designed for implementing possible improvements.

The Audit Department also collaborates in investment and post-investment processes, participates actively in fraud prevention and control, and arbitrates internal disputes between the various Grupo Ferrovial companies.

Lastly, it should be mentioned that in order to perform these functions, the Audit Department has the knowledge and experience accumulated from continuous direct contact with the various businesses, and draws on assistance from leading external advisors whenever necessary.

Code of Business Ethics

Since 2004, Grupo Ferrovial, S.A. has a Code of Business Ethics, approved by the Board of Directors, that establishes the basic business ethics principles and commitments that all its companies, employees and executives must respect and comply with in the performance of their activities.

The document complies with the Company's commitment to ensure that relations between the Company, its employees and other interest groups adhere to the principle of respect for the law, ethical integrity and respect for human rights.

In parallel, the company has also established a procedure for proposing improvements, making comments and criticisms, and reporting inefficient situations, inappropriate conduct, possible cases of non-compliance with the Code of Business Ethics and other matters, all of which can be done anonymously. The new Board of Directors Regulations, which were approved on 23 February 2007, confer responsibility for supervising this mechanism on the Audit and Control Committee.

Procedure for protecting Grupo Ferrovial's assets by preventing internal fraud

An internal procedure, whose aim is to protect the corporate assets through the prevention of conduct that could mean internal fraud, has been current in Grupo Ferrovial since 2005.

The procedure implements the corresponding principle of the Code of Business Ethics and establishes the right and obligation to inform of behaviour or actions that may jeopardize Group assets either to a superior or via a system through which employees can make a report (signed or anonymous).