2019 Corporate Social Responsibility Report Table of Contents

2019 CORPORATE SOCIAL RESPONSIBILITY REPORT TABLE OF CONTENTS

ABOUT COMSA ECONOMIC ENVIRONMENTAL SOCIAL ABOUT THE CORPORACIÓN SPHERE SPHERE SPHERE REPORT

MAIN MILESTONES 2019 BUSINESS MODEL ENVIRONMENTAL COMSA CORPORACIÓN ABOUT THE REPORT CONTRIBUTION TEAM LETTER FROM THE RISK MANAGEMENT ADITIONAL CHAIRMAN INNOVATION EXTERNAL INFORMATION CORPORATE STRATEGY MANAGEMENT COLLABORATORS MORE THAN 125 YEARS ANNEX I: SDGS TABLE MAIN FIGURES OF HISTORY CLIENTS OF CONTENTS VALUE CREATION MISSION, VISION AND SOCIAL CONTRIBUTION ANNEX II: SDG CONTENT VALUES INDEX

SDG COMMITMENT

CORPORATE GOVERNANCE

TRANSPARENCY, ETHICS AND INTEGRITY ABOUT COMSA CORPORACIÓN MAIN MILESTONES LETTER FROM MORE THAN 125 MISSION, VISION COMMITMENT TO CORPORATE TRANSPARENCY, ETHICS 2019 THE CHAIRMAN YEARS OF HISTORY AND VALUES THE SDG GOVERNANCE AND INTEGRITY

MAIN MILESTONES IN 2019

International Presence Human Team »»Commissioning of a new railway section between Gradec and Sveti Ivan Zabno, »»Launch of the “COMStruimos Liderazgo” project, focused on improving the in Croatia. culture of leadership. »»Track rehabilitation of the La Mata - Colonia Jordán section (33.5 km) of the »»Inclusion in the Top 25 companies of the MEPS2, a model of business excel- Istmo de Tehuantepec Railway in Mexico. lence in occupational risk prevention.

Economic area Environmental Impact and Contribution »»Turnover of 777 million euros. »»Signatories of the Spanish Government’s Circular Economy Pact »»Portfolio of 1,167 million euros. »»Membership of the #PorElClima Community initiative to reduce greenhouse gas emissions. Transparency, Ethics and Integrity »»Review of the group’s compliance model, with the updating of the map of Social Impact and Contribution criminal risks, including those associated with corruption. »»COMSA-UNHCR partnership, through the Salary Solidarity Programme, with »»Review of the Conflict of Interest and Harassment Protocols, derived from the the aim of helping improve coverage of the basic needs of refugees. 1. ABOUT COMSA CORPORACIÓN 1. ABOUT COMSA Code of Ethics. »»Creation of value at the local level, voluntary participation of professionals in social projects and promotion of culture and healthy habits. Innovation Management »»Investment of more than 7 million euros in a total of 35 innovation projects. »»Appointment of COMSA as a member of the Steering Committee of the Euro- pean Construction Technology Platform (ECTP).

New railway line between Gradec and Sveti Ivan Zabno, Croatia Istmo Railway, Tehuantepec (Mexico)

4 5 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES Chairman ofCOMSA Corporación INTERVIEW WITHTHECHAIRMAN OFCOMSA CORPORACIÓN Jorge Miarnau, THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 ic situation experienced in the previous crisis and its group in recent years following the serious econom- I would like to highlight the positive evolution of the group’s total turnover, the with185 million euros. of 22% to 14% from gone has which portfolio, note is the increase in the weight of the Engineering Concession businesses totalled 752 million euros. Of and Development Infrastructure and Services, and Maintenance Engineering, Industrial Infrastructure, accounts for 97% of total turnover. Thus, in 2019, the which corebusiness, our around centrating activity con - euros, million 1,167 of book order an haveWe turnover ofalmost 6%. in increase an shows method consolidation same are not included. However, the comparison with the Poland, in subsidiary Trakcjaits Group,the of sults re- the therefore and 2019, January since method equity the under consolidated been has group The the year with a global turnover of 777 million euros. In 2019, we maintained sustained growth and closed for drawing upthenew 2020-2024 Strategic Plan. bases the of establishment the as well as business, corehavinggrowthconsolidatedsustainedour a in and objectives established the achieved having of certainty the with Plan Strategic 2016-2020 the of conclusion relevancethe cial as group,such the for spe- of events two by marked was 2019 year The Corporación’s 2019 fiscal year? COMSA of assessment overall an give you Could AND VALUES MISSION, VISION THE SDG COMMITMENT TO GOVERNANCE CORPORATE cnmc evrnetl n sca performance, social and environmental economic, found exercise in reflection and transparencypro- on our a is 2019 for report Responsibility Social rate Corpo- our pages, following the in see will you As 2019? year this from highlight you would actions What by day. COMSACorporaciónday build together who those all of culture the into integrate to want we that it values into all areas of the group, reflecting the spir- integratewehowour showing wayof our is sibility Respon- Social Corporate that believe we short, In der equalityandendingpoverty. gen- change, climate against fight the to attention special paying (SDG), Goals Development tainable Sus- the with we have model end, business our this align to To worked 10principles. its of filment ful- the to commitment our showing thus 2019, in Compact Global Nations United the to adhesion group a our as highlight to like would I Therefore, its of pillars 2020-2024 Strategic the Plan. of one is and group’s mission and the vision into integrated fully is Sustainability poración? Cor - COMSA at understood sustainability is How ability to overcome adverse scenarios. AND INTEGRITY TRANSPARENCY, ETHICS 6 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES of prevention inorganisations. Safety culture the stimulatesrewards and which (MEPS2), and Health Occupational in Excellence of Monitor the of Top25 the highlight to like would I we2019received in ees, newawards, which among employforour caring of line same the Also,in and a safe andhealthy working environment. equal management, diversity, promoting fostering work-life balance, non-discrimination, and talent promoting and on opportunities based COMStruimos project, the in out set action of lines the in greatest asset, we have continued to make progress At the same time, aware that our human capital is our coverage ofthe basicneedsofrefugees. improvehelp to aims which Programme, Solidarity Salary the of launch the through UNHCR the with for example, I would like to highlight the partnership these key elements into its corporate integratingstrategy. and Thus, activity its for ones relevant most tainable Development Goals (SDG) by analysing Sus- the the to commitment its in progress made has With regard to responsible management, the group in which we operate. environments the of development sustainable the to activities our of contribution the including INTERVIEW WITHTHECHAIRMAN OFCOMSA CORPORACIÓN THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 - 2050. Finally, I would like to conclude by expresslyby conclude to like wouldFinally, 2050.I by our neutrality carbon achieving reducing and emissions progressivelyCO2 of aim the with tors, indica- rigorous and actions specific with change climate against plan strategic a up drawing are we end, this to and, emergency climate the of gation miti- the to contribute to is challenges our of one change, climate against fight the of context the In innovation. as well as ethics, business and governance porate cor- performance, sustainable stakeholders, our to commitment employees, our at aimed directly are In this sense, the strategic priorities of sustainability tal tools willserve asacatalyst. digi- of implementation creativity,the tive which in efficiency, differentiation, innova and sustainability - growth basedon to commitment our maintain we say, to Needless well asintherobustness ofourfinancial structures. of all the collaborators who are part of the group, as professionalcapacities the human in and especially strengths, our in confident are we crisis, Covid-19 uncertainty,of moments these In resulting from the further progress incontributing to sustainability? Where are you going to focus in the future to make AND VALUES MISSION, VISION THE SDG COMMITMENT TO GOVERNANCE CORPORATE Chairman ofCOMSA Corporación Jorge Miarnau velopment. de- sustainabletocommitment a growth,on based environmental and social economic, on focused ny the throughout support pastyear. We continuewill working compatoa be - and trust their us given sible and committed company, and those who have involved in our project to become a socially respon - havebeen stakeholderswho the all acknowledging AND INTEGRITY TRANSPARENCY, ETHICS 7 1. ABOUT COMSA CORPORACIÓN Latin America. by arapid expansion inEurope and establishment inPortugal, followed its internationalisation with its generation, COMSA started the arrival ofthefourth family of thegroup, andcoinciding with On theoccasion ofthecentenary companies ofthetime. made COMSA oneoftheleadingrailway the skillsofitsprofessionals quickly Knowledge oftheinfrastructures and track works andstation renovation. its activitiesinearlyyears onrailway Founded in1891 inReus, COMSA focused 2019 MAIN MILESTONES MORE THAN125YEARSOFHISTORY partner for clientsandcollaborators. COMSA Corporación areference of transport infrastructures, make construction andmodernisation with thehighspecialisation inthe experience ofthisgroup, together The more than125years of THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 Seville line. Spanish high-speedrail project, theMadrid- culminating withparticipation inthefirst was consolidated inthefollowing years, of thegroup throughout Spain,which track works, andbegantheexpansion promoted themechanisation ofrailway In the1960’s, thethird family generation AND VALUES MISSION, VISION geographical area. and territorial structuring inany development ofcommunications component focused onthe services withahigh technological with theaimofoffering integrated known asCOMSA Corporación, Group andtheEMTE Group, today saw theintegration oftheCOMSA The first decadeofthe21st century THE SDG COMMITMENT TO GOVERNANCE CORPORATE types ofworks. the construction ofall civil engineering,starting activities, withnew areas of change, it began to diversify its with thesecond generational Already inthe1940’s, coinciding security systems. on theinstallation andmaintenance of services, andCOMSA Security, focused COMSA Solutions,specialised inauxiliary sector. This area iscompleted by the maintenance andenergy efficiency with COMSA Service consolidated in area willcelebrate its25thanniversary In 2019, themaintenance andservices AND INTEGRITY TRANSPARENCY, ETHICS professionalism andclient which itoperates, always satisfaction, withrespect and innovation, COMSA and theenvironment in sustainability, integrity with theprinciplesof acting inaccordance for thecommunities Corporación isfully sustainable growth focused onquality, and responsibility. Committed to 8 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES growth. of humandevelopment withinaframework ofprofitable andsustainable and innovation, thereby meeting customers’ needs and fostering an environment and technological services following principlesofprofessionalism, quality To provide societywithintegrated infrastructure, engineering,environmental MISSION New Natura Bissé corporate headquarters, Cerdanyola delVallès (Spain) COMSA Corporación’s culture isbasedonthe mission, visionandvalues. MISSION, VISIONANDVALUES THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO technological andsocialprogress. driving international growth, whilepursuinggoalofcontributing to economic, To beleaders,consolidating theprofitability of various business linesand VISION (Colombia) Design, supplyandinstallation ofIntelligent Traffic Systems (ITS) inthe Villavicencio Corridor, Bogotá GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 9 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES VALUES MISSION, VISIONANDVALUES talent must benurtured asaguarantee ofitscollective success. their and assets corporation’sprincipal the of one are people Since Human team the sector, ensuringtheefficient managementofits resources. in group benchmark a as Corporación COMSA position to order In Results oriented solutions whichexceed theirexpectations. Concentrating efforts onmeetingcustomers’ needswithinnovative Customer focus strengthening thegroup. customers provide thereby solutions, value toadded high with integratedservice orderan with in lines business different the tween be- synergies exploiting on based strategy global a with Working Global vision, THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO in allitsactivities. With aclearcommitment to societyandtheenvironment Environmental responsibility improve theefficiency oftheirprojects. and needs their of anticipation in solutions technological advanced valuecustomerthe enabling assetin chain, an offersinclude that As Innovation andtechnology highest standards ofquality. the best solutions to each customer and implement projects with the and talentofitshumanresources, withacommitment to provide In thesearch for new opportunitiesbasedontheprofessionalism Excellence andinitiative GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 10 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES significantly. contribute can it where actions its focuses it that so stakeholders, its arerelevantmostthat analysingcommitment,those group and the for Developmentble COMSA(SDG), Goals Corporación advancedhas its in Sustaina- the by especially and 2030 Agenda the by year,marked This strategy, together withtheleadershipandinvolvement ofseniormanagement. COMSA Corporación integrates the key elements of sustainability into the group’s FOUR GREAT PRIORITIESFOR COMSA CORPORACIÓN centres. group contributes to reducing theenvironmental impact generated by urban than 7millioneuros. and the improvement of production and digitalisation processes worth more In 2019, thegroup managedinnovation projects linked to energy efficiency the development ofthecommunities where itispresent. basic services suchaselectricity, water andtransport, andthuscontribute to COMMITMENT TO THESDG increase theenergy efficiency oftheprojects, meanthat the projects were executed, which,together withmeasures that In 2019, 12LEEDorBREEAMcertified sustainable building come more inclusive, safe, resilient andsustainable. communities: and cities Sustainable modern andefficientinfrastructures, whichfacilitate access to COMSA Corporación’s own activityinvolves theconstruction of economic development. able infrastructure andinnovation are key drivers ofgrowth and infrastructure: and Industry,innovation THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 Urban spaces must be- Investment insustain- AND VALUES MISSION, VISION THE SDG COMMITMENT TO ing specific goals for the identified objectives with the greatest impact, as well as impact, greatest the with objectives identified the for goals specific ing group’sthe with line In commitments, COMSA Corporación workingis defin- on porate offices inSpainhave energy efficiency certification. joining thePact for aCircular Economy. In this regard, in 2019 the group formalised its commitment to this SDG by waste) anddeveloping new, more sustainable products. s n eemnn te prpit idctr t b al t maue their measure to able be to indicators appropriate the determining on as progress. This integration process is part of its commitment to sustainabil - ity,betweenbalancegrowth,economic the understood as reductionof environmental impactandsocialprogress initsenvironment. lan Climate Action Summit. Along these lines, these ClimateActionAlong lan Summit. efficiency and renewable energies and in 2019 energy joined the Cata- construction, sustainable to committed is group The emergency whoseconsequences may beirreversible. action: Climate system asraw materials (thuscontributing to thereduction of the into them reintroducing by by-products to value adding infrastructures, of life useful the extending resources, efficient of the use on working by economy circular the to mitted Responsible production and consumption: GOVERNANCE CORPORATE The fight against climate change is a global change climate against fight The AND INTEGRITY TRANSPARENCY, ETHICS The group is com- 75% of the cor75%the - of 11 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES Likewise, COMSA Corporación incorporates otherspecificactionsthat develop specificaspectsoftheSDG,amongwhichitis worthhighlighting: priority isgiven to therecruitment orpromotion ofwomen. whereby,criterion, selection mind, in betweencandidatesconditions equal with system for cooling theprimarycrushingmachinery. a water and recirculation has reuse area,water which deficit a (Spain), Maials in cient use of water at its facilities, most notably the GMN production plant located watersite.on treatmentInternally,out carried grouppromotesthe also osmosis effi- the the to thanks work the of use sanitary for and machinery the for cooling both reused been have water of m3 700,000 than More out. stands 2019, reduce thenumberofaccidents at work. carried out, as part of the project “Detection and Prevention of Overexertion” to overexertion”on back yourwas turn “Don’t Day,Worldcampaign Health of the occasion the Likewise,on vehicles. in improveergonomics awarenessand raise COMMITMENT TO THESDG In this area, the Amagá Tunnel project (Colombia), carried out in out carried (Colombia), projectTunnel Amagá the area, this In in thecomprehensive managementofwater. fication and desalination projects on four continents, collaborating yearshistory,of water,groupparticipateddrinking the has in puri- SDG 6 - Clean Water and Sanitation: culinisation of the sector, the group has decided to introduce a new and promotion of talent. Furthermore, despite the traditional mas- selection the in valued are diversity and meritocracy end, Tothis equal opportunities. - 5 SDG the reduce to activities to training through work, out at accidents traffic carried of number was campaign a 2019 in end, this To all itscollaborators. to extends commitment this and safety and health to committed Well-being:fully COMSACorporaciónand is Health Good - 3 SDG THE CHAIRMAN LETTER FROM Gender Equality: COMSA Corporación works to promote to works Corporación COMSA Equality: Gender YEARS OFHISTORY MORE THAN125 Throughout its more than 125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO riig n seilsto o dfeet rus tahn sbet i different in subjects training centres. teaching groups, different of specialisation and training the to contributed group the 2019, In apprentices. as CorporaciónCOMSA into incorporation and training their facilitating market, labour the to people young as joiningtheGlobalCompact. initiative. The group also promotes cross-cutting sustainability partnerships such in collaboration with UNHCR and membership of the #Porelclima the of membership and UNHCR with collaboration in programmesolidarity salary the in participation include Examples eas suchasinnovation, environment andsocialaction. lishes partnerships with different entities to maximise results in ar- Goals: the for Partnerships - 17 SDG production of263,868 MWhofrenewable energy. the tocontributed CorporaciónCOMSA power facilities, wind and photovoltaic of management the through 2019, in regard, this In renewable energy sector ispartofthegroup’s business strategy. energy: clean and Affordable - 7 SDG social exclusion in its hiring policy, also encouraging the accessof policy,encouragingthe hiring also its exclusion in social of risk at groups of integration the promotes group the Likewise, risk-free and working environments. safe promoting in lies professionals its to mitment Growth: Economic and Work Decent - 8 SDG GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS COMSA Corporación estab- Corporación COMSA h dvlpet f the of development The The group’s com- group’s The 12 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES Construction ofaStudent Residence nearSantsStation, Barcelona (Spain) COMMITMENT TO THESDG THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO NATIONS GLOBAL COMPACT ACCESSION TO THE10PRINCIPLESOFUNITED continuous improvement inthesector. has helpeddisseminate someofitsgood practices, thuscommitting itselfto Water Day orthe4thAnniversary oftheSDG,inwhichCOMSA Corporación Code ofEthics, aswell asininternational days suchasWorld HealthDay, World awareness ofitsemployees andcollaborators through specific training andits The group integrates theseprinciplesbothinits day-to-day work, withthe business group. ards, Environment andAnti-Corruption by joiningtheGlobalCompact asa the 10GlobalCompact Principlesintheareas ofHumanRights,LabourStand- At thebeginningof2019, COMSA Corporación strengthened itscommitment to GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 13 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES » » » Managing bodiesandstructures ofCOMSA Corporación: operation andcorporate governance, aswell asthedecision-makingprocess. This in thesector interms ofturnover. shareholding, in addition to being one of the leading unlisted Spanish companies 30% a family,Sumarrocawith the and stake,70% a family,with Miarnau the by owned still is it that fact the namely groups, both of characteristics significant integrationthe In process, COMSA mostCorporaciónthe of one maintained has the infrastructure and industrial engineeringsector. referencein a become allowedtoCorporaciónCOMSA has vision This projects. relationshipallowedthat comprehensive toclients offerthem their for solutions ly business groups. Both groups had historically maintained a close collaborative COMSA Corporación was born as a result of the integration, in 2009, of two fami- Areas. ResourcesHuman and CorporateLegal Economic-Financial,the supervising for responsibility direct has and CommitteeExecutive the chairs he these, Among ap- is pointed by the other members of Montserrat,the Board and discharges executive Miarnau functions. Jorge Mr. Directors, of Board the of Chairman The for theirknowledge ofthebusiness, management experience andexpertise. directors, who are elected by the General Meeting from among the shareholders proprietary of entirely consisting and Meeting Shareholders’ General the by ed COMSA Corporación’s highest governing body is the BOARD OFDIRECTORS » » » Operating andOperations Committees. Executive Committee. Board ofDirectors. CORPORATE GOVERNANCE eemns t a ag etn, h mdl of model the extent, large a to determines, business family of condition THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 Board of Directors, appoint- AND VALUES MISSION, VISION THE SDG COMMITMENT TO COMSA Corporation headquarters, Barcelona (Spain) GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 14 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES Composition oftheBoard ofDirectors of thedirectors isindefinite andtheseniorityofallthemdates back to 2014. functions in COMSA Corporación. As it is a limited liability company, the position representedsons by natural Threepersons. directorsthe of discharge executive The Board of Directors is made up of seven members, all of whom are legal per- CORPORATE GOVERNANCE THE CHAIRMAN LETTER FROM Mr. ALBERT SUMARROCACLAVEROL Mr. ALBERT SUMARROCACLAVEROL Mr. JORGEMIARNAU MONTSERRAT NON-BOARD MEMBERDEPUTY SECRETARY BALMORE PLUS, S.L. YEARS OFHISTORY MORE THAN125 BOARD MEMBER VILMAR ONE,S.L. BOARD MEMBER Mr. CARLESMASES VIÑAS BOARD MEMBER TI 2009, S.L. AND VALUES MISSION, VISION Mr. JORGEMIARNAU MONTSERRAT SHERATAN MANAGEMENT, S.L.U CHAIRMAN THE SDG COMMITMENT TO NON-BOARD MEMBERSECRETARY Mr. JOSEP LLUIS VILASECA IREQUENA BOARD MEMBER Mr. JOSÉ MIARNAU MONTSERRAT SEP MANAGEMENT, S.L.U. GOVERNANCE CORPORATE BOARD MEMBER Mr. JOSEP LLUIS VILASECA IREQUENA FIBEX BLUE, S.L. BOARD MEMBER Mr. JUAN MIARNAU MONTSERRAT DEIMOS INVERSIÓN,S.L.U. AND INTEGRITY TRANSPARENCY, ETHICS 15 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES the Executive Committee andtheOperating andOperations Committees. to any clarifications required by the Board and inform it of the decisions taken by Rodrigo,attend Boardthe of meetings the Directorsof guests.as They respond Lorenzo Guillermo Mr. function, Business the in and Samarra, Perea FerranMr. the Corporate function, nomic matters from the group itself. Likewise, the top executives of the group in sectoral bodies, and internally, through experts in environmental, social and eco - and consultants independent externally,through both reports, relevant quests reDirectors- of Board the stakeholders, affect may that decisions taking When mission, visionandcorporate values. compliance model, the Board of Directors has also reviewed the definitiongroup’s of the the updating of purpose the for regard, this In companies. member its and Corporación COMSA of mission the of definition the and principles values, functions as the highest managing body, its the of developmentone as of basis, recurringobjectives, a strategy,on promotesDirectors of Board the addition, In The matters dealtwithby theBoard of Directors are: strategic positioning implementation of long-term plans. CORPORATE GOVERNANCE strategy and Short-term and

