SOCIAL INFORMATION
Compliance with legislation in each geography through contracts by composition of the supply chain, mainly by local suppliers. Ferrovial’s supply chain varies according to its different divisions, although it is marked by the Construction unit, which concentrates more than 92% of suppliers and orders. It is mainly made up of manufacturers, distributors, and subcontractors, and is characterized by a high number of suppliers, a significant degree of subcontracting, a high percentage of local suppliers, an extremely varied supplier type and the need to adapt to the requirements of each local market.
Continuous monitoring and follow-up of contractual compliance in projects.
Ferrovial does not directly consider the perspectives of value chain workers in its decision-making. However, it ensures that their working conditions and rights are upheld through mechanisms such as supplier assessments, due diligence processes, and compliance audits. Additionally, Ferrovial promotes ethical labor practices among suppliers and subcontractors, aligning with international labor standards to mitigate potential negative impacts on workers.
Ferrovial determines and evaluates real and potential impacts on value chain workers using a comprehensive framework. These impacts are assessed in the context of their relevance to the Company’s strategy and business model. For example, potential risks such as reputational damage due to non- compliance with human rights are directly tied to the Company’s reliance on supply chain partners adhering to fair labor practices. Additionally, positive contributions, such as generating wealth and employment in the communities where Ferrovial operates through its local purchasing policy, showcase how operational strategies are interlinked with broader societal outcomes. These incidents also support Ferrovial’s adaptation of its strategy to align with stakeholder expectations and regulatory demands, thereby reinforcing its commitment to sustainable and responsible business practices.
In its Construction division, Ferrovial employs advanced management tools, such as Insite, Supplier360, and BuildAdvisor, to parameterize controls related to the financial, administrative, and production areas of projects. These tools are continuously adapted in response to updates in policies and procedures, regulatory changes, or as part of the Company’s commitment to process improvement. Ferrovial’s requirements regarding workers in its value chain and supplier commitments to these areas are embedded in contractual clauses. This ensures a formal framework for upholding labor standards and managing risks within its supply chain.
Ferrovial evaluates risks and opportunities arising from worker-related impacts in its value chain. Negative impacts, such as systemic risks of human rights violations or exploitative labor practices, are addressed through measures like supplier engagement and adherence to international standards. Effective risk management plays a central role in this approach, including the evaluation of suppliers and the implementation of appropriate measures to ensure the quality and safety of supplies. Risks, such as disruptions in the supply chain, are mitigated through continuous monitoring of critical suppliers and the identification of viable alternatives to ensure supply continuity and minimize negative effects. On the other hand, opportunities such as fostering mutual trust with suppliers through improved operability and transparency are leveraged to strengthen long-term relationships and operational efficiency. These efforts emphasize the integration of value chain resilience into the Company’s strategic and operational frameworks.
The Company ensures that its disclosure encompasses all workers within its value chain who might be significantly affected. This includes not only those directly employed by Ferrovial but also workers in the supply chain (e.g., those involved in raw material extraction or production processes), downstream operations (e.g., logistics and distribution providers), and in joint ventures or special-purpose entities.
Ferrovial expects the same level of respect for human rights, health and safety protection, promotion of employee welfare and equality and diversity from its contractors. For this reason, in accordance with applicable legislation and its supplier and procurement policies, Ferrovial requires responsible behavior from its value chain partners through specific actions such as the mandatory signing of contracts that include human rights and labor standards clauses, periodic audits to verify compliance with these commitments, and monitoring processes to ensure adherence to ethical and sustainability criteria. Additionally, suppliers may be required to participate in training programs and improvement plans if any non-compliance is detected .Therefore, it was not necessary to establish a definition of “workers in the value chain” and no particularly vulnerable groups were identified that require differentiated treatment or for which the policies applicable to other workers do not adequately guarantee their rights.
Ferrovial also assesses geographic and sector-specific risks, including potential incidents of child labor or forced labor in regions or sectors where such risks are known to be prevalent. To mitigate these risks, Ferrovial implements due diligence processes and collaborates with suppliers and partners to ensure compliance with human rights standards. The Company monitors the economic, social, and environmental impacts associated with its supply chain activities, ensuring that potential risks are proactively managed while fostering opportunities for sustainable development.
However, it did identify material risks and opportunities related to its supply chain workers.
