Transparency and the Fight against Corruption

In 2007, the decision was made to officially include within Abengoa’s Professional Code of Conduct an express declaration on the company’s adherence to the United Nations Convention against Corruption, as approved by the UN General Assembly in 2003.

This text is intended to foster and bolster measures to prevent and combat corruption more effectively, while encouraging, facilitating and supporting international cooperation and technical assistance in preventing and fighting against corruption, including the recovery of assets, and promoting integrity, the obligation to render accounts and proper management of public affairs and assets.

Over the course of 2010, the Internal Audit Department issued more than six hundred audit reports, which included, among other aspects, the results of the audits and analyses of the risks associated with corruption in those companies classified as material. The company also conducted fifty legal audits to complement the audit reports, the aim being to unearth situations that could be classified as corrupt.
 

In addition to the foregoing and as a practical step, Abengoa has introduced a binding contractual clause into its collaboration, agency and intermediation agreements, requiring the collaborator to undertake in writing to not engage in any illegal practices that could be considered corrupt, abusive or biased.
 

In 2010, the company staged more than 135 training courses in its Common Management Systems, which taught participants specific procedures for managing risks associated with corruption and for implementing anti-corruption policies within the companies.
 

The company has a computer application based on these Common Management Systems that can be consulted by all users at any time to broaden their awareness of the company’s anti-corruption policies and procedures.

Abengoa’s information channels show no record in 2010 of any corruption-related incidents within the company.
There were no significant sanctions imposed in 2010 arising from non-compliance with laws or regulations.