development. THE CHAIRMAN LETTER FROM Institutional

lines ofbusiness and onstrategic Decision onthe launch ofnew investments. YEARS OFHISTORY MORE THAN125

relationships with stakeholders. Definition of

AND VALUES MISSION, VISION well ashiring,talent term leadership, as people andshort- development of long-term work environment. pool and Values,

Crisis management. THE SDG COMMITMENT TO at itsmeetinginthelast quarter of2020. Directors of Board the byinternally analysed and discussed be expectedtoare led by the Deputy Secretary of the Board. The conclusions of this self-evaluation was which Board, the of self-evaluationapproved a Board the 2019, of end the at Directors, of Board the of performance the of evaluation the to regard With govern that values COMSA Corporación’s and activities. principles the of application the of control and vision super- the with as well behaviour,as ethical and reputation corporate on icies pol- of adoption the CommitteeDirectorswith Ethics TheBoardof the entrusts of indicators main business performance. the of evaluation overall an the out year, carries the Directors of of quarters Board fourth and second the in months, six every least At

succession planning. company’s senior Evaluation ofthe executives and GOVERNANCE CORPORATE

Budgetary control.

AND INTEGRITY TRANSPARENCY, ETHICS and riskassumption decision-making Definition of processes.

appropriate measures implementation of or regulatory non- for theprevention of risksethical Adoption and compliance

