VIARIUM INGENIERÍA, S.L., by decision of its governing body dated 30 September 2020, has implemented a Criminal Compliance Management System that meets the requirements of Article 31 bis of the Criminal Code and is kept up to date.
Within this framework, the Internal Reporting System is incorporated in accordance with Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption.
The governing body has incorporated into the Compliance System essential aspects of its own SDG objectives in the areas of governance, social responsibility and sustainability, as well as European standards on due diligence and sustainability, expressing the commitment of VIARIUM INGENIERÍA, S.L. (hereinafter, VIARIUM or the Organisation) to the principles of ethical and regulatory compliance.
VIARIUM's Criminal Compliance Management System comprises the Criminal Compliance Policy, the Compliance Manual, the Criminal Risk Report, and the policies and protocols that implement them.
Compliance oversight body
VIARIUM's Sole Director has appointed a collegiate Compliance Oversight Body, vested with independent powers of initiative and control and including the participation of an external specialist member. It supervises the operation and observance of the System and the effectiveness of the controls for preventing criminal offences.
Criminal compliance policy statement
The Criminal Compliance Policy, updated on 16 October 2026, sets out the general principles underpinning VIARIUM's internal rules, which apply to its members and their activities.
VIARIUM requires strict compliance with criminal law, is committed to the continuous improvement of the System, and adopts objectivity, integrity, confidentiality, transparency, neutrality, responsibility, accountability and honesty as its guiding principles.
VIARIUM maintains a zero-tolerance policy towards unlawful conduct or conduct that, even if it does not violate the law, is contrary to ethics, particularly fraud and corruption in any form.
General code of conduct or code of ethics
It sets out the basic guidelines and general principles governing the conduct of VIARIUM members in the performance of their duties and in their business and professional relationships, and constitutes the “cornerstone” of its compliance culture.
Internal reporting system (IRS)
Anyone may report, including anonymously, facts that may constitute criminal offences or infringements relating to VIARIUM through the internal channel Viarium Ingeniería, S.L. – Secure Channel. The IRS Manager is the Compliance Oversight Body, which guarantees the confidentiality of the identity of the reporting person, the persons concerned and the information; the prohibition of retaliation; acknowledgement of receipt within a maximum of seven days; and a response within the legally established time limits. Its operation is governed by the Internal Reporting System Policy.
Anti-corruption policy and conflicts or interest management procedure
It sets out VIARIUM's standards of conduct and measures to prevent corruption, including rules on gifts, invitations, donations and sponsorships, and the procedure for managing conflicts of interest, together with the Declaration of Absence of Conflicts of Interest (DACI) to be completed by its members.
General code of conduct for third parties
Garantiza que los colaboradores y proveedores de VIARIUM ejercen su actividad de acuerdo con su Código General de Conducta y con la legislación aplicable, evitando comportamientos contrarios a la ética.
Tax good practice policy
It establishes the principles and guidelines for conduct in tax, taxation and accounting matters that VIARIUM members must apply to ensure compliance with the applicable regulations.
Anti-money laundering policy
Establece los principios y pautas de actuación de VIARIUM It establishes VIARIUM's principles and guidelines for preventing the company from being used for money laundering or terrorist financing.
General policy on relations and contracting with clientes, collaborators and/or suppliers
Complementa el Código General de Conducta con las pautas que deben seguir los integrantes de VIARIUM It supplements the General Code of Conduct with the guidelines that VIARIUM members must follow when engaging and entering into contracts with clients, collaborators and suppliers, public administrations and entities, authorities and public officials.
Procedure to follow in the event of an inspection or administrativve supervision
It establishes how VIARIUM members must act in response to requests from inspection authorities, reflecting a commitment to cooperate with them while protecting the legitimate interests of VIARIUM and its members.
Criminal response protocol
It governs VIARIUM's response when it becomes aware, by any means, of the suspected commission of a criminal offence within the organisation, including through the Internal Reporting System.
Disciplinary system
VIARIUM has established and communicated to its members a disciplinary system to sanction conduct that breaches its procedures and internal regulations, in accordance with the applicable collective bargaining agreements, the Workers' Statute and the specific applicable regulations.