Among the risks, key concerns include the potential impact of construction and infrastructure development on the human rights of communities and clients, such as population displacement; reputational damage and loss of trust in case of human rights non-compliance; and poor labor conditions within the supply chain.
On the other hand, opportunities include improving working conditions in the supply chain by fostering quality work environments, differentiating within the sector through adherence to high human rights standards, gaining access to clients with strict human rights requirements, and strengthening transparency and trust with suppliers, enhancing operational efficiency and business sustainability.
Despite the fact, Ferrovial does not operate in any geographical area nor source raw materials that present a significant risk of child labor, forced labor, or compulsory labor within its value chain. The Company remains firmly committed to respecting human rights and ethical labor practices, ensuring that its operations and supplier relationships comply with the highest international labor standards. To further mitigate these risks, Ferrovial implements robust due diligence processes, including supplier audits, contractual obligations aligned with human rights principles, and grievance mechanisms to promptly address any concerns. These measures help ensure that the Company does not contribute to or cause harm in the countries where it operates.
Policy | Procurements and Value Chain Policy |
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Description | Ferrovial integrates environmental, social, and corporate governance (ESG) principles into its supply chain, promoting efficiency, quality, sustainability, transparency, respect for human rights, non-discrimination, and equal opportunities. The selection, negotiation, and contracting of suppliers and contractors are objective and rigorous, supported by continuous quality control evaluations. Ferrovial prioritizes long-term relationships with socially responsible organizations and partners. |
Target | The policy aims to promote a responsible, sustainable, and transparent supply chain while fostering innovation and improving ESG-related performance among suppliers and contractors. |
Associated material impacts, risks and opportunities |
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Follow-up and remediation process |
Evaluations are conducted regularly, including ESG criteria. Incidents are recorded and may result in supplier exclusion or remedial action plans. The Ethics Channel is available for reporting misconduct, ensuring transparency and accountability. It is open to everyone, including external individuals. We make its existence known through third-party contracts, requiring them to acknowledge and sign that they are aware of the channel. |
Scope of the policy | |
Stakeholders impacted | Suppliers, contractors, and other partners within the value chain. |
Geographic areas | Global |
Value chain application | Applies to upstream suppliers, contractors, and downstream partners, with emphasis on fostering ESG commitments within the communities where Ferrovial operates. |
Exclusions from application | There are currently no exclusions; the policy applies to all areas of activity, geographies, and stakeholders |
Policy approval flow | |
Chief Executive Officer | Board of Directors – responsible for approving the policy. |
Other issues to report (if applicable) | |
Consistency with third-party instruments or standards | The policy aligns with Ferrovial’s Code of Ethics and Business Conduct, Corporate Responsibility and Human Rights Policies, and international frameworks such as the United Nations Global Compact and the 2030 Agenda for Sustainable Development. |
Attention to stakeholders | The policy incorporates stakeholders’ interests, particularly focusing on sustainable procurement practices and ESG compliance. |
How it is made available | This policy is available on the Ferrovial website (ferrovial.com) and on its intranet. |
Significant policy changes | N/A – no changes were made |
Policy | Anti-Harassment and Anti-Discrimination Policy |
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Description | Ferrovial is committed to developing a working environment which is free from all types of harassment, discrimination, and bullying. We require all our people to promote the highest standard of ethics as well as our values of respect, collaboration, and integrity. This policy reinforces the principles outlined in Ferrovial´s Code of Ethics and Business Conduct (“Code of Ethics”) and our Diversity and Inclusion Policy. |
Target | The goals of this policy are:
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Associated material impacts, risks and opportunities |
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Follow-up and remediation process | Ferrovial ensures compliance with the policy by establishing clear reporting channels for employees, such as the Ethics Channel, and implementing internal investigation protocols to promptly address reported incidents. The Company also promotes awareness and prevention of harassment and discrimination through comprehensive training programs. Ferrovial also conducts regular monitoring and updates its policies to align with best practices and legal requirements, ensuring a robust and proactive approach to compliance. |
Scope of the policy | |
Stakeholders impacted | All Ferrovial employees, suppliers, and customers with access to company systems or data. |
Geographic areas | Global |
Value chain application | The policy extends across the entire value chain, including upstream suppliers and downstream customers, ensuring secure practices in all business interactions. |
Exclusions from application | There are currently no exclusions; the policy applies to all areas of activity, geographies, and stakeholders globally. |
Policy approval flow | |
Chief Executive Officer | Chief Executive Officer of Ferrovial – responsible for approving the policy. Human Resources Department – responsible for implementation. |
Other issues to report (if applicable) | |
Consistency with third-party instruments or standards | The policy aligns with:
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Attention to stakeholders | The policy reflects Ferrovial’s commitment to employee well-being and addresses feedback from key stakeholders to ensure fair treatment and an inclusive environment. |
How it is made available | This policy is available on the Ferrovial website (ferrovial.com) and on its intranet. |
Significant policy changes | N/A – no changes were made |
Ferrovial upholds the respect for human rights throughout its value chain by implementing a comprehensive set of policies and procedures.