16 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES and MrFerran Perea Samarra. Montserrat,LorenzoMontserrat,Miarnau Guillermo Miarnau José Mr Mr Rodrigo The Executive Committee is composed of Mr Jorge Miarnau Montserrat, Mr Juan attend thesemeetingsasguests. may Areas Corporate the of directors The Corporación. COMSA of progress in operations main the as well as objectives, and indicators business main the of evolution the up follow to basis monthly a on meets CommitteeExecutive The ures. basis for the analysis, determination and implementation of improvement meas- the as serves Board, the approvedby once which, Report Responsibility Social Corporate the of preparation the with Management Area Innovation and nical Techthe entrustedDirectors of - together,Boardareas threethe To these bring mittee inturndelegates to executive bodies,asdescribedbelow: mattersDirectors.Boardentrustedbyon of tothe it Thelimits, Executive Com- certain within decisions, take to delegated been has CommitteeExecutive The EXECUTIVE COMMITTEE CORPORATE GOVERNANCE tional HumanResources Department. Through theBusiness DepartmentandtheCorporate andOpera- Social area Department. Through the Business Department and the Technical and Innovation Environmental andhealthsafety area Business Department. the and Department Affairs Financial and Economic the Through Economic area THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 17 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES those of: notably most include Committees Operational These group. the governanceof good the on greatestimpact the with areas the monitor controland toare ities responsibil- main whose formed,areOperationalCommittees other addition, In as guests. can be attended by the directors and controllers of the respective theybusiness areas and objectives, established the of fulfilment the guarantee that indicators operational and management main the control and analyse committees These monthly. cept for the Infrastructure and Industrial Engineering Business area, which ex is areas, held business the of each for held are meetings committee Four-monthly meetings asguests. Board the attend who executives, top group’s the through the Directors of to Board report that Committees Operations and Operating are there Likewise, OPERATING ANDOPERATIONS COMMITTEES CORPORATE GOVERNANCE Contracting Resources Human THE CHAIRMAN LETTER FROM Communication Innovation YEARS OFHISTORY MORE THAN125 Finance Legal AND VALUES MISSION, VISION - THE SDG COMMITMENT TO top executives. group’s the through Directors, of Board the to finally, and, Committee ecutive are Organisation the of channelled upwards, from the concernsOperating and Operations Committees, to the critical Ex and information the of analysis The ly to theChairmanofBoard ofDirectors. es Department, which are responsible for the group’s social affairs, report direct- of Directors. Likewise, the Legal Department and the Corporate Human Resourc- environmentalresponsibleforBoard Department matters,report the directly to TechnicalR&D the includes which Department, Business Engineering and ture TheCorporateInfrastruc the and ServicesDepartment - EconomicFinancial and GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS - 18 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES ties are carriedout. activi- their which in setting environmental and social the and rights human for current regulations on matters of corruption and bribery, and in favour with complianceof respectstrict to respect with tolerancezero of criterion a with ración, COMSACorpo- up make who those all of conduct and behaviour for guidelines specific the in and model ance These principlesofbehaviour are reflected intheCode ofEthics , intheCompli- firmly committed to theethicalmanagementofalltheiractivities. are subsidiaries its and groupInfraestructuras, S.L. de CorporaciónCOMSA The TRANSPARENCY, ETHICSAND INTEGRITY 4 5 2 3 1 terest. in- of situation any avoiding organisation, the to loyalty with Acting tended benefits for theorganisation or for oneself. in- entertainment or payments improper on prohibition express An plete andunderstandable way. Transparency and reliability of financial information, transmitting com- Protection for responsible useofresources andinformation. Respect for internationally accepted laws andpractices. THE CHAIRMAN LETTER FROM derived from them, which indicate the indicate which them, from derived policies YEARS OFHISTORY MORE THAN125 DECALOGUE OFEXPECTEDBEHAVIOUR INCOMSA CORPORACIÓN AND VALUES MISSION, VISION THE SDG COMMITMENT TO CODE OFETHICS commitments oftheorganisation inthisarea orto theapplicableregulations. who form part of the group in those questions of an ethical nature related to the way,determinesCodeEthics expectedthe of the behaviour professionalsthe of this In activities. their out carry they which in environmentgeographical the or of its professionals, whatever their responsibility, their position in the organisation tended to establish the guidelines of behaviour that should guide the daily work Corporación’sCOMSA 10 9 6 8 7 flict ofenvironment andmaximisingthepurposes onthe community. Respect for the environment, minimising negative impacts on the contain healthandsafety standards. ob- to occupational external and internal with compliance Rigorous a in it truthful, orphysical, psychological ormoral harassment. authority of abuse discrimination, of kind any of Prohibition Fair competition. and collaborators. Acting withimpartialityand objectivityintheselectionof suppliers Code ofEthics COMSA Coroporación GOVERNANCE CORPORATE , available on the corporatein- website,the is availableon Ethics, of Code AND INTEGRITY TRANSPARENCY, ETHICS 19 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES » » » » » out: As part of this review, carried out in 2019, the following actions have been carried the group’s Compliance Modelhas beenreviewed andupdated. commitmentthe with to continuous improvement assumed by organisation,the some changes affecting the criminal liability of legal persons and, in accordance haveregulationsnewthat criminal the revisionsintroduced wellestas as made, lat- the and adoption its since elapsed has that time the accountinto taking al, Although the criminal prevention system implemented to date is fully operation - corruption andmoney laundering. pliance Policy details, among other elements, matters related to the fight against sponse Manual the Ethics, of system for ethical and regulatory non-compliance risks. Among others, the Code management constitutesa which Corporación,COMSAby headed group the in In 2011, COMSA Corporación adopted a COMPLIANCE MODEL » » » » » inatory Behaviour. DrawingProtocola of up for Preventionthe Harassmentof Discrim- other and conflict ofinterest in employment contracts for new hires. of declaration the of inclusion and Protocol Interest of Conflict a of Drafting Appointment ofaliaisonofficer for corporate vehicles in Peru. Committee. Ethics the resourcefor support a as technician compliance a of Appointment tion. corrup- with associated risks those including map, risk criminal the Updating TRANSPARENCY, ETHICSAND INTEGRITY , and the and Policy , Compliance Criminal form part of the group’s compliance documents. The Legal Com - THE CHAIRMAN LETTER FROM Compliance Model for all the companies YEARS OFHISTORY MORE THAN125 Crime Prevention and Re - and Prevention Crime AND VALUES MISSION, VISION THE SDG COMMITMENT TO Terminal 2ofthe Malaga-Costa del SolAirportsite visit,Malaga(Spain) GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 20 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES » » » » » » lenges are posedasof2019, amongwhichthefollowing stand out: chal- of series a model, compliancegroup’s the advancing continue to order In COMPLIANCE MODEL » » » » » » ulations, implementanethicalchannelandobtainISO37001 certification. In Peru, completion of the project to adapt the compliance model to local reg- cember 2019. De- approved Protocol, in Management Interest of Conflict the of Publication the RightsandDutiesofEmployees vis-à-vis theCompliance Model. Management of the Ethics Channel and Internal Investigations and Protocol for Approval and publication of a new Compliance Body protocol, Protocol for the prepared inthelast quarter of2019). already was (this Behaviour Discriminatory other and Harassment of vention Preventionthe Treasury Public againstthe Crimes of Protocoland Preforthe - tocol for General Risk Management Measures in Group Structures, Protocol for Policy,Hospitality Proand - Gifts privatesector), and (public of Risks Corruption Prevention the for Protocols protocols: new of publication and Approval mation SecurityPolicy. the for ProtocolControl Policy, of Critical Suppliers and Partners, compliance questionnaire Complianceand Infor - Criminal Ethics, of Code the doc- of current uments the of updating the of publication applicable, if and, Approval Appointment ofliaisonofficers inLatin America. TRANSPARENCY, ETHICSAND INTEGRITY THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO te tre ae, h Cmite a rld u ay ik ewe te alleged the betweenevents andCOMSA Corporación and/or link itsgroup companies. any out ruled has Committee the cases, three other has decided, for the time being, not to commence any internal procedure. In the and cases these with dealt has Committee Ethics The past. the in Corporación COMSA with associated been have or are who persons involvinginvestigation part of the group. Of the five issues assessed, only in two cases is there a judicial related to ADASA Sistemas, S.A.U. which, at the date of issue issue one of this and report, international) is are not two which (of S.A.U. COMSA, to related issues four companies: following the to correspond that issues five evaluated has tee a risk to COMSA Corporación or any of its group companies, the Ethics Commit - With respect to questions related to corruption issues that could eventually pose GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 21 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES Composition oftheEthicsCommittee : the terms ofthelegislation. controlunder powersinitiativeendowedautonomousand of Committeeis with Ethics Ethics The Model. group’sCompliancethe the framework of the within Committee,by out carried is Ethics of Code Corporación’s COMSA with line in In this regard, the analysis, research, evaluation and resolution of behaviours not mechanisms intheevent ofpotential non-compliance. in the Code of Ethics, COMSA Corporación has established follow-up and control included principles the with complianceguarantee to order Additionally,in and THE ETHICSCOMMITTEE TRANSPARENCY, ETHICSAND INTEGRITY INFRASTRUCTURE ANDENGINEERING G.D. THE CHAIRMAN LETTER FROM HUMAN RESOURCESDIRECTOR Mr. GUILLERMOLORENZO YEARS OFHISTORY MORE THAN125 Mr. IGNACIO PONZ BOARD MEMBER BOARD MEMBER AND VALUES MISSION, VISION ETHICS COMMITTEE SECRETARY LEGAL DEPARTMENT DIRECTOR CHAIRMAN OFTHECOMMITTEE CHAIRMAN OFTHEBOARD Mr. JORGEMIARNAU Mr. CARLESMASES OF DIRECTORS THE SDG COMMITMENT TO the managingbodyofthat company. pany andconsequently ofthedifferent liaisonofficers ismade by agreement of liaison officer. The appointmentofthecriminal prevention bodyofeach com- respective criminalprevention bodies,madeupoftheEthicsCommittee anda In addition,thenational subsidiariesofCOMSA Corporación allhave their BOARD MEMBER DIRECTOR OF ADMINISTRATION ANDCORPORATE CONTROL Mr BOARD MEMBER CORPORATE ECONOMIC SERVICES G.D. Mr. FERRANPEREA GOVERNANCE CORPORATE . SANTIAGO SANJOSÉ AND INTEGRITY TRANSPARENCY, ETHICS 22 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES Construction ofthe AVE station inLaSagrera, Barcelona (Spain) on theintranet andalsoonCOMSA Corporación’s corporate website. Information on the complaint channels is detailed in the Code of Ethics, available treatment andactionundertheprincipleofnon-retaliation. Tofromit. toensureconfidentiality, designed is Channel Ethics the end, this fair derived conduct of code the tocontrary is that behaviour observed any report The Code of Ethics includes, as a requirement for all personnel, the obligation to COMSA Corporación employees andintheirrelations withthird parties. by application their in safety,both and health to related those including rights, human of violation or bribery corruption, of form any to relation in especially, and, matters its of any in Ethics of Code the provisionsof the with line in not ly group can communicate in good faith about behaviours and practices potential - COMSA Corporación has an THE ETHICALCHANNEL TRANSPARENCY, ETHICSAND INTEGRITY THE CHAIRMAN LETTER FROM Ethics Channel, through which all employees of the YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO Ethics is accessible to all of them and can be consulted on the corporate of website. Code Corporación’sCOMSA group, the outside stakeholders to regard With training courses are alsodelivered intheabove-mentioned languages. tion and Response Manual, are available in Spanish, English and Portuguese. The The Code of Ethics, the Criminal Compliance Policy, as well as the Crime Preven- and Response Manual. PreventionCrime the procedureprovidedin the accordingproceedings, to tion cient data, and therefore the Ethics Committee decided not to initiate investiga- garding facts that could not be confirmed due to a lack of information and suffi- re- Channel, Ethics the through received was complaint one only 2019, During An EthicsChannelwillalsobeimplemented inPeru. an on done been has workgroup’sreview compliancemodel, the the of of part As Ethics Channel Protocol that will be approved during the financial year 2020. GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 23 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES 1 Categories include:1Directors; 2Delegates, Managers, Area Headsand DepartmentHeads; 3Site ManagersandUnit Heads;4Technical andAdministrative staff, and5Operatives. People trained intheCode ofEthicsin2019 recruits, sothat 80peoplewere trained inthisarea duringtheyear. providednewtoalso Mexico, wastraining and and Chile Colombia,Brazil, Peru, cycleing wasSweden,from Portugal,continued forpersonnel Spain, Argentina, particular,trainIn 2019.the - 2019,in later in and 2018 in continued this and ees, Corporación’sbody,managing group’stothe wellas executivesas employand COMSA to provided were subject this on training and communication2017, In in thisbusiness culture. collaboratorsits making valuechain, participants intoits principles ducedthese promoting trainingimplementing professionals,and among to COMSA Corporación introhas - addition In rights. human for respect to relating issues includes ards that make up the culture of compliance in the organisation, which implicitly and the group, who must know and apply the instruments, principles and stand- continuous training implies in these matters management for all employees responsible and managers of and COMSA Corporación ethical to commitment The TRAINING ANDCOMMUNICATION Total Category 5 Category 4 Category 3 Category 2 Category 1 Professional category TRANSPARENCY, ETHICSAND INTEGRITY 1 THE CHAIRMAN LETTER FROM YEARS OFHISTORY MORE THAN125 Women 18 15 - 1 1 1 Men 62 38 9 6 9 - AND VALUES MISSION, VISION Total 80 53 10 9 7 1 - THE SDG COMMITMENT TO Office training day, Barcelona (Spain) GOVERNANCE CORPORATE AND INTEGRITY TRANSPARENCY, ETHICS 24 1. ABOUT COMSA CORPORACIÓN 2019 MAIN MILESTONES doms by allpersons. joyment or exercise,en- recognition, on an equal footing, of human rights and fundamental free- the impairing or nullifying of effect or purpose the has which preferenceor exclusion,restriction distinction, any means discrimination terms, ment and/or discriminatory behaviour within the group’s organisation. In harass- general any eradicate and avoidprevent, to Corporación COMSA that govern must guidelines procedural the establish to aims Behaviour Discriminatory er the hand, other the On the negotiation soallows. to comply with it are included in contracts with suppliers and partners, whenever commitmentexistence the its toto and Ethics, of Code the valuesof and ciples ship with suppliers and partners. Along these lines, clauses referring to the prin- The Code of Ethics establishes the framework for COMSA Corporación’s relation- the among companies that make upthegroup oramongthosethat collaborate either withthem. these to contrary practices admitting not conventions, ILO basic the in contained provisions labour the with compliance ensure to means COMSAstatesthatCorporación Ethics provides of Code respect,the the this In tinational Enterprises, amongothers. on Fundamental Principles and Rights at Work and the OECD Guidelines for Mul- ConventionsOrganisationInternational(ILO),Labour the of ILOthe Declaration the Rights, Human of Charter International the as such standards, international highest the on based area,geographical each forcein requirementsin legal the with compliance in projects its out carry to commitment its accordancewith in the with Compliance RESPECT FOR HUMANRIGHTS TRANSPARENCY, ETHICSAND INTEGRITY THE CHAIRMAN LETTER FROM guarantees that COMSA Corporación acts CorporaciónCOMSA that guarantees Ethics of Code rtcl o te rvnin f aaset n Oth - and Harassment of Prevention the for Protocol YEARS OFHISTORY MORE THAN125 AND VALUES MISSION, VISION THE SDG COMMITMENT TO ations where there isariskofhumanrightsviolations. situ- identified not COMSACorporaciónhas hand, other the On Channel. Ethics the through notified be can rights human of violation possible of situation Any pact. Corporación adhered to the to adhered Corporación COMSA 2019 in rights, human respect to commitment group’s the with line In courses heldsince 2017 ontheCode ofEthics. training the relation in included been in have contents these established rights, human for guidelines respect to the with compliance guarantee to order In United Nations Sustainable Development Goalnumber 8. protection,atworkrights dialogue,aresocial which and central the of elements the of pillars four the of ment In the same vein, COMSA Corporación expresses its commitment to the develop- for freedom ofassociation andcollective bargaining. respect and activities, its on carries it where area geographical any in peoples the of defence total its as well as ditions, workof anyinvolvesthattype and extreme,painful, degradingor coninhuman - of rejection total its declares Corporación COMSA GOVERNANCE CORPORATE 10 Principles of the United Nations Global Com- Global Nations United the of Principles 10 decent workdecent AND INTEGRITY TRANSPARENCY, ETHICS rights of minorities and indigenous and minorities of rights agenda, namely, job creation, social namely,creation, agenda, job child labour, forced labour,forcedlabour, child ECONOMIC SPHERE BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

BUSINESS MODEL

COMSA Corporación’s business model is structured in four main areas, which contribute to the development of advanced infrastructures with a high technological component, with the aim of promoting economic growth and the territorial structuring of the countries in which it carries on its activity, integrating the highest quality standards and sustainability principles in order to offer high added value solutions to its clients.

»»Infrastructures 2. ECONOMIC SPHERE 2. ECONOMIC »»Industrial Engineering »»Maintenance and Services »»Infrastructure Development and Concession »»Other activities

COMSA Corporación exports its knowledge and more than 125 years of experience in the construction and maintenance of infrastructures all over the world. It is currently present in Andorra, Algeria, Brazil, Chile, Colombia, Croatia, Den- mark, Spain, France, Mexico, Morocco, Paraguay, Peru, Poland, Portugal, Roma- nia, Sweden, Switzerland and Uruguay.

In 2019, the COMSA Corporación de Infraestructuras group managed a workforce of more than 5,000 employees, allowing it to achieve a turnover of 777 million euros. In line with its strategic plan, 38% of this turnover corresponds to its international activity. Tram construction, Odense (Denmark) INFRASTRUCTURES

COMSA has been involved in the development of railway infrastructure for more COMSA is one of the main unlisted construction companies in Spain and has a than 125 years, offering a comprehensive service covering the construction and solid international presence in markets such as Brazil, Chile, Croatia, Colombia, maintenance of high-speed lines, trams, as well as metropolitan and regional Denmark, Mexico, Peru, Poland, Portugal, Romania, Sweden and Uruguay. railways.

In the field of civil works, COMSA carries out comprehensive works on roads, airports, housing developments, maritime and port works, as well as hydraulic, sanitary works, etc. In building, the group stands out as an experienced builder of singular works of great architectural complexity.

26 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

BUSINESS MODEL

INDUSTRIAL ENGINEERING MAINTENANCE AND SERVICES

COMSA Industrial has more than 50 years of experience in carrying out engi- COMSA Service, which celebrated its 25th anniversary in 2019, is a multidiscipli- neering projects with a high technological component, focusing on the design nary service company operating in the maintenance and energy efficiency sec- and execution of installations for the infrastructure, industrial and services sector. tor, specialising in the comprehensive maintenance of buildings and facilities, in order to ensure their optimal operation and extend their useful life, as well In the field of engineering, COMSA Corporación focuses its offer on installations as property management, technical assistance, energy optimisation and carbon

2. ECONOMIC SPHERE 2. ECONOMIC and systems, electrification and railway systems, ITS (Intelligent Traffic Systems), neutrality, also developing the design, construction and preservation of orna- fire protection, solutions for Bio&Pharma, telecommunications, airports and mental fountains, including the decorative treatment of water, light, image, fire ports, as well as electrical transport and distribution. and sound.

Likewise, and with the vocation of comprehensive service, the companies COM- SA Auxiliary Solutions, specialised in auxiliary cleaning, janitorial and gardening services, among others, and COMSA Security, focused on the installation and maintenance of security systems, are part of this area.

INDUSTRIAL

SERVICE SOLUTIONS SECURITY

Installation of boarding bridges and auxiliary equipment, Malaga airport (Spain) Renovation of the ornamental fountains on the Salou promenade, Tarragona (Spain)

27 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

BUSINESS MODEL

INFRASTRUCTURE DEVELOPMENT AND CONCESSION

Concessions Under this activity, investments in transport infrastructure and real estate concession companies are grouped together, offering additional business opportunities. 2. ECONOMIC SPHERE 2. ECONOMIC TRAMVIA METROPOLITÀ DEL BESÒS S.A.

Renewable Energies This area groups together companies that manage renewable energy projects and assets, such as wind, photovoltaic, solar thermal and biomass. Tramway Concession, Murcia (Spain)

RENOVABLES

OTHER ACTIVITIES

This area groups together the group’s supplementary activities, such as radi- ofrequency diffusion systems, water technology, management, treatment and recovery of end-of-life tyres, and consultancy and development of IT projects.

Telecommunications transmitter from Egatel (Colombia)

28 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

RISK MANAGEMENT

COMSA Corporación has established a proactive process in relation to risk man- »»With regard to the activity, Infrastructure and Industrial Engineering projects agement that is based on the early identification, evaluation and mitigation of have a high variability in terms of volume, which is determined to a large ex- risks as a key factor for risk management, as well as for the detection of new tent by the type of activity, which is very diversified in the case of industrial improvement opportunities. engineering. »»As for the geographical scope, this will be a determining factor in establishing The group is exposed to risks that are directly related to the carrying on of its the resources needed and available for each project, which, together with the activity, whether they are related to the geography and countries in which it tight margins within which the sector operates, make proper project selection operates and/or to the socio-economic, environmental and legal environment, 2. ECONOMIC SPHERE 2. ECONOMIC and optimum risk management essential, both at the tender stage and later on among other key aspects. in the implementation phase. »»

In 2017, COMSA Corporación carried out identification and evaluation of the main risks, obtaining the following key risk map:

R01 Own damage in project execution R19 Exchange rates R43 R42 R02 Errors during construction R23 Reputational risk R23 R12 R06 Breach of contract with third R30 Partner actions R30 R01 R41 parties R18 R36 Reporting of project progress R36 R02 R08 Health and Safety information

Impact R14 R06 R08 R12 Administrative civil and criminal R38 Loss of talent liability R41 Contractual clauses R38 R14 Damage to the environment R42 Compliance with the Strategic Plan R18 Delays or insolvencies of clients R19 R43 Loss of ability to contract

Probability

The risk map will be revised during the 2020, to adapt it to the new realities of a substantially changing and complex environment. To review the group’s key risk map during 2020.

OBJECTIVE

29 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

RISK MANAGEMENT

COMSA Corporación also has other systems to identify, evaluate, manage and minimise possible risks that may affect the group in other areas, as described below.

