WHAT IS COMPLIANCE?

Compliance refers to the fulfillment of obligations, both of an imperative nature as a consequence of compliance with a legal norm, and of those that the ACS Foundation has decided to assume voluntarily, with the ACS Code of Conduct at the top of the list.

Throughout 2020, 2021 and 2022, a Compliance System has been implemented in the ACS Foundation which, essentially, has led to three significant changes:

• New formats for Agreements with grantees.

• Stricter documentation of the grantee's obligations.

• Greater control of suppliers, although in the case of the ACS Foundation, they are not potentially problematic.

WHO IS RESPONSIBLE FOR COMPLIANCE?

The existence of a true culture of compliance requires the participation of all the people who make up the ACS Foundation. In order to help maintain this culture, a criminal compliance body has been set up to ensure that the obligations affecting the ACS Foundation are respected at all times.

HOW CAN I REPORT A BREACH?

The ACS Foundation provides all its members and third parties with the Ethics Channel, a tool through which they must report breaches of the law, the ACS Code of Conduct, as well as any other internal regulations or policies.

Communication with the Ethical Channel is confidential and allows anonymous complaints to be made. The ACS Foundation guarantees that there will be no retaliation against the complainant. The processing of data will be carried out in accordance with the provisions of current personal data protection regulations.

You can contact the ACS Foundation Ethical Channel by the following means:

• By post to: Canal Ético Fundación ACS, Avda. Pío XII 102, 28036 Madrid, Spain.

• Through the online channel accessible from here.

WHAT ARE THE INTERNAL COMPLIANCE RULES?

At the epicenter of the ACS Foundation's compliance culture are the ACS Group Code of Conduct and the Code of Conduct for Business Partners, which set out the standards of behavior expected of all members of the ACS Foundation. In this sense, all employees, managers and persons associated with the ACS Foundation are expected to comply with the aforementioned Code, as well as with the rest of the implementing regulations.

The ACS Foundation has set up a Criminal Compliance and Anti-Bribery Management System in order to structure an environment for the prevention, detection and early management of Criminal Compliance and Anti-Bribery Risks, as well as to reduce their unwanted effects in the event that they materialize, helping to generate a culture of ethics and respect for the law among all members of the ACS Foundation in matters applicable to them.