Through its Code of Ethics and Business Conduct, the Company emphasizes conducting all business and professional activities with integrity, honesty, and a strong commitment to human rights. This framework applies to all employees and is grounded in the principles of the Universal Declaration of Human Rights.
Ferrovial’s Human Rights Policy highlights its cooperation with government agencies, international organizations, and civil society to promote and uphold human rights. The Company actively identifies, prevents, and mitigates potential negative impacts on human rights from its operations. It fosters a respectful and dignified work environment by providing training and raising awareness about human rights across its workforce.
While Ferrovial introduced a specific human rights policy in 2014, it renewed this policy in 2022 to align with international standards such as the United Nations Global Compact, the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, and International Labor Organization regulations. The updated policy also incorporates emerging trends, bringing the Company’s human rights approach closer to its operational realities, further strengthening its commitment to protecting and respecting human rights. With respect to severe human rights incidents there were no incidents of this type along our value chain.
Ferrovial’s commitment to diversity, inclusion, and labor practices is reinforced through additional policies:
To ensure ethical partnerships, Ferrovial follows a Due Diligence Procedure that establishes a structured process for assessing collaborations, partnerships, and procurement activities. The procedure integrates the Supplier Code of Ethics and enforces compliance with the Anti-Corruption Policy to ensure ethical and transparent business relationships.
The Supplier Code of Ethics, updated in 2024, sets clear ethical principles for Ferrovial’s suppliers. This code underlines the importance of due diligence in supplier integrity and mandates the rejection of corruption or bribery. It applies to all suppliers, regardless of location or sector, requiring them to adopt and enforce these principles within their supply chains. Ferrovial reserves the right to audit suppliers and terminate agreements with those who fail to comply.
Ferrovial manages its supply chain through the Global Purchasing Policy and Purchasing Procedure, which ensure efficient, ethical, and sustainable procurement practices. These procedures include global guidelines adapted locally, ensuring that products and services meet contractual and company standards. Supplier performance is continuously monitored through the Supplier Quality Evaluation and Follow-up Procedure, further promoting legal compliance and human rights oversight in operations and business relationships.
This monitoring includes processes and mechanisms to ensure compliance with international frameworks such as the United Nations Guiding Principles on Business and Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. Ferrovial evaluates suppliers’ adherence to these principles through due diligence processes, which include scheduled assessments, audits, and the review of suppliers’ policies and practices to ensure alignment with ethical, social, and environmental standards. Non-compliance may lead to corrective actions or, if necessary, the termination of the commercial relationship.
On sustainability, Ferrovial has adopted several strategic policies to address material sustainability issues:
Ferrovial’s 2030 Sustainability Strategy is built on three pillars: environment, community, and governance. The 2024–2030 strategy strengthens the Company’s commitment to society while addressing stakeholder expectations and ESG requirements. This approach ensures sustainable project management and maintains Ferrovial’s leadership in the construction sector.
Ferrovial addresses issues such as human trafficking, forced, compulsory, and child labor in its Human Rights Policy. This policy establishes the company’s commitment to respecting human rights across its operations and value chain, including the prevention of these practices. Additionally, Ferrovial has a Supplier Code of Conduct, which reinforces these commitments and sets specific requirements for suppliers to comply with labor and human rights standards.
The Supplier Code of Conduct requires business partners to adhere to international labor standards and explicitly prohibits child labor, forced labor, and any form of human trafficking. These principles are included in supplier contractual clauses, and compliance with these policies is monitored through management tools such as Supplier 360, supplier audits and/or assessments.