»»Criminal risks. The group has implemented a Compliance Model which, taking the Code of Ethics, the Criminal Compliance Policy and the Crime Prevention and Response Manual as a reference framework, develops a whole series of policies and procedures that ensure ethical and responsible behaviour in the 2. ECONOMIC SPHERE 2. ECONOMIC group, meeting the regulatory requirements related to the organisation’s activity. For more information on this area, please refer to the section on Transparency, ethics and integrity in this report.

»»Aspects related to environmental management. Within the framework of COMSA Corporación’s environmental management system, the group has identified the internal and external factors that may represent a risk and/or an opportunity for it. Second phase of Metro Line 4, Sao Paulo (Brazil)

These factors include the following: For each factor, threats and opportunities are identified, and the actions contem- plated to respond to them are detailed.

External factors Internal factors »»Health and safety aspects. Similarly, the group has also identified internal and »»Legislative changes in the environmental »»Strategic management and leadership. external factors that may pose a risk and/or opportunity within the framework field. of the occupational health and safety management system. »»Environmental conditions and »»Weather conditions (natural disasters). operational control. »»Potential effects on cultural heritage. »»Performance of the organisation. Monitoring, measurement, analysis and External factors Internal factors »»Client requirements. evaluation of environmental aspects. »»Value chain: clients, suppliers, partners »»Employees competence in terms of »»New market needs, related to client and »»Significant environmental aspects and competitors. qualifications and use of equipment. investor expectations. during the execution of the works. »»Technical aspects and those aspects »»Operational control systems. »»Technical aspects. »»Training and awareness on related to the production process itself. »»Project types and geographical »»Social demands. environmental issues. »»Related to economic investment. distribution. »»Aspects related to purchases and »»Socio-economic situation and legal and management of suppliers and social security of the environment. subcontractors »»Geographical accessibility.

30 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

CORPORATE STRATEGY

In recent years, COMSA Corporación has developed its 2016-2020 Strategic Plan, structured around four fundamental objectives:

»»To focus the group’s activity on the activities of the Infrastructures and In- Additionally, during 2019, COMSA Corporación consolidated its upward trend dustrial Engineering business area, integrating the support and production in the innovation project portfolio. Currently, 32 initiatives are being developed assistance functions, with the aim of ensuring maximum organisational effi- with a budget of more than 7 million euros. ciency. During 2019, the integration of cross-cutting and business areas linked to the 2. ECONOMIC SPHERE 2. ECONOMIC core business continued. »»Divestment of non-strategic assets that do not offer the possibility of generating synergies with the Infrastructure or Industrial Engineering activities. The divestment objectives for the period of the Strategic Plan were already achieved in the previous year. However, the process of divestment of some Business Units that are not strategic for the group has continued. »»Internationalisation of activities, using the specialities in which COMSA Cor- poración makes use of its competitive advantages, both technical and mana- gerial, acting as a spearhead to capture new opportunities. During 2019 the group worked to consolidate and expand its activity in Lat- in American markets, such as Peru, Colombia and Mexico, as well as in the strengthening of European markets such as Sweden and Portugal, or which represent new business opportunities, such as the Balkan Peninsula. »»To promote Innovation as a differential factor, developing an open innovation model, based on Corporate Venturing. During 2019 COMSA Corporación launched the programme “The InnCom Challenge” to encourage collaboration with startups, receiving 120 applications from 34 different nationalities. After analysing the applications of the different candidates, three finalists were selected with solutions based on Artificial Intelligence (AI) and Big Data focused on improving efficiency and decision making in the execution of large infrastructure works, thus promoting the digitalisation of the construction sector. COMSA Corporación is collaborating with them in the process of validation, scaling and commercialisation of their products/services at national and international level.

Tram section under construction, Odense Tram (Denmark)

31 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

CORPORATE STRATEGY

Furthermore, COMSA Corporación, during 2019, established the basis for the drafting of the new 2020-2025 Strategic Plan. The strategic lines of this new plan are as follows:

1 Prepare and develop commercial plans based on specific guidelines for each of the businesses and activities with the support of the Contracting

2. ECONOMIC SPHERE 2. ECONOMIC area. The group’s strategy in this regard is to advance in the establishment of methodologies for the identification, evaluation and mitigation of commercial and operational risks.

2 Develop a unified project planning system to anticipate risks and opportunities and make decisions more quickly.

3 Continue with the digitalisation of the group both in the support in the execution of projects and in the improvement of the internal processes.

4 Maintain specialisation and comprehensive service to our clients, with innovation as the backbone to enhance our competitive advantages.

5 Continue promoting collaboration between the group investees in international projects.

6 Review the organisational model in the Infrastructure and Industrial En- gineering perimeter during 2020 and place the work at the centre of the model.

Based on these guidelines, the 2020-2025 Strategic Plan is expected to be im- Track rehabilitation of a 327 kilometer section between Piedra Sola and Salto Grande (Uruguay) plemented and deployed during the year 2020.

32 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

MAIN FIGURES IN 20191

SPAIN

Sales: € 507 M 2. ECONOMIC SPHERE 2. ECONOMIC

Portfolio: € 626 M

Employees: 3,938

EMEA LATAM

Sales: € 106 M Sales: € 164 M

Portfolio: € 311 M Portfolio: € 184 M

Employees: 302 Employees: 854

1 Group consolidated figures.

33 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

VALUE CREATION

COMSA Corporación’s strategy in Corporate Social Responsibility has been promoted, since its inception, by Senior Management. Based on the conviction that ethical and responsible action is essential for the sustainability of the business, the group maintains a stable, sustainable and integrating commitment, in which the participation of all the stakeholders in the value chain, the motivation and promotion of the talent and creativity of its professionals, as well as the commitment to continuous improvement, are its backbone. 2. ECONOMIC SPHERE 2. ECONOMIC Among the main initiatives that have been launched, COMSA Corporación con- solidates measures of shared prosperity and that promote common benefit. Ex- amples of this type of initiative are those carried out in the area of personal and professional development of the group’s employees, which include policies on work-life balance and the right to disconnect, or the participation of clients in the development of products and services that cover both explicit needs and present and future expectations.

These same principles are the basis of the commercial relationship with suppliers and collaborators, in which trust and the promotion of initiatives for the common benefit are aimed at producing stable and lasting relationships, creating value by generating quality employment and wealth in the countries where COMSA Corporación carries out its activities.

During 2019, COMSA Corporación contributed to the productive growth of society, generating stable and quality employment, with an average employees of 4,205 people, and almost 20,000 collaborating companies, 97.24% of which are companies located in the countries where the activities are carried on. All in all, the activity generated by the group in 2019 involved 14,795 direct jobs in its work centres, including its own workers and collaborators.

In addition to its own business activity, COMSA Corporación contributes to social causes in the areas where it is present, either by supporting cultural, sports and environmental institutions or by training and integrating groups at risk of exclusion, with a view to contributing, directly and indirectly, to the achievement of the United Nations Sustainable Development Goals.

Widening of the BR-101 highway, São Miguel dos Campos (Brazil)

34 BUSINESS RISK CORPORATE MAIN VALUE MODEL MANAGEMENT STRATEGY FIGURES CREATION

VALUE CREATION

MAIN BUSINESS FIGURES IN 2019

SALES (¤M) PORTFOLIO (¤M) INNOVATION

Infrastructure and

2. ECONOMIC SPHERE 2. ECONOMIC Industrial Engineering ¤ 1,101 M1 ¤ 1,113 M1 ¤ 1,140 M ¤ 734 M2 ¤ 777 M2 ¤ 1,155 M ¤ 7 M 35 + de 10 Other Businesses I+D+i Innovation of projects with Collaborative 2018 2019 ¤ 15 M Investment projects UNE 166002 partnerships certification

ENVIRONMENTAL CONTRIBUTION

Building Research Establishment Environmental Assessment Method (BREEAM) 78% 11,372 MWh 1,384,084 t SUSTAINABLE BUILDING of sales with Electricity Non-hazardous ISO 14001 consumption waste generation 75% Spanish corporate offices Certified certification 12 Projects in execution in 2019

SOCIAL AREA

97.2% 80% 8.2/10 + 5,0002 5% 62,175 77 % Local of sales with Average Direct Reduction Training of sales with suppliers ISO 9001 client employees Incidence Rate hours OHSAS 18001 certification satisfaction compared to 2018 certification

1 Data homogenised according to 2019 consolidation criteria (Trakcja Group in Global Integration). 2 Figure referring to the COMSA Corporación group (not including the Trackja Group). 35 ENVIRONMENTAL SPHERE ENVIRONMENTAL INNOVATION CONTRIBUTION MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

COMSA Corporación, aware of the potential impact its activities may have on the environment, assumes a commitment with the communities where it is present and works to minimise their effect on climate change, reducing their carbon footprint, increasing the efficiency of the resources used, making a responsible use of them and carrying out projects that integrate sustainability throughout their life cycle.

COMSA Corporación integrates, as an organisational value, For each project, the group also designs and implements Environmental Mon- itoring programmes, based on a procedure for evaluating the normal environ- respect for the environment in which its operations are carried out mental aspects, as well as the potential ones and emergency situations in each case, taking into account the entire life cycle of the project to ensure that these

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL The group carries out an analysis of risks and opportunities in relation to its en- points are known and adequately controlled. In this way, the group implements vironmental performance, taking into account the context of the organisation, measures that minimise the environmental impact derived from the execution of as well as the needs and expectations of the stakeholders. To this end, COMSA the project and improves the environmental conditions of the surroundings by Corporación identifies these risks and opportunities through the analysis of the providing added value. processes and activities carried out in the different business areas, and establishes actions to be implemented in this respect. The Environmental Policy of COMSA Corporación defines the principles of action of the group, acquiring commitments in different areas to: Among the main environmental risks identified by COMSA Corporación in the carrying on of the activity, the following stand out: »»Promote the circular economy. »»Combat climate change and reduce the carbon footprint. »»Contamination of soil, aquifers, watercourses and sea beds by accidental spill- »»Reduce water consumption. age of hazardous products and waste. »»Improve energy efficiency. »»Negative impacts on biodiversity. »»Reduce waste generation. »»Noise and vibration. »»Respect biodiversity. »»Effects on historical and artistic heritage. »»Uncontrolled dumping of waste. »»Atmospheric pollution by combustion gases from machinery and equipment and by particle emissions. 78% of COMSA Corporación’s sales are executed under the »»Fires. guidelines and directives of the international environmental management standard ISO 14001:2015. Environmental Policy of COMSA Corporación

37 ENVIRONMENTAL INNOVATION CONTRIBUTION MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

These commitments are specified in the Environmental Management System, In addition, COMSA Corporación has a Procedure for the Identification and Eval- certified based on the ISO 14001:2015 standard, which is integrated with the uation of Legal Requirements both in the projects it executes and in its own Quality and Health and Safety Management System, with which it is interre- workplaces. In 2019, thanks to the implementation of the Wordlex platform, the lated. Within the framework of the management system, COMSA Corporación group was able to centralise and automate the document management of legal promotes continuous improvement, establishes the objectives to be achieved, requirements on construction sites, thus optimising time and resources. monitors their attainment and evaluates their performance by means of periodic audits at its work centres. The management of the various companies also re- Furthermore, it should be noted that in 2019 COMSA Corporación carried out an views the entire system periodically. internal environmental awareness campaign, which included, among others, the following actions:

»»In offices, the sustainability course “Good environmental practices in offices

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL As a tool for continuous improvement, starting in 2020, and energy efficiency” has been launched, an online training course taught semi-annual reports of good environmental practices through the virtual campus that aims to provide new information on funda- have been planned, which will be available to all the mental practices in environmental management to raise awareness and im- organization’s personnel. prove aspects such as resource scarcity and pollution. More than 420 employ- OBJECTIVES ees have received this training in Spain.

»»On construction sites, the group gives informative talks to all the personnel involved at the beginning of each project and also during the course of the project at the coordination meetings. Along these lines, and as a supplementary measure, the group has taken out voluntary environmental responsibility insurance, both at national and international level, which provides coverage in the event of the risks described above materialising.

With respect to the disclosure of COMSA Corporación’s environmental commitment in the supply chain, the group transfers the required environmental criteria through contractual requirements. These criteria are systematically evaluated and serve as an indicator in the selection of suppliers.

Castilla A-62 motorway. Section: Fuentes de Oñoro, Border between Portugal and Salamanca (Spain)

38 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

WASTE MANAGEMENT AND CIRCULAR ECONOMY

Generation of waste

The efficient management of the waste produced in the projects is focused on minimising its generation, promoting segregation at source, recycling, reuse and recovery as opposed to disposal by controlled deposit.

Waste produced by type: 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL Hazardous Waste Non-Hazardous Waste 2019 2018 2019 2018

Total waste 1,384,084 826,6911 335 217 (t) (86.69% land) (71.37% land)

As is the case with most of the resources used by the organisation, waste production is strongly linked to the types of projects executed, with infrastructure projects being the ones that generate the greatest volume due to the large amount of land that must be mobilised in the case of road or tunnel construction, among others.

»»Corporate: eliminate plastic cups and replace them with ceramic cups and reusable bottles for the group’s professionals, as well as compostable cups for the visits. »»Works: optimise the methodology for quantifying OBJECTIVES the materials revalued internally or through waste managers.

GMN processes out-of-use tires for recovery, separating their components and recycling the rubber for reuse in Maials plant, Lleida (Spain)

1 Variation from 2018 publication: An error occurred in the unit of measurement used for land in Denmark, where the mass was reported in kg and counted as t. 39 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

Circular economy

The circular economy is one of the strategic axes of COMSA Corporación’s activ- With regard to earth, which accounts for approximately 87% of the materials ity, in which it integrates the life cycle approach in its management. considered as waste in the projects, the group prioritises the use of these both within the same work from which they are extracted or moved, and in nearby The group considers that the implementation of the circular economy is key to projects, thus avoiding their consideration as waste, and at the same time reduc- the transformation of the construction sector, which has a considerable impact ing the amount of materials needed in new projects. on the environment due to the amount of natural resources it mobilises and the high percentage of waste it generates. Additionally, as described below, COMSA Corporación considers innovation as an internal ally with which to make possible the true transition to a circular econ- For this reason, in 2019, COMSA Corporación adhered to the Covenant for the omy. Through innovation, the group promotes the development of new materials

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL Circular Economy of the Spanish Government Ministries of Agriculture and Fish- and construction techniques that contemplate the rational, efficient and respon- eries, Food and Environment and Economy, Industry and Competitiveness, which sible use of resources, applying these criteria in the design phases and under a mainly promote the reduction of the use of non-renewable natural resources, the vision of energy efficiency and improvement in the performance and durability reuse of waste as raw materials, recycling, the analysis of the life cycle of prod- of the infrastructures in which it carries on its activity. ucts and services, the incorporation of eco-design criteria and the awareness of the public. In this area, and within the framework of the State R&D&I Programme Orient- ed to the Challenges of Society, the NOVOFUEL project stands out. Through The Group also specifically promotes the use of recycled and/or certified con- the treatment of plastic and biomass waste synthesis, the group is developing struction materials, offering these types of more environmentally friendly alter- different types of fuels, whose use is ideal for industries with high energy con- natives to the client when selecting the materials to be used. sumption, such as cement, steel and ceramics, as well as for thermal coal plants, cogeneration or gasification of biomass or urban waste.

