Code of Ethiscs and Legal ComplianceDirect Channel

Indra has a Compliance Model consisting of the Criminal Risk Prevention Model and the Antitrust Risk Prevention Model focused on promote a culture of compliance and to prevent any activity that violates the legality in the field of our business. The Audit and Compliance Committee of the Board of Directors is the maximum body of control of the Model and the Compliance Unit is the responsible to implement and execute the Model.

Both, the Senior Management and the Board of Directors have the firm commitment to establish a solid culture of compliance and integrity. The mentioned above culture is based on “do the right thing” and it is applicable to all the Professionals and Partners of Indra (representatives, suppliers and other third parts that provide services to Indra or that, at any rate, act on his name) who are responsible to comply with legislation in force and apply the principles of Indra.

To accomplish with the mentioned commitment and to keep a control environment and continuous improvement, Indra has a Code of Ethics and Legal Compliance, with a Whistleblower Channel (Direct Channel), both are the main controls of our Compliance Model.

Code of Ethics and Legal Compliance

The Code of Ethics and Legal Compliance of Indra is a reference impassible framework, which establishes the following corporate principles and standards of conduct:

Corporate Principles:

  • Integrity: o Integrity: means acting in good faith and establishing professional relationships based on transparency and ethics
  • Professionalism: means maintaining a proactive attitude with respect to ensuring the excellence of our efforts
  • Respect: means recognizing the value of people and their work, and of the social and natural environment in which we operate
     

Standards of Conduct about:

  • Compliance with legislation
  • Rejection of corruption and bribery. In this sense, Indra has specific procedures to regulate the hiring of Commercial Consultors and Strategic Advisors as well as the request of donations, sponsorships and corporate courtesy.
  • Conflicts of interest
  • Information security
  • Equality and Non-Discrimination
  • Foreign trade of defense materials and dual-use goods
  • Subsidies and public aids
  • Sustainability
  • Best tax practices
  • Economic-Financial information management
  • Protection of Antitrust
  • Money laundering and terrorist financing
  • Occupational health and safety
  • Relations with governments and authorities

The Code of Ethics also reflects recognized Human Rights, within the framework of the United Nations Guiding Principles on Business and Human Rights, the International Bill of Human Rights and the principles related to rights established in the International Labor Organization’s Declaration.

Additionality, the Code of Ethics, the Criminal Risk Prevention Model, the Antitrust Risk Prevention Model and the procedures and politics of Indra establishes action Guidelines and controls, which are executed periodically in the different areas of the company to minimise the potential risks of unlawful conducts perpetrated by Professionals and Partners of Indra.

Direct Channel

The Direct Channel (https://canaldirecto.indracompany.com/) also available on the Company's internal and external website and including the possibility of anonymous communications) is the confidential channel available to all Indra Professionals and Partners, as well as other third parties with a legitimate interest, to communicate any doubt about the interpretation or application of Indra's Code of Ethics and its implementing regulations and through which they must report any illegal behavior detected in relation to the Code of Ethics and its implementing regulations as well as other infringements or irregularity acts under the terms set out in Annex 4 of the aforementioned Code.

In accordance with Law 2/2023 regulating the protection of persons who report violations of the law and the fight against corruption, Indra has designated a Chief Compliance Officer as the person responsible of the internal information system, who carries out its functions independently and autonomously. Additionally, its governance body together the Senior Management are involved actively in the supervision of the Compliance Model.To that effect, and as mentioned above, the Audit and Compliance Committee is in charge of supervising the functioning, effectiveness and compliance of the mentioned Model.

Indra has defined an organisation chart and organisational model that establishes the functions, responsibilities and reporting lines of each of the organisation's departments in all the businesses and countries in which it operates. This organisational chart is available internally to all professionals on a global scale through the corporate Intranet. This, together with the Code of Ethics and Legal Compliance, allows us to establish a regulatory and behavioural framework throughout the organisation.