Policy | Sustainability Policy |
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Description | Ferrovial develops and operates innovative, efficient, and sustainable infrastructures, creating value for its stakeholders (employees, customers, users of its infrastructures, society, and shareholders). Inspired by the United Nations Sustainable Development Goals (SDGs), Ferrovial aims to consolidate its position as a contributor to a more sustainable, innovative, inclusive, and low-carbon economy. Sustainability is seen as a key factor for the business model, contributing to new opportunities and facilitating future growth. |
Target | The Sustainability Policy establishes the principles and values that guide Ferrovial’s commitment to sustainability across all its entities, regardless of their business area, geographic location, or activities. |
Associated material impacts, risks and opportunities | Ferrovial focuses on preventing pollution and proactively managing environmental risks to minimize negative impacts. The Company also aims to achieve a neutral or positive impact on natural capital and biodiversity. Ferrovial contributes to global climate action by setting ambitious emission reduction targets aligned with the Science Based Targets Initiative (SBTi) and managing climate-related risks and opportunities. The Company adds value to the communities where it operates, supports local development, and collaborates with social organizations to benefit vulnerable populations. |
Follow-up and remediation process | Ferrovial commits to the highest standards of integrity and transparency, practicing zero tolerance for legal violations and corruption. The Company periodically verifies the effectiveness of its control systems to prevent fraud and corruption risks. Ferrovial ensures a safe working environment for all employees and promotes human rights protection in its business activities and collaborations with third parties. |
Scope of the policy | |
Stakeholders impacted | This policy applies to all entities within the Ferrovial Group, regardless of their business area, geographic location, or activities. |
Geographic areas | Global |
Value chain application | Ferrovial fosters mutual benefit in its relationships with customers, suppliers, shareholders, employees, and other external operator involved in the 2030 Sustainable Development Agenda or related to Ferrovial’s activities and initiatives. |
Exclusions from application | None specified |
Policy approval flow | |
Chief Executive Officer | Board of Directors – responsible for approving the policy. |
Other issues to report (if applicable) | |
Consistency with third-party instruments or standards | This policy is inspired by the United Nations Sustainable Development Goals (SDGs) and aligned with Ferrovial’s existing policies on sustainability, human rights, corporate responsibility, and the principles of the United Nations Global Compact. |
Attention to stakeholders | Ferrovial commits to disseminating relevant information to markets, shareholders, and other stakeholders transparently, quickly, completely, and truthfully, following principles of equal treatment and non- discrimination. |
How it is made available | This policy is available on the Ferrovial website (ferrovial.com) and on its intranet. |
Significant policy changes | N/A – no changes were made |
DISCLOSURE REQUIREMENT S2 – 2: PROCESSES FOR ENGAGING WITH VALUE CHAIN WORKERS ABOUT IMPACTS
Ferrovial has an Ethics Channel that allows workers in its value chain to express concerns and report negative incidents confidentially. This channel is designed to facilitate communication about any possible irregularity, non-compliance or behavior contrary to ethics, legality and the Company’s internal rules.
In addition to the possibility of reporting negative situations, Ferrovial is committed to investigating and responding appropriately to concerns raised through the Ethics Channel. This system not only acts as a means to report problems, but also plays a crucial role in mitigating and remediating negative impacts on workers by enabling the Company to proactively identify and address situations that may require intervention. Ferrovial strives to ensure that all concerns are treated with the seriousness and confidentiality they deserve, thus contributing to a safer and fairer working environment for all employees in its value chain.
The degree of criticality of all suppliers is analyzed, where critical suppliers are defined as those whose purchasing volume is significant from an economic viewpoint, or those whose supplies or services could have a negative impact on business continuity in the event of an incident, either because they manufacture critical materials or equipment, or because they are difficult to replace. Based on these criteria, at the end of 2024 there were 210 critical suppliers identified in the Construction division, of which 208 were Tier-1 and 2 Tier-2. Of these suppliers, 138 were evaluated, of which 17 were detected with potential negative impacts. During 2024, a total of 6,280 suppliers were evaluated (compared to 7,562 in 2023). Of these, less than 1% were rejected in 2024 (same figure in 2023). In terms of supplier turnover, a total of 31.7% corresponded to critical suppliers , while 97.8% came from local suppliers.
The BuildAdvisor platform, deployed by the Construction division in Spain, facilitates collaboration with the supply chain by streamlining the search for and evaluation of suppliers, and by offering them opportunities for improvement and suitable projects. This achieves greater efficiency and competitiveness in projects and advances the ESG objectives of responsibility and sustainability.