Construction of the Amagá Tunnel of the Pacific Connection Highway 1, Antioquia (Colombia) Development of new high energy content CSR from urban and industrial waste

40 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

Initiatives undertaken in 2019 to promote the circular economy and recycling:

Awareness In Mexico, internal Revaluation of materials 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL awareness campaigns In Colombia, 33,066 kg of non- Awareness Revaluation of materials have been carried out to hazardous waste was managed for In Spain, a campaign was carried In Spain, at GMN Maials plant, 31,273 t make people aware of reuse, largely made up of wood and out to reduce the use of plastics in of end-of-life tyres were reused, the correct separation metal, which accounts for 31.94% of the office. representing a 32% increase on the and disposal of waste the non-hazardous waste from the previous year. and the prevention of its project1. generation at work sites.

Revaluation of materials Revaluation of materials In Spain and Mexico, In Brazil, improvements to the 3,540 purchased pallets Revaluation of materials waste management system have were returned to the In Peru, 1,715 kg of materials led to an increase in the volume supplier to be put back (including waste from clearing, of segregated waste going to a into circulation. paper, land and toner) have cooperative in the region. been separated and donated to the community for reuse and revaluation.

1 Non-hazardous waste from the Amagá Tunnel Project not including earth and debris. 41 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

SUSTAINABLE USE OF RESOURCES

Water consumption1

The activities carried out by COMSA Corporación have a considerable consumption of water associated to them, especially relevant in infrastructure works.

Water consumption in the organisation and its projects2 by type: Mains Water (m3) Purchased Water (m3) Harvested Water (m3)

2019 2019 2019

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL 51,012 13,455 719,857 On site On site On site

Office 6,085 Office 696 Office

0 10 20 30 40 50 0 3 6 9 12 15 0 100 200 300 400 500 600 700 800

Total Consumption (m3) Total Consumption (m3) Total Consumption (m3) 57,096 14,151 719,857

2018 2018 2018 29,343 25,209 72,162 On site On site On site

Office 5,562 Office Office

0 5 10 15 20 25 30 0 5 10 15 20 25 30 0 10 20 30 40 50 60 70 80

Total Consumption (m3) Total Consumption (m3) Total Consumption (m3) 34,905 25,209 72,162

1 Water consumption data for 2018 have been modified with respect to those reported in the 2018 Report. 2 The water consumption in projects and works includes the consumption of logistics centres and all those non-corporate offices, and which are associated with projects.

42 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

2019 2018 Overall Consumption (m3) On Site Water Footprint (t CO2) 20.15 11.59

Office Water Footprint (t CO2) 2.40 2.20

Overall Water Footprint (t CO2) 22.55 13.79

2019 Lines of action to reduce water consumption: 2018

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL »»Awareness: in addition to the usual on-site training on the efficient use of re- 791,104 m3 132,275 m3 sources and the internal campaigns carried out in Spain and Mexico, in Colom- bia an awareness session was also held at a school in the area on the efficient use of water and the operation of the water treatment system linked to the Amagá Tunnel Consortium project (Colombia). As with the rest of the group’s resources, water consumption is closely linked to »Reuse of water: as indicated above, the Amagá Tunnel Consortium project in the number, type and progress phase of each project. The use of this particular » Colombia has a system for harvesting infiltration water that is subsequent- resource and its variation with respect to 2018 is conditioned by the reuse of ly reused in the tunnel excavation process, which has resulted in a total of water collected during the excavation process of the Amagá Tunnel in Colom- 700,061 m3 of water being reused for industrial purposes. Another example can bia. Specifically, a total of 700,0613 m of water has been reused for industrial be found at the GMN plant in Maials (Lleida) where rainwater and reused irri- processes. For this reason, and to facilitate comparison with respect to 2018 gation water have been used for the cooling system of the crushing machine. and future reports, it has been considered more appropriate to provide this data broken down between water consumed in corporate offices, where effective sav- »»Contamination prevention: Procedures to prevent contamination of groundwa- ing measures can be taken, and water consumption at construction sites, where ter are usually carried out during the development of projects, such as settling there is great variability from year to year. basins to prevent the deposition of solids in the water or covering the ground to prevent the infiltration of materials into the subsoil, thus preventing them From the moment it is extracted until the moment it reaches the user, mains wa- from reaching groundwater. ter has associated with it, among others, processes for harvesting, potabilisation

and distribution, whose treatment results in the emission of CO2 into the atmosphere. The water footprint allows us to know the emissions associated with this process.

43 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

Consumption of materials

The characteristics of the construction and industrial engineering sector imply a significant consumption of materials. However, the heterogeneity of each project, the fact that semi-finished materials are acquired, the different types of ac- quisition of the same material and the great variability that can be found within the same material make it difficult to account for them homogeneously.

Even so, the materials that represent a greater volume of consumption for COM- SA Corporación are concrete, in works, and paper, in offices. The consumption of these materials has been: 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL

2019 2018 Concrete (m3) 164,337.971 176,989.672 Overall: 27.58 (10.93% Overall: Data not available recycled) Paper (t) Spain: 12.52 (24.80% Spain: 19.42 (15.52% recycled paper: 3.1 t) recycled paper: 3.0 t)3

As far as paper consumption is concerned, the group is working to reduce its use through awareness campaigns such as those carried out in Spain and Mexico, as well as projects to digitalise documents in the Supplier Portal, among others.

»»To launch a project to register and quantify materials of recycled origin, as well as materials reused in its own projects or those of third parties. »»Where the use of paper is essential, the aim is OBJECTIVES to encourage the use of recycled or sustainably sourced paper.

Construction of a new wine cellar for the Peralada Group, Girona (Spain)

1 This figure includes the volume of concrete used in Spain. 2 This figure includes the volume of concrete used in Spain, Argentina, Brazil and Portugal. 3 The role of COMSA Auxiliary Solutions and COMSA Security is also included. 44 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

Energy consumption1

Energy is one of the main resources used by the group and is a key element for As can be seen in the table, fuel consumption, mainly linked to travel, continues the implementation and execution of its activities. to play a leading role in the group’s energy use. This consumption is strongly linked to the type of project and its location. Consumption of fuel: With regard to external2 energy consumption, the data come from sources outside COMSA Corporación that do not provide kWh or litres of fuel, but rather Petrol Diesel Km/mile travelled or directly associated CO2 emissions, which is why they are 2019 2018 2019 2018 shown in the following section. Fuel (GJ) 16,046 16,565 280,381 250,285 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL

Consumption of electrical energy:

Offices Works Promote the contracting of renewable energy for corporate centres. 2019 2018 2019 2018 Electricity (GJ) 20,669 18,203 20,269 16,013 OBJECTIVE

Overall energy consumption within the organisation:

Global Country 2019 2018 Fuel (GJ) 296,427 266,850

Electricity (GJ) 40,938 34,216

Overall Energy (GJ) 337,365 301,066

1 Fuel consumption data for 2018 have changed from the 2018 SNFI Report. See details in Annex I. 2 External energy consumption refers to that associated with business travel.

45 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

Some of the measures implemented in the group to reduce energy consumption In 2019, COMSA Renovables managed 263,868 MWh of ener- are: gy from renewable sources, the equivalent of a municipality with »»Energy efficiency certifications in 75% of the corporate offices in Spain. 204,000 inhabitants. »»Campaigns to raise staff awareness, such as the course on good environmental practices held in offices, which has a specific section on energy efficiency. »»Within the framework of the Mobility Plan, and with the aim of minimising fuel consumption, which is the main consumption of the organisation, the group promotes the rental and leasing of vehicles, prioritising those with lower consumption and greenhouse gas emissions. Thus in 2019 the electric and LPG

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL fleet has increased to a total of 25 vehicles, compared to 12 in 2018. »»Use of drones in some phases of the projects, thus optimising the movement of the technicians and reducing the associated emissions, while increasing pro- ductivity. »»In works, the group applies geothermal systems that allow taking advantage of the temperature of the subsoil in the cooling systems. An example of application of this technology is the one carried out in the new Warehouse of the Perelada Group (Spain). In this way, the building is more energy efficient in its operating phase, which means significant energy savings.

COMSA Corporación offers within its service portfolio solutions for the improvement of energy efficiency of its clients, thus promoting a more efficient use of energy. In addition to the hand of the Renewable Energy Business Area, it contributes to the development of the renewable sector, both in the design and construction phases, as well as in the management of various energy infrastructures, thus helping to guarantee universal access to sustainable energy.

LPG vehicles used in road maintenance contracts

46 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

CLIMATE CHANGE

COMSA Corporación is firmly committed to the fight against climate change Group emissions (t CO2 eq) and, to this end, works to reduce the greenhouse gas emissions generated by its activity. The group’s strategy is based on proper management of direct emissions and fossil fuels, prioritising the use of renewable resources, energy saving and efficiency, as well as sustainable mobility.

Scope 1 Scope 2 Scope 3 TOTAL 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL Development of the group’s Strategic Plan to face cli- Fuels Electricity Corporate Travel and Water mate change 2030-2050, establishing reduction per- centages for each of the Scopes. 2019 19,020.68 2,311.56 2,792.32 24,124.56 OBJECTIVE 2018 17,158.02 2,809.21 2,219.66 22,186.89

Greenhouse gases

As part of COMSA Corporación’s commitment to reduce greenhouse gas emis- Emission intensity in relation to turnover1: sions, in 2019, the group joined the #PorElClima Community, a pioneering multi-player initiative for action against climate change, in accordance with the Scope 1 Scope 2 Scope 3 Total guidelines set out in the Paris Agreement. In this line, since 2018 the group has published its emissions annually in the CDP Disclosure Insight Action. 2019 24.48 2.97 3.59 31.05

2018 23.38 3.83 3.02 30.23 COMSA Corporación performs the calculation of greenhouse gas emissions and reports scope 1, 2 and 3 of such emissions. Scope 3 includes emissions associated with corporate travel as well as emissions associated with mains water treatment (water footprint).

1 A turnover of 734 million euros in 2018 and 777 million euros in 2019 are considered for the calculation of the intensity.

47 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

To help achieve SDG 13 – Climate Action, the group is working on the implementation of measures throughout its value chain, thus promoting the development of its collaborators in this field:

»»Mechanisms to offset emissions associated with business travel (Scope 3) through reforestation projects have begun to be explored with travel suppliers. »»Suppliers that incorporate green energy into their facilities, as well as those who have energy efficiency certifications for their facilities or services, are given higher scores in tenders. »»With some suppliers, the group provides support so that they can make im-

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL provements that will reduce their emissions.

Obtain certification of the carbon footprint of scope 1 and 2 for Spain.

OBJECTIVE

Maintenance of photovoltaic panels, Tarragona (Spain)

48 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

APPLICATION OF SUSTAINABLE CONSTRUCTION STANDARDS

COMSA Corporación also contributes to mitigating the effects of greenhouse gas emissions by implementing policies related to the application of sustainable construction standards.

In 2019, 12 projects were implemented with energy efficiency certifications: LEED and BREEAM. 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL These certifications provide a complete framework for evaluating water, energy and material selection efficiency, which ensures better indoor air quality, as well as more comfortable and safe lighting and noise levels for users. As a result, these buildings use fewer resources, have lower maintenance costs, show a greater commitment to sustainability and offer safer environments.

Some of the highlights in this area are:

»»In 2019, 12 energy-certified projects were executed, including the Barcelona Office Building Project in Barcelona’s Barrio 22@, which achieved the highest LEED certification score in the world. »»75% of the corporate centres have ISO 50.001 or BREEAM energy certification.

75% of corporate centres have energy certification.

The energy audits of buildings can define the actions to be carried out to optimise the performance of air conditioning (heating and cooling), improve thermal insulation, efficiency in lighting and automation of facilities associated with them. Barcelonesa Real Estate headquarter in the 22 @ neighborhood, Barcelona (Spain)

49 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

PROTECTION OF BIODIVERSITY

The activities carried out by COMSA Corporación may affect the natural environ- Below are some of the actions highlighted in 2019 regarding the protection of ment where the work projects are executed. For that reason, the group works biodiversity in the territory where the group operates: to minimise its impact on biodiversity, especially when its activity takes place in protected areas or areas of high ecological value. Fauna: »»Murcia (Spain): separation of native species from invasive ones, helping to During the execution of the work in the field, if new significant impacts on the re-establish the natural balance of the ecosystem when moving a raft, in the environment are identified, the group proceeds to modify the project, as far as Reguerón joint venture. possible, implementing the best available techniques and relevant measures to reduce or minimise such impact. »»Salamanca (Spain): landscape integration of the wildlife passage on the Castil-

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL la A-62 highway to make the passage more accessible to the fauna of the area. In the event that this impact cannot be avoided or mitigated completely, as a »»Vizcaya (Spain): restoration and cleaning of slopes in the Cadagua River basin, fundamental part of the project planning phase, compensatory measures for the thus facilitating access for the European mink (in danger of extinction) to food, conservation of flora and fauna are carried out. These measures are based on the shelter and communication between adjacent hydrographic areas, within the physical protection, transplantation or transfer, as well as on the respect of the framework of the Emergency Works project of the Iberian Wide Conventional life cycles of the plant and animal species that may be affected by the execution Network. of the work. Another of the measures carried out in areas of special landscape interest is training for personnel in the correct handling of wild flora and fauna, »»Huesca (Spain): installation of a mesh to avoid the risk of entry of small ver- such as those that took place in the Pacific Highway project in Colombia. tebrates, amphibians and micromammals in the A-21 Jaca highway work. In addition, a feeding trough for necrophagous birds has been built and anti-bird screens have been installed to reduce bird collisions with vehicles. »»Spain, different locations: replacement of conventional insulation in electrical installations to avoid possible effects on birds, as well as the installation of nest boxes.

Flora: »»Cordillera Central mountain range (Colombia): carrying out rescue, transfer and relocation activities for species the hunting of which is banned (terrestrial and vascular epiphytes) located in the project’s intervention area.

Project for the rescue, transfer and relocation of endangered species (terrestrial and vascular epiphytes), Cordillera Central mountain range (Colombia).

50 ENVIRONMENTAL WASTE GENERATION AND SUSTAINABLE USE OF CHANGE SUSTAINABLE OTHER ENVIRONMENTAL INNOVATION BIODIVERSITY CONTRIBUTION CIRCULAR ECONOMY RESOURCES CLIMATE CONSTRUCTION IMPACTS MANAGEMENT

ENVIRONMENTAL CONTRIBUTION

OTHER ENVIRONMENTAL IMPACTS

Noise pollution Light pollution

COMSA Corporación is aware of the acoustic impact caused by the activities it COMSA Corporación carries out Environmental Monitoring Plans in all its pro- carries out, especially by the use of heavy machinery in its projects. jects that determine the preventive measures to be adopted to mitigate the impacts of light pollution. The activities that generate a greater impact in this During the execution of construction works, the group maintains time limitations sense are those works carried out at night, as well as the exterior lighting of the for work with noise-generating equipment. Work in urban areas is carried out at workplaces. the times established by each region, and noise screens are installed along roads and railway lines to protect the immediate environment from noise generated by In order to minimise these impacts, various measures have been implemented, 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL machinery and vehicles. In the case of transport infrastructure works, in many among which the following can be highlighted: cases the work must be done at night to minimise the impact on the mobility of the population, especially in densely populated urban areas. »»Replacement of exterior lights with others of greater efficiency (LED). »»Use of environmentally-friendly night-time lighting devices on sites with night- In order to minimise these impacts, various measures have been implemented, time opening hours. among which the following can be highlighted: »»Installation of presence detectors and timers to ensure minimum use of lighting. »»Noise monitoring systems in urban areas or areas of special interest. »»Replacement of machinery with the highest noise emission. »»Installation of acoustic screens in the areas with the highest emissions. Particle pollution »»Protection of workers with specific equipment. The group works to avoid environmental pollution, especially when working with One of the initiatives highlighted in 2019 in this area was the installation of stands materials that can be released into the atmosphere, such as soil, aggregates and for the generators, especially in urban projects, to avoid noise pollution. rubble. Accordingly, the group has implemented different measures, such as:

»»Tarpaulin covering for lorries to prevent the spread of particles during transport. »»Watering of surfaces to avoid the volatilisation of particles.

