Corporate code of conduct

The Code of Conduct establishes the standard of conduct that Navantia wishes to observe throughout its business activity, and reflects in writing its commitment to its principles and values.

The Code of Conduct represents a major step forward in the process of improving corporate governance at the Company, and is an ideal instrument for the people comprising Navantia, and third parties connected with the company, to be able easily to ascertain the reality of the firmness of Navantia’s ethical commitment.

The Code of Conduct is aimed at individuals and entities who are direct recipients (recipients) and also those who have to be or may be familiar with it (informed parties).

In the first place, the Code of Conduct is intended for all individuals providing services at Navantia and acting in their capacity as directors, officers and workers, who must adjust their conduct to the standards established therein.

Likewise, this code of conduct is intended for the representatives, proxies, agents and mediators acting in Navantia’s interest, or in the name and on behalf of Navantia.

The Code of Conduct is intended mainly for clients, suppliers, advisors and other individuals or entities that interact with Navantia for professional or business reasons.


Compliance System

Navantia has developed a model for the crime prevention, as well as compiled the procedures and controls currently in place for the effective prevention and mitigation of these risks. Navantia’s Compliance Manual sets out the Compliance System implemented by the Company from the perspective of the Spanish Criminal Code.

The Compliance Manual applies to all employees, executives and persons employed by or accountable to Navantia and its subsidiaries, and to their legal representatives and de facto or de jure directors.

This Manual is divided into two parts:

  • General part. The general part of the Manual defines the general control structure currently existing at Navantia on the basis of the essential elements established by Article 31bis of the Spanish Criminal Code. This Manual includes:
    • Structure and functional organisation of Navantia, along with its main lines of activity.
    • Legal context of the criminal liability regime of corporations.
    • Purpose and objectives of the Manual as a mechanism to accredit Navantia’s crime prevention compliance obligations in relation to art. 31 bis of the Spanish Criminal Code.
    • Main general control elements of Navantia’s Compliance Model.
    • Assessment of criminal risks, controls and corrective measures
    • Good practices in the field of corruption prevention
    • Violations of the Compliance Model, notification of any suspicious actions and disciplinary procedure
    • Activity of Navantia with regard to dissemination and training tasks regarding compliance and the prevention of criminal risks.
  • Special part. As a complement to the general part of the Compliance Manual, a special part has been developed in an internal procedure of the company, in order to collect all the criminal risks identified in Navantia, as well as the specific control system required for every one of them.

Compliance Committee

This Committee is the self-governing body of initiative and control, entrusted by the Board of Directors with promoting and coordinating implementation, supervision, monitoring and control of the Code of Conduct and the Crime Prevention Compliance and Anti-Corruption Systems of Navantia.

The Committee is made up of the Chief Compliance Officer and the heads of Human Resources (HR), Legal Affairs (LA) and Finance (FD).

The Chief Compliance Officer takes on the chairmanship of the Committee, the coordination of its functioning, and the definition of the annual working plans regarding supervision, monitoring and control of Navantia’s Code of Conduct and Crime Prevention Compliance and Anti-Corruption Systems.

The Compliance Committee, as a supervisory body, reports directly to the Board of Navantia.


Transparency is a permanent policy, and Navantia complies with Law 19/2013, of 9 December 2013, on transparency, access to public information and good governance, the purpose of which is to expand and strengthen the transparency of public activity as a mechanism to facilitate control of public action.

Navantia promotes active transparency and fulfils its obligations by regularly and promptly publishing relevant information to ensure the transparency of its activities, making them known to citizens.



Transparency International positively assesses Navantia’s active advertising and places it at level “C” in the latest Defence Companies Index on Anti-Corruption and Corporate Transparency Defense (DCI), published in February 2021, which evaluates the levels of public commitment to anti-corruption and transparency in the corporate policies and procedures of 134 of the world’s largest defence companies.

With regard to the right of access to public information, Navantia has made available to citizens, through the Transparency Portal, the possibility of exercising this right, within the limits established in law.


  • Adress:

Navantia, S.A.  S.M.E. (Ley de Transparencia)
Calle Velázquez 132
28006  Madrid (Spain)

Whistleblowing channel

Navantia has a whistleblowing channel where it is possible to report, after proper identification, any suspected unlawful conduct or violations of the Code of Conduct. Any wrongful events or irregularities that are contrary to Navantia’s interests can also be reported.

All reports reported via this channel are evaluated by the Chief Compliance Officer and the Head of Integrity and Crime Prevention Compliance.

Navantia assures the confidentiality and anonymity of complaints and the anonymity of good-faith complainants.

Investigations of the alleged events shall be conducted in accordance with the presumption of innocence and other procedural guarantees for the respondent.

Compliance Channel

Navantia has in place a queries channel allowing Navantia employees and third parties connected with our Company (clients, suppliers, etc.) to have an open-door channel in place to express their doubts, concerns and, in short, to collaborate in the creation of an environment where good practice prevails.

These consultations are handled directly by Compliance Committee staff.