Ferrovial, as part of its commitment to integrate sustainability and human rights throughout its value chain, invited suppliers from different geographies to participate in the “Training Program: Sustainable Suppliers,” a program developed by the UN Global Compact Spain, ICEX Spain Export and Investment and ICO Foundation.
This online training program enables SME suppliers to prepare themselves to meet the sustainability standards of large companies, while acquiring general knowledge about corporate sustainability, how to integrate it into their strategy and how to measure the results achieved.
Ferrovial does not engage in direct communication with workers in its value chain. However, it ensures that labor standards and commitments to human rights are reflected in contractual clauses with its suppliers. The Company uses management tools such as Supplier360, which enable monitoring and evaluation of supplier performance, including aspects related to the economic, social, and environmental impacts of their activities.
Through these audits and/or assessments Ferrovial monitors risks in its supply chain and promotes compliance with labor standards. While there is no evidence of direct consultations with value chain workers, these tools and processes ensure that the labor conditions of suppliers are indirectly considered as part of risk and opportunity management.
Ferrovial did not publicly disclose any global framework agreements or agreements with global trade union federations concerning the respect for human rights of value chain workers, including their right to collective bargaining. Therefore, there is no evidence that such agreements provide the Company with direct insights into these workers’ perspectives.
Regarding the evaluation of collaboration with value chain workers, Ferrovial uses tools such as Supplier 360 and supplier audit and/or assessments processes to monitor labor conditions within its supply chain. While these mechanisms do not involve direct collaboration with workers, they help monitor labor-related risks and promote continuous improvement in supplier practices. The effectiveness of these processes is assessed through supplier performance indicators and their compliance with contractual commitments established by Ferrovial.
Ferrovial did not disclose specific measures to directly understand the perspectives of workers particularly vulnerable to incidents or marginalized, such as female workers, migrant workers, or persons with disabilities, within its value chain. However, through tools like Supplier 360 and supplier audits and/or assessments, theCompany monitors labor conditions in its supply chain, including aspects related to diversity and human rights.
While these processes do not involve direct consultations with vulnerable workers, they allow for the evaluation of supplier performance in meeting labor and social standards that protect vulnerable groups. Supplier contractual clauses also include commitments related to human rights, indirectly addressing these risks.
S2 – 3: PROCESSES TO REMEDIATE NEGATIVE IMPACTS AND CHANNELS FOR VALUE CHAIN WORKERS TO RAISE CONCERNS.
The Company makes the Ethics Channel available to its employees and stakeholders (see more information in ESRS G1-1), a confidential and—if the informant wishes—anonymous system (pursuant to applicable legislation), to facilitate the reporting of any possible irregularity, non-compliance or behavior contrary to ethics, legality and Ferrovial’s internal rules, particularly including possible cases of fraud or corruption, anti-competitive practices, human rights violations, financial and tax matters or damage to the environment. The Compliance and Risk Department is responsible for managing the Ethics Channel and receives support from Internal Audit for the analysis of high-priority communications, as well as from other Company departments depending on the nature of the matter. The Compliance and Risk Manager reports quarterly to the Audit and Control Committee, and annually to the Board of Directors, on the reports received and the actions taken in relation to them.
Ferrovial also has Supplier360, an IT tool that monitors suppliers using advanced data analytics techniques, language processing and internet searches. This makes it possible to detect potential risks, whether financial, environmental, legal, labor, human rights or reputational. The platform provides additional information to that already available in the supplier databases, both for the selection, contracting and follow-up phases. In 2024, 1,378 suppliers of Ferrovial Construction were monitored, representing more than 60% of supplier turnover in Spain, the U.S., and U.K.. A total of 43,500 pieces of information were collected through this tool. Likewise, the sources of information were expanded, incorporating mainly data relating to ESG compliance and behavior. On the other hand, the information obtained through Supplier360 was integrated into the corporate purchasing tool, which allowed greater visibility of the information throughout the Company.
In the event that a negative impact is identified, Ferrovial follows a structured remediation process to address and resolve the issue. Each case reported through the Ethics Channel or detected via Supplier360 is analyzed to determine the appropriate corrective actions, which may include contractual penalties, engagement with affected stakeholders, or collaboration with external authorities if required. The effectiveness of these remedies is monitored through follow-up actions to ensure that the issue is fully resolved and that similar risks are mitigated in the future. Additionally, the company tracks the usage of the Ethics Channel and other reporting mechanisms, analyzing trends in received communications to continuously improve its response processes. Reports on identified issues and their resolutions are periodically reviewed by the Compliance and Risk Department, ensuring transparency and accountability in the remediation process. In the contract with suppliers, it is necessary to sign that they are aware of the existence of this channel, and that all their employees could use it to report any type of incident. For more information refer to ESRS G1-1.