Additionally, in episodes of high particulate matter pollution, some activities are temporarily stopped to avoid increasing the levels of suspended solids pollution.

51 ENVIRONMENTAL INNOVATION CONTRIBUTION MANAGEMENT

INNOVATION MANAGEMENT

THE COMMITMENT TO INNOVATION AT COMSA CORPORACIÓN

COMSA Corporación has had a certified Management System in R+D+i in place according to the UNE 16602 standard since 2007.

COMSA Corporación considers innovation as a differential factor of maximum added value for its clients, integrating it as one of the fundamental pillars of its business culture and corporate values since its foundation, more than 125 years ago. 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL

In line with this commitment, COMSA Corporación continues to develop advanced technological projects aimed at obtaining value, promoting a culture of innovation and the creation of competitive advantages and fruitful collaborations with clients and other agents in the scientific ecosystem.

Thanks to this approach, COMSA Corporación manages to incorporate all business units to the innovative process, which ensures a successful exploitation of results, both internally and in direct marketing.

Currently, COMSA Corporación has 35 innovation projects in progress, of which five started in 2019. In total, R&D&I activities and projects worth over 7 million euros were carried out in 2019.

Application of the BIM methodology in the Generalitat de Catalunya Campus, Barcelona (Spain)

52 ENVIRONMENTAL INNOVATION PROJECTS COLLABORATIONS CONTRIBUTION MANAGEMENT

INNOVATION MANAGEMENT

Most notable projects in progress

National level European level Railway »»RESILTRACK: Railway infrastructures resilient to the effects of »»S-CODE: Design to reduce the composition of the structures that climate change. allow changing track. »»SWITCHES: Optimisation of maintenance of structures for track »»BALLAXT: New artificial ballast from 3D printing. switches. »»NEOBALLAST: The ballast is lined with recycled rubber to extend the »»RECOVER: Comprehensive sustainable anti-pollution treatments life of the railways. and creation of green railway corridors. »»BIRBALAS: Development of ballast products from metallurgical slag. 3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL Air navigation and »»INMA: Remote management system for air navigation assistance »»5G-PICTURE: Converged infrastructures that integrate advanced communications systems. wireless solutions and innovative network solutions. PRL »»BIMIÓTICA: Control of protection devices through image detection. Digitalisation »»BIMTable: Virtual construction before the execution of the work. »»SPHERE: Digital Twin for building construction and maintenance. Civil Works »»PAVIRE: Analysis of data generated by users during driving, for »»GEOFIT: Integration of geothermal energy generation in building improvements in maintenance, sustainability and safety of the rehabilitation. infrastructure. »»ROADZ: System for the illumination of road signs from the energy generated by the passage of vehicles.. »»ALBEPAV: Creation of high performance asphalt from the reuse of recycled glass aggregate. Building and Smart »»REFER: Energy reduction and flexibility in building »»LIFE BIPV: Building Integrated Photovoltaic. Buildings rehabilitation. »»BIPVBOOST: Cost reduction of BIPV solutions. »»BIMTable: Virtual construction before the execution of the work. »»DRIVE: Improving the energy efficiency of buildings. »»INSPECTOR: Maintenance of installations by means of drones. »»GEOTECH: Renewable heating and cooling system that, through an innovative system of perforation and heat exchange with the floor, allows application in the housing sector. »»HYBUILD: Hybrid electric and thermal storage systems that guarantee thermal comfort for buildings in both Mediterranean and continental climates.

53 ENVIRONMENTAL INNOVATION PROJECTS COLLABORATIONS CONTRIBUTION MANAGEMENT

INNOVATION MANAGEMENT

Below are some of these projects executed during 2019.

INNOVATION IN INFRASTRUCTURE MAINTENANCE NEW MATERIALS

The impact of the consumption of construction materials on the environment Within the framework of COMSA Corporación’s commitment to the environment, translates into the need to extend the useful life of infrastructures and, con- the development of new sustainable products is another of the fundamental pil- sequently, into a determined commitment to intelligent and effective mainte- lars of the group’s commitment to innovation. These new product developments nance that eliminates the over-exploitation of natural resources related to the must always meet a double requirement: use recycled materials and provide ad- reinforcement of their durability. vanced performance.

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL It is also essential to ensure that infrastructures are resilient to the effects of Currently, the contamination associated with trains on external and underground climate change, an area in which COMSA Corporación contributes by making in- railways is very important and its effects are very worrying, since during the frastructures resilient, as one of the main objectives of its portfolio of innovation circulation of these trains, heavy metals and hydrocarbons are released, which projects dedicated to predictive maintenance. represents a toxic risk for health and the environment. Although this is a significant problem identified by the Member States of the European Union, very little In this regard, the RESILTRACK project stands out. Its objective is to design a has been studied to date. system that allows knowing the state of the railway infrastructure and its effect with respect to adverse climatic phenomena in real time, as well as to foresee its In this sense, the RECOVER project, in which COMSA Corporación is partici- behaviour in order to act where it is necessary, thus obtaining resilient railway pating, aims to create Green Railway Corridors by eliminating or mitigating the infrastructures in the face of the effects of climate change. pollution associated with the operation of these infrastructures. The aim is to generate a zone free of the pollution associated with the movement of trains on This project, promoted by a group of companies led by COMSA Corporación, railways and their surroundings that will allow an environmental improvement of was executed thanks to the financing of the Centre for the Development of In- the tracks themselves and their surrounding area. dustrial Technology as an organisation attached to the Ministry of Science and Innovation. The RECOVER Project is financed by the European Regional Development Fund (ERDF) through the Ministry of Economic Affairs and Digital Transformation.

Rail yard expansion of high-speed train at the base of Santa Catalina, Madrid (Spain)

54 ENVIRONMENTAL INNOVATION PROJECTS COLLABORATIONS CONTRIBUTION MANAGEMENT

INNOVATION MANAGEMENT

INNOVATION AND ENERGY EFFICIENCY DIGITALISATION

Another priority area for innovation in COMSA Corporación is energy efficien- Undoubtedly, digitalisation is one of the fundamental areas for boosting innova- cy. The group is aware that, in order to reduce polluting emissions and energy tion projects and accompanies most of them during their development. expenditure, one must start by exploiting resources and adapting facilities. In- formation and communication technologies, as well as the implementation of Likewise, the exponential growth of mobile Internet traffic introduces the need intelligent networks, are key to achieving this scenario. The “Demand-Response” to transform traditional closed, static and inelastic network infrastructures into aspect is decisive for energy automation, with flexible and distributed genera- open, scalable and flexible ecosystems that support new types of connectivity, tion being a necessary tool for sustainable development and efficient energy high mobility and new services. Responding to this new need, the 5G-PICTURE management in buildings. project will develop and demonstrate a converged infrastructure that integrates advanced wireless solutions and novel network solutions. This will enable the

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL The REFER project aims to improve the energy alternatives available for build- provisioning of any service across the infrastructure through the flexible and ings, providing them with flexibility with various options for energy generation. efficient combination of network, computing and storage resources. Taking into account the great challenge of improving the energy efficiency of existing buildings -not so much in new buildings where it is easier to incorporate The results of the project will provide operational services on mobile telecom- new technologies and knowledge-, the REFER project takes both points of view munications networks and will be applicable, inter alia, to the management of and focuses on the energy and flexible rehabilitation of residential and tertiary railway infrastructures. The 5G-PICTURE project is part of the European Union’s buildings separately. Horizon 2020 programme for research and innovation.

REFER is financed by the European Regional Development Fund through ACCIÓ, the Catalan Government’s agency for business competitiveness, attached to the Department of Enterprise and Knowledge.

55 ENVIRONMENTAL INNOVATION PROJECTS COLLABORATIONS CONTRIBUTION MANAGEMENT

INNOVATION MANAGEMENT

CORPORATE VENTURING NEW CONSTRUCTION METHODS

During 2018, COMSA Corporación presented The InnCom Challenge, an initia- COMSA Corporación innovates in the design of projects by integrating the use of tive that aims to support the development of companies with solutions based BIM technology, which allows “building before you build”, i.e., to build virtually on emerging technologies applied to the fields of digitalisation of construction before the work is executed. and maintenance of infrastructure, or specialised in improving services related to energy efficiency in the management of facilities. To this end, the group created its own BIM Unit years ago and has designed the BIMTable, a tool that allows projects to be monitored in situ in a collaborative »»Within the framework of this initiative, it is worth highlighting the promotion of environment and which was presented in 2018 at the BIMExpo fair in Madrid, the FINALCAD project, which has developed an application that allows for the generating great expectation. efficient management of infrastructure and construction projects. It consists of

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL a digital platform for collaborative work that integrates all the components of In 2019, 20 projects were implemented using BIM methodology, including the the project in real time. rehabilitation of the Garraf Tunnel for Adif and the Johan Cruyff Stadium for FC »»Likewise, it is worth mentioning the collaboration with SAALG Geomechanics, Barcelona. a Spanish startup specialised in the analysis of geotechnical instrumentation data in real time to minimise risk, save time and maximise the profitability of On the other hand, and within the framework of the commitment to environmental the work. sustainability in the application of construction methodologies, BIGEO (Building- Integrated Geothermal System) technology has been integrated as an innovative Other selected projects were: solution for the generation of renewable geothermal energy installed in buildings, whose geothermal exchangers are embedded in elements of the foundations »»Allread (Spain): development of computer vision software that detects, reads themselves. and processes any type of text or symbol that appears in industrial processes. »»Constru (Israel): platform that uses AI to optimise the inspection and analysis of the construction process. »»Infrakit (Finland): platform for real-time monitoring of construction sites.

In this same area, COMSA Corporación reinforces its commitment to digital transformation and open innovation through a collaboration agreement with the Mobile World Capital Foundation’s The Collider programme. Within the framework of this agreement, the Smart Tower startup has been set up to market remote monitoring services for electric towers and other infrastructures.

56 ENVIRONMENTAL INNOVATION PROJECTS COLLABORATIONS CONTRIBUTION MANAGEMENT

INNOVATION MANAGEMENT

COLLABORATION AND PARTICIPATION IN SECTORAL ASSOCIATIONS AND FORUMS

The group collaborates with sectoral and other more specialised entities to pro- Likewise, COMSA Corporación encourages participation in forums and meeting mote the development of the sector, among which the following stand out: spaces with other companies, in order to jointly advance in the promotion of innovation. Construction field: »»Association of Infrastructure Construction and Concession Companies (SEO- »»UIC Workshop on Noise and Vibration (Paris). COMSA Corporación attended PAN) to present Neoballast as an effective technology against noise and vibration in »»Spanish Construction Technology Platform (PTEC) the railway. »»Expo Rail Mexico 19 (Mexico City). The group was present at Expo Rail Mexico Railway field:

3. ENVIRONMENTAL SPHERE 3. ENVIRONMENTAL 19, the main fair of the Mexican railway industry, organised by the Association »Spanish Railway Association (MAFEX) » of Mexican Railways, where information about Neoballast technology was also »Spanish Railway Technology Platform (PTFE) » shared. »»Railgrup »»IABSE Symposium 2019 (Guimarães). The symposium aimed to provide an in- Energy efficiency: ternational forum for the discussion of issues related to sustainability in the »»Catalonia Energy Efficiency Cluster (CEEC) construction sector, risk assessment and asset management in infrastructure, »»Agency for Enterprise Competitiveness, RIS3CAT energy project among other topics. Within this framework, COMSA presented the RESIL- »»Energy Efficient Buildings (E2B) TRACK project, an intelligent and resilient system for the predictive maintenance of railway infrastructures.

Neoballast field test section between Maçanet-Massanes and Caldes de Malavella section, Girona (Spain)

57 SOCIAL SPHERE COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

COMSA CORPORACIÓN TEAM

For COMSA Corporación, human capital is the greatest asset for the creation of Within the framework of the COMStruimos Plan, in 2019 the basic competence value and implies the guarantee of success in all the projects in which it contrib- map and the description of all the job positions were reviewed, and the perfor- utes. In this regard, the group has a strong commitment to SDG 8 - Decent Work mance evaluation model was reviewed and defined, which at the same time was and Economic Growth, as well as SDG 3 - Good Health and Well-being, SDG 4 - systematised and digitalised, with the aim of professionalising and improving Quality Education, SDG 5 - Gender Equality and SDG 10 - Reduced Inequalities. the efficiency of talent management. The group has also planned a review of the remuneration policy for this year and has set the long-term objective of drawing 4. SOCIAL SPHERE On this basis, the group offers inclusive, safe, healthy and non-discriminatory up succession plans for strategic positions. working environments where everyone can grow and develop their career, and where talent, professionalism and performance are the success factors. In the field of risk management, COMSA Corporación’s risk map identifies and evaluates significant risks in the area of people management. In this respect, the COMSA Corporación expresses its commitment to its professionals in the Human materialisation of labour accidents and the lack of talent retention were iden- Resources Policy. In 2018, the group also launched the COMStruimos Plan. This tified as significant risks. Both risks have been prioritised historically and have is part of the Human Resources Strategic Plan, which incorporates the lines of independent structures, which analyse, establish and implement specific policies comprehensive management of human capital and has a three-year horizon. and procedures in this regard to create interdependent teams as a model of leadership.

COMStruimos PLAN LINES OF ACTION:

1. Review of the basic competence map. 2. Review of the remuneration policy, based on internal equity and external competitiveness. 3. Review and digitalisation of the performance evaluation model. 4. Updating the group’s talent map. 5. Drafting of succession plans for strategic positions.

Project meeting at the corporate headquarters (Spain)

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HUMAN CAPITAL1

The COMSA Corporación team is structured around the principles of business The cross-cutting and global strategy of the group requires a diverse team inte- culture. Thus, based on the mission and vision of the group, the shared value of grated by different professional profiles that generate wealth and prosperity in offering integrated infrastructure projects, industrial engineering, maintenance all geographical areas where COMSA Corporación operates. An example of this 2

4. SOCIAL SPHERE and services, and development and concession of environmental infrastructures, commitment is that almost all senior positions are covered by local staff, and in always under the principles of professionalism, quality and innovation, driving in- 92.7% of cases (95.8% in 2018). ternational growth, and thus supporting the economic, technological and social progress of the countries where it carries on its activity.

