Promoting ESG transparency is one of Navantia’s priority objectives in accordance with which we have started to adapt our sustainability report to feature new trends and best practices in regard to non-financial reporting.

Moreover, attention is brought to Navantia’s commitment to transparency in line with Act 19/2013, of 9th December, on Transparency, Access to Public Information and Good Governance, through the inclusion of relevant information affecting such.

Initiatives:

Governance

Navantia implements a Corporate Governance model establishing the fundamentals of the company strategy and contributing to the integrity, efficiency and agility in company management. This model reinforces our activity supervision and control systems, risk management and personnel development, thus ensuring compliance with internal and external requirements.

The company also implements a Corporate Governance Code, which identifies the set of policies, regulations and other standards and also establishes a framework for implementation of the structure and operation of Navantia’s Management System.

Within this framework, the company focuses on generating security and value for its shareholders, the Board of Directors and for all stakeholders in general.

Navantia has simplified, restructured and mapped its governance model, and also its processes and standards in line with our strategic priorities.

Risks

Navantia’s internal risk control and management system is based on a combined assurance model comprising three lines, taking the best international practices as the references. This model has a principles based approach and has been adapted to the organisation’s circumstances and objectives, thereby representing coordination, cooperation, alignment and feedback between Navantia’s different areas and departments. This way we collectively contribute to creating and protecting value and achieving better risk coverage and control functions.

Human Rights

Chapter III of Navantia’s Business Code of Conduct addresses Respect for People and comprises a fundamental principle which is inherent to all Navantia’s actions.

Navantia is committed to effectively abolishing child labour and eliminating forced or compulsory labour, which is likewise discussed in Chapter III of our Code of Conduct.

Furthermore, labour rights, the freedom of assembly and the right to collective negotiations are guaranteed and regulated in the 1st Inter-site Agreement, thus complying with the framework of the International Labour Organisation (ILO). The company guarantees equal treatment at work and non-discrimination among all its employees, regardless of their race, colour, religion, sex or sexual orientation, nationality, age, pregnancy, disability and any other legally protected circumstances.

Sustainable Public Procurement

Navantia is driving Sustainable Public Procurement, which additionally takes environmental, social and ethical aspects into account in procurement processes and when contracting services. This materialises through a responsible procurement policy based on relations with the supply chain and suppliers who take ESG into account in order to achieve integration of the three priority vectors in all sustainability scenarios. Navantia already incudes ESG criteria in most of its tendering processes, and has created a Sustainable Public Procurement work group to drive relations with our suppliers.

Navantia has developed a crime prevention model, and has standardised the procedures and controls that were implemented to prevent and mitigate these risks. Navantia’s Compliance Manual includes the Compliance System implemented by the company, from the perspective of the Spanish Criminal Code. This Manual is applicable to all employees, directors and other persons who depend on Navantia and their subsidiaries, and also their legal representatives and de facto or legal managers.

Navantia also has a Code of Conduct which establishes the standards of conduct that Navantia wishes to see in all its business activities, and is a written reflection of our commitment to these principles and values.

The Code of Conduct is applicable to the people and businesses who provide services at Navantia as managers, directors or workers. Our customers, suppliers, advisors and other persons or entities related to Navantia through their work or business must also be aware of the Code of Conduct.

Moreover, Navantia’s Compliance Committee is the autonomous body concerning initiatives and control, and its task is to promote and coordinate the implementation, supervision, follow-up and control of the Code of Conduct and the Criminal Compliance and Anti-corruption Systems implemented by Navantia. It consists of the Chief Compliance Officer, the Human Resources Director, Legal Counsel Director and Financial Director.

The Chief Compliance Officer chairs the Committee, coordinates its operations and defines its annual work plans in regard to supervision, monitoring and control of the Code of Conduct and the Criminal Compliance and Anti-corruption Systems implemented by Navantia.

Finally, Navantia provides a Whistleblowing Channel through which any allegedly illegal conduct, breaches of the Code of Conduct or any other irregular or suspicious events contrary to Navantia’s interests can be reported confidentially, although the whistleblowers must identify themselves. Investigations will be carried out under the principle of the presumption of innocence and other procedural guarantees. Confidentiality and anonymity of the whistleblower are also guaranteed. The people in charge of analysing and assessing any reports received through this channel are the Chief Compliance Officer and the Integrity and Criminal Compliance Manager.