Although there is no specific policy solely dedicated to protection against retaliation for individuals using these channels to raise concerns, the Ethics Channel ensures that no related issues arise. Protection against retaliation is explicitly addressed in the Code of Ethics and Business Conduct. Additionally, the Compliance Department periodically reviews closed communications to detect and prevent potential cases of retaliation. In 2024, new training courses on “Practical Information for Avoiding Retaliation in the Workplace” were launched for managers and employees involved in key decision-making processes, such as recruitment, promotions, mobility, layoffs, and disciplinary measures.
S2 – 4: TAKING ACTION ON MATERIAL IMPACTS ON VALUE CHAIN WORKERS, AND APPROACHES TO MANAGING MATERIAL RISKS AND PURSUING MATERIAL OPPORTUNITIES RELATED TO VALUE CHAIN WORKERS AND EFFECTIVENESS OF THOSE ACTIONS
ESG issues are also considered in the analysis of suppliers. In this sense, suppliers are classified as high-risk suppliers if they supply products considered high-risk or belong to sectors characterized as high-risk, and/or manufacture the products supplied in countries considered at risk.
Ferrovial Construction Supplier Quality Assessment and Monitoring Procedure, enforced in all our projects around the world, establishes the method for the evaluation and monitoring of supplier performance, which also considers ESG criteria. The Construction division has a computer application for the evaluation and monitoring of each supplier based on the evaluations conducted at each construction site or work center. The evaluations make it possible to qualify suppliers on an ongoing basis, and the result can lead to a warning for the supplier, the establishment of an improvement action plan, or even disqualification from working with Ferrovial, depending on the severity of the situation. When an incident is reported by one of the projects, we seize the opportunity to collaborate and evaluate. Sometimes, if necessary, the suppliers are informed of the situation and required to address the issue through a formal report. We offer our support through courses or improvement plans. If a supplier receives three negative assessments within a year, we propose their rejection and, once they are rejected, they cannot work with the Company again. Throughout our supply chain, we offer the “Training Program: Sustainable Suppliers” for medium and small-sized companies. This free and exclusive program is developed by UN Global Compact Spain and U.K. networks, ICEX Spain Export and Investments, and the ICO Foundation. It is an excellent opportunity for our suppliers to strengthen their competitiveness and align themselves with ESG best practices. Also, the Ethics Channel is available to all stakeholders on the Ferrovial website, guaranteeing transparency in relations and allowing the reporting of any conduct that is not in line with the Company’s standards. Ferrovial has a Supplier Code of Ethics, integrated into the Supplier Ethical Integrity Due Diligence Procedure, which suppliers are aware of and accept before entering into contractual relations with the Company. It establishes the basic principles that should guide their behavior in their business relations with Ferrovial. In addition, the model orders and contracts include clauses that address environmental, social and labor, health and safety, compliance with the principles of the Global Compact, as well as ethics and anti-corruption issues.