Distribution of employees by geographical area Distribution of employees by gender

2019 2018 2019 2018

3,393 81% Spain 3.013 63% Spain 893 21% Women 634 13% Women 603 14% LATAM 1,594 33% LATAM 3,312 79% Men 4,165 87% Men 209 5% Rest and EMEA 192 4% Rest and EMEA 4,205 TOTAL 4,799 TOTAL

1 Unless otherwise specified, all figures, tables and comparisons in this section refer to the countries and businesses included in the scope of this report. 2 The senior positions include: Directors, Delegates, Managers, Area Heads and Department Heads. 60 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

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People management indicators reflect some of the characteristics of the con- Distribution of the workforce by age struction and industrial engineering sector. One of them is the temporary nature of the projects and their relocation, understood as a productive model in a discontinuous geographical environment in the short term, which significantly conditions the form of job creation, both in terms of the hiring modality and its temporary duration. However, COMSA Corporación is committed to the creation 4. SOCIAL SPHERE of quality employment that contributes to the development of the communities 2019 in which it operates, which is why, globally, in 2019, 76% of the contracts were permanent, and 89% of them were full-time. women men

74 8% <30 348 11% <30 564 63% 30-50 2,039 62% 30-50 255 29% >50 925 28% >50

893 TOTAL 3,312 TOTAL

2018 women men

95 15% <30 540 13% <30 466 74% 30-50 2,662 64% 30-50 73 11% >50 963 23% >50

634 TOTAL 4,165 TOTAL Construction of two access tunnels to the E4 motorway, Stockholm (Sweden)

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Type of contract by gender 4. SOCIAL SPHERE 2019 women men TOTAL

688 77% Indefinite 2,492 75% Indefinite 3,180 76% Indefinite 205 23% Temporary 820 25% Temporary 1,025 24% Temporary

893 TOTAL 3,312 TOTAL 4,205 TOTAL

2018 women men TOTAL

501 79% Indefinite 2,414 58% Indefinite 2,915 61% Indefinite 133 21% Temporary 1,751 42% Temporary 1,884 39% Temporary

634 TOTAL 4,165 TOTAL 4,799 TOTAL Intelligent Traffic Systems (ITS) in the Bogotá - Villavicencio Corridor (Colombia)

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Type of contract by type of workday and gender 4. SOCIAL SPHERE 2019 women men TOTAL

514 58% full time 3,228 97% full time 3,742 89% full time 379 42% part time 84 3% part time 463 11% part time

893 TOTAL 3,312 TOTAL 4,205 TOTAL

2018 women men TOTAL

489 77% full time 4,083 98% full time 4,572 95% full time 145 23% part time 82 2% part time 227 5% part time

634 TOTAL 4,165 TOTAL 4,799 TOTAL

Cleaning work carried out by COMSA Solutions

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TURNOVER

The seasonality of operations in a given region also affects the need to adjust Notwithstanding the above, COMSA Corporación maintains a clear commitment contracts, with the aim of adapting to the productive and organisational reality to job creation in all the areas in which it carries on its activities. As a result of of different businesses and projects. this commitment, the group has made 1,504 additions to its workforce, the distribution of which can be seen in the table below: 4. SOCIAL SPHERE Thus, employees turnover is highly conditioned by two fundamental factors: Number of new hires »»Firstly, many of the projects are carried out in dispersed geographical areas, which means that at the end of these projects the continuity of a large number Age under 30 30 - 50 over 50 of the employees assigned to the contract is highly conditioned by contracts ending. The impact of this type of leave on the workforce, for the group as a Gender Women Men Women Men Women Men Total whole, translated into 1,261 people leaving the group, 55.3% of the total number 2019 81 293 168 723 61 178 1,504 of employees who left in 2019. 2018 89 612 122 1.068 9 236 2,136 »»Secondly, some types of service contracts mean that, in order to guarantee clients the best conditions and continuity of the service, the group subrogates In order to analyse and improve the conditions of employment, the project of personnel with extensive experience and knowledge of the type of work to be follow-up interviews for new recruits was launched in 2019. This practice has carried out. This same process, in the opposite direction, occurs in cases where been fully implemented in COMSA Corporación and partially in the rest of the one of the group companies ceases to provide a contract of this type, and the group. The interviews are carried out three months after hiring and consist of personnel assigned to it is subrogated by COMSA Corporación which takes personal interviews with the new hire and their manager to obtain a general over the service. The impact of this type of leave on COMSA Corporación’s assessment of these three months, their perceptions, fulfilment of initial expec- employees can be seen in the example of Peru for 2019, with a total of 1,143 em- tations and proposals for improvement. ployees leaving by their own free will or because their contracts ended (more than 50% of the group’s total in 2019), due to these types of circumstances. Likewise, in 2019 the process of leave interviews began, which consists of a questionnaire and a subsequent interview with Human Resources by the person In this sense, and taking into account the factors mentioned above, the ratio who leaves the group voluntarily. of personnel turnover, without considering contract terminations and without including the case of Peru, due to the above-mentioned cases, is 12.79%. In the case of Spain, the rotation due to voluntary leave of personnel is 7.25%. To publicise job vacancies internally and to implement In turn, the termination of employees contracts for non-voluntary reasons has the On Boarding project, the welcome programme for been the result of specific needs for adjustments to the reality of production and new recruits. organisational conditions in the various group companies. OBJECTIVE

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REMUNERATION

COMSA Corporación publishes the remuneration of the Board of Directors annu- »»Flexible remuneration: Depending on the country, the group offers its employ- ally in the management report, in accordance with the group’s commitment to ees the possibility of modifying their remuneration package, on a voluntary ba- transparency and equality. sis, replacing part of it with products or services, so that the employees have a

4. SOCIAL SPHERE remuneration that is optimised to their needs. Through this option it is possible The amount accrued in 2019 by the current members of the Board of Directors to acquire transport passes, subsistence allowances, medical or life insurance, in respect of all remuneration items (salaries, gratuities, per diems and remuner- as well as pay for nurseries and training programmes. ation in kind) amounted to 796 thousand euros. As mentioned above, COMSA Corporación is committed to the creation of quali- The group determines the remuneration on the basis of the salary structure laid ty employment that contributes to the development of the communities in which down in the applicable collective agreements, which are generally composed it operates. In this regard, in 2019, the ratio between the salary that COMSA Cor- of basic salary, seniority and additional bonuses related to specific conditions, poración’s workers initially receive and the minimum salary in each of the coun- quality and/or quantity of work. tries in which the group operates is 1.43 on average, compared with 1.28 in 2018. It should be noted that there are countries where this ratio is not comparable. COMSA Corporación’s remuneration model is made up of:

»»Fixed salary: Corresponding to the professional category, the collective agreement and the country. »»Variable remuneration: In some countries, depending on the responsibilities of the employees, and their category1, in addition to the fixed salary, they receive a variable that is made up of three parts:

»»Achievement of the group’s general objectives. »»Achievement of the objectives of the unit, company or country. »»Individual worker performance.

In 2018, 83% of the workforce in Spain received this type of remuneration, while in 2019, 74% of the workforce in Spain, Argentina, Brazil, France, Mexico and Peru had access to this type of remuneration and their performance was formally evaluated and reported.

Night works on the railway track, Caldes de Malavella (Spain)

1 Employees from the administrative category.

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Gender Pay gap by category 2019

2019 Annual compensation ratio Age Category 1 y 2 Category 3 Category 4 Category 5 4. SOCIAL SPHERE

under 30 NA1 5.58 % -8.31 % -18.97 % 13.632 9.763 30-50 10.38 % 13.62 % 14.47 % 18.08 %

over 50 -9.88 % 30.31 % 20.01 % 24.17 % 2019 2018

The calculation of the gender pay gap presents a similar problem to that of aver- The annual compensation ratio for 2019 is obtained from the fixed gross annual age salaries, since the presence of the group in highly differentiated geograph- salary plus the variable compensation, while in 2018 it was obtained only from ical areas makes the results obtained unrepresentative. As an example of this the gross annual salary, the main reason for the difference between the values diversity, for category 3 corresponding to Site Managers and Unit Managers, very obtained. different realities are compared both in terms of geographical areas and areas of responsibility, and even labour market and activity situations. In this sense, the pay gap for this category in the 50+ age group in Spain is 12.13%. DEVELOPMENT OF THE SKILLS MAP

In 2019, the Success Factors project was launched, with training and implementation in early 2020. Success Factors is a tool that allows an evaluation of the employee’s performance, taking into consideration group and specific objectives, To review the remuneration policy, working on the as well as the person’s competence. This tool will facilitate the development of a definition of salary bands by function, internal equity competence map in the organisation. and with respect to the market of the 25 key positions OBJECTIVE of the group.

1 It is not possible to indicate the Gender Pay gap for this category and age range due to personal data protection policy. 2 The calculation includes the fixed salary and the variable remuneration. 3 The calculation only includes the fixed salary. 66 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

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TRAINING

Talent is an indisputable value within COMSA Corporación, and this has been Average training hours per gender highlighted in the COMStruimos Strategic Plan. In this sense, not only is it necessary to identify talent in the selection of new hires, but it is also fundamental to

4. SOCIAL SPHERE promote the growth and professional development of all the people who form part of the group. This aspect is one of the most relevant elements to attract and retain talent within the organisation. 18.5h 11.7h 15.6h 19.1h In this line, in 2019 a total of 62,175 hours of training were given, both in person and through the online or “e-learning” platform, which favours the implementation and organisation of training courses.

The “e-learning” platform operates on an intuitive and visual basis, which has women men women men made it possible to increase the number of training courses per worker. Moreo- ver, thanks to the flexibility provided by distance learning, professionals are free 2019 2018 to organise themselves to complete the training when it least interferes with their work tasks and personal life.

Total investment Total training hours

2019 590,391 € 2019 62,175 h 2018 575,619 € 2018 89,185 h

20.000 40.000 60.000 80.000

Training of workers in the Maintenance of Metro Madrid (Spain)

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Most of the training courses held in 2019 were specific to the knowledge and skills required for each job, training in occupational risk prevention and safe- »»Carry out plans to develop basic skills by area based ty, languages, certifications and their requirements, personnel management and on the competence map resulting from the perfor- updates of regulations and procedures. mance evaluation (Success Factors). »»Share the job description with the competence as- In 2019 the group collaborated with external training centres to carry out the OBJETIVO 4. SOCIAL SPHERE sociated with all positions within the organisation to following training: identify the skills needed to access the various positions. »»Training for Health and Safety inspectors in Construction Works, in collaboration with the Construction Labour Foundation. »»Collaboration in the Training of Internal Auditors in Occupational Risk Pre- vention carried out by the INSST (National Institute for Safety and Health at Work). »»Training in technical and legal solutions for prevention technicians, in collaboration with AJP Asesoría Jurídica Y Prevención. »»Conference on Innovation in Construction, Màster d’Enginyeria de la Construc- ció de l’Universitat Politècnica de Catalunya.

In addition, COMSA Corporación has launched the 2019-2020 Leadership Pro- gramme to work on the collective leadership of the organisation, which has begun with the completion of a Collective Leadership Survey of managers based on the international standard called ‘The Leadership Circle’.

In addition, at EOLIS , due to the generational change it is facing, the “Eolis University” has been implemented to encourage the transmission of knowledge from experienced personnel in COMSA Corporación to new personnel, thus contributing to their training.

Presence in Human Resources Forums

In 2019 COMSA Corporación participated in the 4th edition of the Human Factor Congress in Barcelona organised by International Faculty for Executives. During the congress, business strategy, training in emotional and relational skills, and support for employees on a personal and professional level, among other topics,

were discussed. During the congress, the group participated in a round table Training to prevent musculoskeletal disorders in the framework of the campaign “Don’t turn your discussion on how emotions and the integral well-being of teams are key to back on overexertion” (Spain) achieving business success.

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EQUALITY

Equal opportunities, non-discrimination, decent work and respect for human In this sense, COMSA Corporación has established policies and actions that fa- rights are fundamental principles in the promotion and professional develop- vour work-life balance, flexibility and disconnection, in the context of the differ- ment of COMSA Corporación, as established in the group’s Code of Ethics. These ent realities and organisational needs of the different work centres. Some exam-

4. SOCIAL SPHERE principles are shared through the specific training and information processes ples of these measures adopted in Spain are: that are systematically carried out on the employees. »»Flexible office entry and departure times. However, the gender distribution in most professional categories is strongly mas- »»Intensive working day on Fridays all year round. culinised due to the strong link to physical strength that has historically prevailed »»Continuous working day in summer periods. in the sector. The incorporation of women into the construction and engineering »»Flexibility in the choice of holiday periods, as well as extension of the period sector has taken place, above all, in recent years. beyond the calendar year.

The 2019-2023 Equality Plan is the instrument used by the group to guarantee equality between women and men, including enforceable and applicable meas- Paternity or maternity leave requested ures, in line with SDG 5 - Gender Equality. This document sets out the measures carried out to promote the progressive increase of the number of women in the group. Among them, one measure stands out, which establishes that, in the face of equal conditions between candidates, priority should be given to the recruit- ment or promotion of women. 2019 2018 The commitment to equal opportunities goes beyond the labour level, since the group understands that the organisation of employment must also favour this equality on a personal and family level, enhancing, in addition, the well-being of the employees.

120 176 Approved permits Approved permits 23% Women 19% Women 77% Men 81% Men

With regard to paternity or maternity leave, the group, as provided for in the regulations, accepts all applications received.

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In addition, as mentioned above, employees have other advantages in this regard Disconnection Policy such as the option of childcare as part of the flexible compensation plan. On the other hand, regarding the right to digital disconnection, COMSA Corpo- In addition, COMSA Corporación has been working on updating the Protocol for ración recognises it as a key factor in respecting personal and family life. In this the Prevention of Psychological, Sexual and Gender-based Harassment, which regard, in 2019 the group approved a Disconnection Policy which aims to es- was revised at the beginning of 2020. The objective of this protocol is to prevent tablish the general guidelines that regulate the right of employees to be digitally 4. SOCIAL SPHERE and, where appropriate, punish all conduct that violates the dignity, equality and disconnected, except in positions whose obligations or responsibilities cannot moral and sexual freedom of any person who is a member of the group. This pro- be postponed due to the position held. Some of the lines of work to favour this tocol establishes the complaint channels, guaranteeing confidentiality through- digital disconnection are aimed at the use of collaborative work environments, in out the process. In 2019, there were no complaints in this area. which the sharing of information between the different members of a work team does not make it essential to interconnect between them. During this year, the organisation of the Workshop on Induction, Prevention and Response to Sexual and Gender-based Violence, held by the Office in Peru of the United Nations High Commissioner for Refugees (UNHCR) in Lima, and attended by 12 employees members, is noteworthy.

To increase business commitment to gender diversity through partnerships and training and awareness campaigns in this area. OBJECTIVE

Transfer terminal in offices (Spain)

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INCLUSION AND DIVERSITY

COMSA Corporación promotes the inclusion and diversity of its employees from Likewise, the group has implemented policies and procedures for the incorpora- the certainty that individual talent and the different ways of interpreting and tion of people with difficulties in accessing employment, materialised in different understanding each of the people who make up its team enrich the actions they projects. Chief among these initiatives is the hiring of women at risk of exclusion

4. SOCIAL SPHERE carry out on a daily basis, and have a positive impact both on their professional for the BR-101 road Duplication project in Alagoas, Brazil. environment, on the team and their clients, and on the personal sphere. With regard to groups with functional diversity, the group prioritises internal Beyond compliance with the guiding principles of the Code of Ethics regarding hiring, except in cases where this is not possible due to the types of tasks to be non-discrimination and equal opportunities, COMSA Corporación is firmly com- performed, and such hiring is done indirectly through special employment cen- mitted to incorporating local personnel in the projects it executes, thus contrib- tres or donations to them, in order to promote the labour integration of these uting to the economic development of the communities where it operates. In workers. 2019, local employees accounted for 93% of COMSA Corporación’s total, compared with 84% in 2018.

Within this framework, in 2019 the group’s participation in university forums to attract young talent stands out, where, in parallel, 15 interns were hired in Spain.

