Compliance

The Code of Conduct sets the standard of behaviour that Navantia wishes to observe in all its business activities. It is a written reflection of the Company’s commitment to its principles and values.

All those who provide services at Navantia as directors, managers or workers are receivers of the Code of Conduct, because it is they who must adapt their behaviour to the standards established therein.

 

On the other hand, Navantia has a specific Code of Conduct for Business Partners. This Code is aimed at all customers, partners, suppliers, advisors and other persons or entities that have a relationship with Navantia and its objective is to establish their behavioural parameters, through basic principles of action, for the duration of their relationship with our company.

This Code of Conduct for Business Partners must be accepted by them and will be annexed to their corresponding contracts.

Navantia has prepared a model to organise, prevent, manage and control corruption and to deal with the commission of criminal offences, and has likewise compiled the procedures and controls currently implemented to effectively prevent and mitigate these risks.

Navantia has for that purpose prepared a Compliance Manual, which contains a detailed analysis of the risks of all the offences/crimes that could theoretically be committed in Navantia’s different areas, taking into account, on the one hand, the policies and controls already implemented, and on the other hand, the degree of exposure to the offences/crimes detected in the specific processes, depending on the sector and the activities in which Navantia is involved.

The purpose of this Manual, and the rest of the procedures and policies implemented, is intended to guarantee (i) the effective ethical culture and compliance culture within the Company, and also (ii) to minimise the risk of illegal behaviour of all those who provide services at Navantia in the capacity of directors, managers and workers, as well as the representatives, governors, agents and mediators who act in the interest of or on behalf of the company.

It is the autonomous initiative and control body that has been entrusted by the Board of Directors to carry out the task of promoting and liaising the implementation, supervision and control of the Compliance Management System and its ongoing improvement.

It is composed of the Board and Compliance Secretariat Manager, who is the Chairperson, and the Managers of Human Resources (HR), Legal Advice (LA Director), Finance (F Director) and Technology & Digital Transformation (TDT Director).

The Compliance Committee, as the controlling body, has a direct line to Navantia’s Board of Directors, to whom it reports its main activities in an ordinary way.

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.

Contact:

• Adress:

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

• Email  [email protected]

Navantia’s Ethics Channel is a communication channel for employees, suppliers, agents, business partners and other third parties related to the company, to report possible indications or incidents contrary to the law (criminal or administrative, of a serious or very serious nature) or to the actions set forth in Navantia’s Code of Conduct.

This mechanism is also available to receive queries about doubts that may arise in the application of the company’s internal rules and procedures related to Regulatory Compliance.