Policy | Supplier Code of Ethics Policy |
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Description | Ferrovial’s values, reflected in its Code of Ethics and Business Conduct, translate into environmental, social, and governance commitments. Ferrovial promotes responsible behavior in its supply chain, in line with the highest standards of ethics and integrity, legality, transparency, safety and health, environmental responsibility, and respect for human rights. Ferrovial drivespromotes that its suppliers to perform their’ activities are carried out responsibly and in compliance with applicable national and international laws. |
Target | The objective of this Supplier Code of Ethics is to establish the ethical principles that should govern the actions of Ferrovial’s suppliers, thus promoting an ethical integrity due diligence system for suppliers and preventing behaviors incompatible with these principles. Ferrovial promotes and expects these principles to be shared by its suppliers, taken on by them, and passed on to their own suppliers and subcontractors in their commercial relationships with Ferrovial. |
Associated material impacts, risks and opportunities | Ferrovial reserves the right to conduct verifications on the integrity of its suppliers, who must cooperate with the due diligence process. Ferrovial may terminate the contractual relationship with suppliers who breach any of the principles established in this Supplier Code of Ethics. Ferrovial will monitor and follow up on the performance of its suppliers, conducting evaluations of compliance with the requirements established in the orders/contracts signed with them when deemed necessary. |
Follow-up and remediation process | Ferrovial will adopt practices and controls to promote the implementation, monitoring, and verification of compliance with this Code. Ferrovial will also establish actions to ensure that the principles underlying this Code are known, understood, and committed to by the Group’s workforce and third parties with whom it does business. Ferrovial has an Ethics Channel through which Group employees, executives, and other stakeholders can report irregularities, non-compliance, or unethical or illegal behavior. The Ethics Channel can be accessed from the Ferrovial website or from the toll-free telephone numbers and postal address provided on the website. |
Scope of the policy | |
Stakeholders impacted | This Supplier Code of Ethics applies to all Ferrovial suppliers, regardless of their business sector, geographic location, or activity. |
Geographic areas | Global |
Value chain application | Ferrovial seeks to extend its commitment to responsible behavior throughout its supply chain, ensuring that suppliers and subcontractors adhere to the principles outlined in this Code. |
Exclusions from application | None specified. |
Policy approval flow | |
Chief Executive Officer | Board of Directors – responsible for approving the policy. |
Other issues to report (if applicable) | |
Consistency with third-party instruments or standards | This Code is aligned with Ferrovial’s Code of Ethics and Business Conduct, and with Ferrovial’s Human Rights, Corporate Responsibility, and Sustainability Policies, as well as with the principles of the United Nations Global Compact and the 2030 Agenda for Sustainable Development. |
Attention to stakeholders | Ferrovial ensures the confidentiality and, if desired, the anonymity (to the extent possible and in accordance with applicable law) of any informant acting in good faith. |
How it is made available | This Code is available on the Ferrovial website (ferrovial.com) and on its intranet. |
Significant policy changes | N/A – no changes were made |
Ferrovial implemented actions to manage its impacts, risks, and material opportunities related to the workers in its value chain. Some key actions were:
These actions cover both Ferrovial’s internal activities and its upstream value chain, including suppliers in various geographies where the Company operates. The scope of these actions extends to all Ferrovial divisions and projects globally.
Regarding time horizons, supplier evaluation and monitoring, as well as the use of the Ethics Channel, are continuous processes. The Sustainable Suppliers Training Program is offered periodically, and the Supplier Code of Ethics applies from the start of the contractual relationship.
In the event of incidents reported by projects, Ferrovial collaborates with suppliers to address and resolve situations, offering support through courses or improvement plans. If a supplier receives three negative evaluations in a year, their rejection is proposed, meaning they can no longer work with the Company.
Ferrovial continuously monitors supplier performance and the effectiveness of the actions implemented. Evaluations allow suppliers to be continuously rated, and the results may lead to warnings, the establishment of improvement plans, or even the disqualification of the supplier, depending on the severity of the situation.
Ferrovial manages real material incidents in its value chain through a structured and clear procedure, including:
Ferrovial implements a comprehensive approach to ensure positive impacts, mitigate risks, and foster opportunities within its value chain through strategic initiatives, responsible policies, and innovative tools. As part of our commitment to becoming a benchmark in the sector by promoting best practices in human rights throughout the value chain and strengthening mutual trust to enhance operability and transparency with our suppliers, we offer the “Training Program: Sustainable Suppliers” for small and medium-sized enterprises. This free and exclusive program, developed in collaboration with UN Global Compact Spain and U.K. networks, ICEX Spain Export and Investments, and the ICO Foundation, equips our suppliers with the tools to improve their competitiveness while aligning with ESG best practices. Through this initiative, we foster a responsible and resilient supply chain that upholds ethical and sustainable business practices. Additionally, Ferrovial ensures that labor conditions are aligned with its Supplier Code of Ethics, which establishes basic principles on human rights and labor practices, and ensures that orders and contracts include specific provisions addressing environmental, social, labor, health, and safety issues, as well as principles of ethics and anti-corruption.
To ensure the effectiveness of its actions, Ferrovial follows structured monitoring practices. Through the Construction Supplier Quality Assessment and Monitoring Procedure, suppliers are continuously assessed based on their performance, enabling informed decisions such as warnings, improvement plans, or disqualification in severe cases. Furthermore, Ferrovial employs tools like Supplier360 to monitor supplier performance in real-time and regularly reviews the results of audits and training programs to identify areas for improvement and adjust policies and procedures accordingly. The Ethics Channel provides a confidential platform for stakeholders to report issues, fostering trust and ensuring proper follow-up.
Ferrovial also integrates ESG principles into its Global Purchasing Policy and the Ethical Integrity Due Diligence Procedure for suppliers. Suppliers are classified as high-risk if they operate in sectors or countries with greater vulnerability as defined by ESG criteria, and continuous monitoring through the Supplier Quality Assessment Procedure ensures adherence to these standards, including human and labor rights. Ferrovial takes a proactive approach by including contractual clauses prohibiting practices such as child labor, forced labor, and human trafficking, which are monitored through regular audits and/or assessments. In cases of non-compliance, the Company collaborates with suppliers to develop improvement plans or provide specific training. Ferrovial has not identified or received any notifications of severe human rights issues related to the upstream or downstream phases of its value chain. The Company maintains a robust due diligence framework aligned with international standards, including the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, ensuring continuous monitoring and risk mitigation across its operations and supply chain.
Ferrovial is committed to innovation and sustainability within its supply chain through the implementation of advanced projects and technologies. For example, it developed the Low-Carbon Concrete Project, designed to create sustainable mixes with lower CO₂ emissions, with progressive targets over the next five years. Ferrovial also promotes the procurement of sustainable products through the Green Purchasing Catalog, which includes Environmental Product Declarations to assess their environmental impact. Consistent with its environmental goals, Ferrovial set a target of achieving 100% renewable electricity consumption by 2025 and reducing fleet emissions by 33% by 2030 through among other measures the integration of hybrid and electric vehicles.
Ferrovial is committed to ensuring that its own business practices do not cause or contribute to material negative impacts on value chain workers. To achieve this, the Company has established robust policies and procedures that regulate supplier engagement, procurement, sales, and data management, aligning with international standards such as the United Nations Guiding Principles on Business and Human Rights.
One of the key measures implemented to prevent negative impacts is the requirement for suppliers to acknowledge and comply with Ferrovial’s ethical standards. As part of the contractual agreement, suppliers must confirm that they are aware of and have access to Ferrovial’s Ethics Channel, which provides a confidential platform to report any misconduct or non-compliance with labor and human rights standards. This ensures that any potential issues can be addressed in a timely and effective manner.
Furthermore, Ferrovial established a structured supplier monitoring and evaluation system to mitigate risks within its value chain. Suppliers with persistent non-compliance issues are required to implement corrective action plans, and in cases where non-compliance continues, they are disqualified from working with the Company. This approach ensures that all suppliers adhere to the Company’s sustainability and ethical commitments, minimizing the risk of adverse impacts on workers.
Ferrovial has not identified or received any notifications of severe human rights issues related to the upstream or downstream phases of its value chain. The Company maintains a robust due diligence framework aligned with international standards, including the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, ensuring continuous monitoring and risk mitigation across its operations and supply chain.
S2 – 5: TARGETS RELATED TO MANAGING MATERIAL NEGATIVE IMPACTS, ADVANCING POSITIVE IMPACTS, AND MANAGING MATERIAL RISKS AND OPPORTUNITIES.
Ferrovial continuously evaluates the effectiveness of its sustainability goals and initiatives through internal assessments and stakeholder engagement. While the company does not have a formalized process for directly collaborating with value chain workers or their representatives to determine lessons learned or areas for improvement, it integrates best practices and insights from industry benchmarks, regulatory developments, and ongoing dialogue with key stakeholders. This approach ensures continuous enhancement of its strategies while maintaining a responsible and sustainable business model.
Ferrovial’s Construction division established a measurable sustainability indicator to conduct evaluations on suppliers representing 60% of the total purchasing volume by 2025. This goal aligns with the sustainability strategy of Ferrovial Construction, demonstrating its commitment to sustainable procurement practices.
Furthermore, Ferrovial’s knowledge of its global supply chain, as well as the tools available to the company, guarantees a more efficient management.
As of now, no significant updates or trends in performance toward this target have been disclosed. However, Ferrovial remains committed to monitoring and achieving this goal within the specified timeframe. While Ferrovial has policies in place for managing its value chain, it has not yet defined specific goals or targets regarding the involvement of credible spokespersons for workers’ representatives. This is an area that could be further strengthened in future sustainability and social dialogue strategies.
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