Construction team made up of more than 11 different nationalities, Odense Tramway (Denmark)

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CORPORATE DIALOGUE

Stable and transparent communication with workers is essential for the proper Due to the nature and location of the group’s activities, different collective performance of the group. agreements apply in COMSA Corporación. In all countries where the group is present, it complies with the respective collective agreements that establish spe-

4. SOCIAL SPHERE To guarantee this aspect, there are various channels, such as formal and informal cific regulations in the field of occupational health and safety. meetings, works councils, e-mail, the website, intranet and the corporate port- let (portal), which is an internal news and communications portal where specific content and information is published for the employees. Some of these channels have established periodicity and others are used when events considered relevant for the knowledge of the employees occur. The group holds Works Councils by business and by area, with worker and company representation, where different topics are dealt with. In this line, specific meetings are also held by subject, such as the meetings of the Health and Safety Committee.

Intranet Home and news in the corporate port-let. Meeting to start the pit with different subcontractors on the Reguerón Highway, Murcia (Spain)

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HEALTH AND SAFETY

COMSA Corporación has been aware from the beginning that people are the 1 Planning and innovation, avoiding routine and false trust, and innovating to most significant value and the greatest guarantee of future for the group. There- eliminate or reduce risks. fore, it maintains a continuous commitment to offer optimal health and safety 2

4. SOCIAL SPHERE conditions to all workers and collaborators, in line also with SDG 8 - Decent Work Coordination and participation of all employees. and Economic Growth and SDG 3 - Good Health and Well-being. 3 Within this framework, the group has implemented an Occupational Health and Rigour and professional competence. Safety Management System based on the OHSAS 18001 standard, which goes 4 beyond the legal and regulatory requirements and incorporates strategic pre- Availability of adequate resources for each activity. cepts aligned with the principles of decent work of the International Labour Or- ganization, and with the goals of the SDG 3 - Good Health and Well-being, of 5 the Sustainable Development Goals promoted by the United Nations. The group Systematic review of all processes as a basic tool for continuous improve- is currently in the process of adapting to the ISO 45001 standard, and COMSA ment. Service Facility Management will be the first business to have this certification by 2019.

77% of COMSA Corporación’s sales are executed under It is also worth noting the cross-cutting nature of the Health and Safety Policy and the Environmental Policy, which are strongly related and the group works in the guidelines of the international OHSAS 18001 or ISO 45001 an integrated manner from the Prevention, Quality and Environment Area, which occupational health and safety standard. is made up of three divisions:

The main purpose of the lines of work determined in COMSA Corporación is to make possible its vision of a zero-harm scenario, promoting a culture in which prevention is prioritised over correction, and which is based on five essential principles that make up the Health and Safety Policy.

Joint Prevention Prevention, Quality Internal audit Service and Environment Health and Safety Policy at National and International level of COMSA Corporación

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Prevention planning Implementation and control of working conditions

As it cannot be otherwise, the management of Safety and Health in COMSA COMSA Corporación has an external Prevention Service responsible for Health Corporación hinges on the fundamental axis of preventive planning. The group Surveillance, which, among other functions assigned to it, is responsible for car- has technicians who are specialists in this field, who make up its preventive or- rying out periodic examinations on the employees, always respecting the confi- ganisation, and who rely on specialised services, such as Occupational Medicine, dentiality of all information. The results of the health surveillance are sent only to 4. SOCIAL SPHERE to provide coverage and a global vision of the occupational risks to which the the professional examined. productive and cross-cutting processes that are integrated within the organisation are subjected. In addition, the group documents the planning for the implementation of preventive measures, both at a general level and at a particular project level, following The group carries out an identification of the hazards in the field of health and criteria of the highest worldwide standards. safety, both at a general level for recurrent activities, and at a particular level for each project. These preventive measures can be:

The risks identified are evaluated by competent technicians belonging to the pre- »»Techniques. ventive organisation, based on proven and documented procedures, which use »»Collective or individual protection. criteria of probability of occurrence and severity of damage in the event of ma- »»Organisational. terialisation. On the basis of this information, prevention measures are planned »»Related to human factors. and implemented at source to eliminate the risks or, if this is not possible, to reduce them to a level that makes the degree of risk moderate. Professionals In order to verify the effectiveness of the actions implemented, the group carries with preventive resource functions have a form with which they can notify new out systematic controls of the conditions of the organisation and the methods risk situations identified in the field of occupational health and safety. COMSA of work, as well as the health of the workers, supplemented by voluntary internal Corporación’s Health and Safety Policy does not allow, in any case, processes and external audits, throughout the geographical area in which COMSA Corpo- involving high or very high levels of risk. ración carries out its activity.

On the other hand, in order to promote the health and well-being of the group’s professionals, among other measures implemented, it is worth highlighting the possibility of contracting private health insurance companies with a discount through the Flexible Compensation Plan, collaboration agreements with gyms near the offices and the promotion of participation in races, paying for the registration to encourage healthy living habits. The group also carries out specific international health prevention campaigns, including the breast cancer awareness campaign in Brazil and the awareness campaign in Mexico on the health effects of alcohol, drugs and tobacco.

74 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

COMSA CORPORACIÓN TEAM

Training as a basis for prevention Consultation and participation

The group has its own annual Health and Safety training plan, which includes The systematic review of the entire previous cycle, with a vision of continuous preventive training for each job position, both for the different trades and in improvement, relies on the participation of the workforce, maintaining perma- offices. Along these lines, in the case of construction work, the group also holds nent channels of communication. Thus, for COMSA Corporación’s own workers, talks at the beginning of the work (both for its own personnel and for subcon- Health and Safety Committees are established, under different terminologies 4. SOCIAL SPHERE tractors) where the risks and preventive measures specific to each project are specific to each geography, which are joint company-worker bodies that peri- explained. For the coming year, the group has worked on the implementation of odically analyse management actions and indicators, and where the workers’ an online platform where training in this area will be centralised. representation proposes measures or lines of action that can supplement and improve those already implemented or proposed by COMSA Corporación’s rep- Another relevant factor is the certification according to AENOR’s TELCO stand- resentatives, which are recorded in the corresponding minutes. Since 2018, 100% ard of its own electrical risk training centres in Madrid and Seville. of COMSA Corporación’s employees have been provided with tools for consultation and participation in Occupational Health and Safety matters. Given the importance of training, information and awareness of society and future professionals in the sector, the group has collaborated by teaching subjects Likewise, COMSA Corporación’s management system makes it compulsory to related to prevention at the University of Las Palmas de Gran Canaria, Vocational hold periodic coordination meetings for the different projects, in which repre- Training Institutes in Girona and other training entities of recognised prestige sentatives of the employees of the collaborating companies participate, and at in the field of prevention such as the National Institute of Safety and Health at which actions are planned and established as a consequence of the pooling of Work. risk management.

All personnel are covered by the Group’s Health and Safety System, which is implemented in all projects. In addition, 77% of the employees are OHSAS 18001 certified.

Metro Maintenance Line A (México)

75 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

COMSA CORPORACIÓN TEAM

Evolution of the accident rate

The result of this cycle of continuous improvement is the progressive reduction of occupational accident indicators. For the year 2019, these indicators for own employees produce the following results:

4. SOCIAL SPHERE Frequency rate (%)1 Severity rate (%)2 Incidence rate (%)3

2019 2019 2019

COMSA COMSA COMSA Corporación 20.66 Corporación 0.48 Corporación 38.91

Sectoral Not Available Sectoral Not Available Sectoral Not Available

0 10 20 30 40 50 0 0,5 1 1,5 2 0 10 20 30 40 50 60 70 80

2018 2018 2018

COMSA COMSA COMSA Corporación 20.29 Corporación 0.40 Corporación 40.78 79.82 Sectoral4 Sectoral4 1.51 Sectoral4 46.1

0 10 20 30 40 50 0 0,5 1 1,5 2 0 10 20 30 40 50 60 70 80

Despite the fact that accident rates are still much lower than those prevalent in the sector, in 2019 indicators related to the number of hours worked (frequency rate and severity rate) have risen slightly. This is due to the expansion of the scope of that report with activities with a higher occupational accident rate.

1 Data on the Construction Sector in Spain for 2018 (latest available at the date of preparation of this report). Source: Ministry of Labour and Social Economy. 2 Severity rate: Days lost per every thousand hours worked. 3 Incidence rate: Number of accidents per thousand workers. 4 Data on the Construction Sector in Spain for 2018 (latest available at the date of preparation of this report). Source: Ministry of Labour and Social Economy. 76 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

COMSA CORPORACIÓN TEAM

In relation to the accidents presented, the percentage distribution of own em- As far as occupational illnesses are concerned, in 2019, there was one case of sick ployees by gender is as follows: leave, while in 2018 no cases were detected. On the other hand, in 2019, there were no fatal accidents, while, unfortunately, there was one in 2018.

Distribution by sex The analysis of the causes of accidents for own employees in 2019 shows the following results: 4. SOCIAL SPHERE

Accident types 2019 2018

Falls to the same level / Sprains 16.0% 7.1%

2019 2018 Hitting or colliding with an object 15.9% 32%

Electrical contact 1.5% 4.1%

Projections / Splashes 1.5% 5.6%

Cutting agent contact 5.3% 5.1% 5% Women 7% Women 95% Men 93% Men Falls from heights 0.0% 0.5% Falls to different levels 0.0% 5.1%

Crushing /Trapping 1.5% 7.1%

The distribution of accidents by gender shows a greater incidence in men than in Insect bite 1.5% 0.5% women, a logical distribution if we take into account both the distribution of the composition of the workforce and, additionally, the factors of exposure to risk. Overexertion (MSD) 37.1% 32.5% Other 19.7% 0.4%

In this regard, the actions derived from the investigations of accidents and incidents are indispensable, which is why an investigation is carried out into each of the accidents that have occurred, whether or not they have caused leave of absence, both for our own workers and for subcontracted workers.

77 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

COMSA CORPORACIÓN TEAM

COMMITMENT TO CONTINUOUS IMPROVEMENT

COMSA Corporación carries out different initiatives aimed at reducing both the number and severity of the main types of accidents. Among these actions, it is worth highlighting long-term projects, such as those on mobility at work and on MOBILITY PLAN

4. SOCIAL SPHERE musculoskeletal disorders. Both plans are multi-year plans aimed at reaching the entire workforce, but focused on risk groups. In 2018, COMSA Corporación launched the group’s Mobility Plan with a twofold objective: on the one hand, to improve health and safety In addition, by consensus with the workers’ representatives, and in line with the conditions at the wheel and, on the other, to reduce the associated SDG3 - Good Health and Well-being, the group has launched different initia- environmental pollution. tives, such as the Mobility Plan to reduce commuting accidents, the prevention of alcohol and drug consumption and the systematic review of psychosocial risk The first phase of this Plan focused on ascertaining the mobility hab- management, among whose actions we can highlight the implementation of the its of employees, while during the second phase, in 2019, different Protocol for the Prevention and Detection of Stress, and the implementation of initiatives were undertaken to reduce the number of road accidents, defibrillators at corporate headquarters and main logistics centres in Spain, turn- the most notable of which were: ing them into protected cardio centres. »»Study on real mobility habits, as well as associated risk and These actions support COMSA Corporación’s commitment to promoting healthy environmental factors. living habits and personal well-being. »»Improving driving skills and raising awareness of preventive and environmental issues. »»Implementation of safety and environmental improvements in the group’s means of transport.

Road safety course with driving simulator, Barcelona (Spain)

78 COMSA CORPORACIÓN CAPITAL INCLUSION HEALTH & EXTERNAL CLIENTS SOCIAL TURNOVER REMUNERATION TRAINING EQUALITY TEAM HUMAN & DIVERSITY SAFETY COLLABORATORS CONTRIBUTION

COMSA CORPORACIÓN TEAM

ABSENTISM

Absenteeism data for 2019 for COMSA Corporación in Spain as a whole are very similar to those of the previous year and show 53,150 lost working days, with the following absenteeism rates: 4. SOCIAL SPHERE

2019 2018

Absence due to common contingencies 3.72% 3.72%

Absenteeism due to accidents at work 0.61% 0.54%

ACKNOWLEDGEMENTS

At Comsa Corporación, health and safety management is considered a key factor, being a cornerstone within the group’s strategy. It has therefore been re- warded with recognition through various relevant initiatives and awards.

In 2019, COMSA Corporación has again been included in the Top 25 of the MEPS2 model, a model of business excellence in occupational risk prevention, in recognition of its Health and Safety management.

Construction of the Reguerón Highway, Murcia (Spain)

79 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

EXTERNAL COLLABORATORS

COMSA Corporación considers the management of the value chain as one of the Suppliers of COMSA Corporación in 2019 fundamental pillars in decision making and, therefore, has a purchasing model established at a corporate level to ensure transparency in contracting processes, fostering free competition and detecting risk situations, thus reinforcing its commitment to ethical behaviour. 4. SOCIAL SPHERE For such purpose, COMSA Corporación requires its suppliers to assume its ethical, social and environmental principles, and therefore includes clauses in the contracts where they express their knowledge and commitment.

In this way, the group works to ensure compliance with human rights in its business relations, applying a policy of zero tolerance towards potential situations of child labour, forced labour, serious risk to the health of workers, and behaviour contrary to its Code of Ethics.

With regard to security service providers, in 2019 the group began working with them to include training on respect for human rights in the performance of their 97.24% 93.72% work, as well as in their action manuals and protocols. local suppliers2 of purchases from local suppliers Likewise, supplier companies are periodically monitored and evaluated to ensure compliance with, among other things, principles related to quality management, respect for the environment and occupational risk prevention during the More than contractual relationship. 592 million euros Its supply chain is made up of nearly 20,000 suppliers1, encouraging the con- in turnover to suppliers. tracting of local suppliers and supporting the generation of positive social impact through the creation of wealth and investment in the countries where it is present.

1 Total number of suppliers, including group businesses. 2 A local supplier is one that is based in the country in which the project is carried out.

80 COMSA CORPORACIÓN EXTERNAL SELECCIÓN Y EVALUACIÓN CULTURA CLIENTS SOCIAL DIGITALIZACIÓN TEAM COLLABORATORS DE PROVEEDORES PREVENTIVA CONTRIBUTION

EXTERNAL COLLABORATORS

SUPPLIER SELECTION AND EVALUATION

COMSA Corporación selects its suppliers based on quality, services offered, rates, health and safety conditions, supply conditions, and environmental and ethical criteria, in order to guarantee that they comply with the group’s standards. 4. SOCIAL SPHERE The main criteria used for the approval of suppliers are:

Legal compliance

Environmental Financial compliance compliance

Quality HOMOLOGACIÓN Commercial management DE PROVEEDORES evaluation

Health and Operational capacity Safety and infrastructure

Corporate Social Responsibility

By formalising the contract, the supplier companies undertake to respect the regulations of the country, as well as to adopt COMSA Corporación’s Code of Ethics in the performance of their activity. In this sense, in order to facilitate two- way communication, COMSA Corporación’s Ethics Channel is made available to the supplier, through which no complaints were received in 2019. Transport of railway lanes (Uruguay)

81 COMSA CORPORACIÓN EXTERNAL SELECCIÓN Y EVALUACIÓN CULTURA CLIENTS SOCIAL DIGITALIZACIÓN TEAM COLLABORATORS DE PROVEEDORES PREVENTIVA CONTRIBUTION

EXTERNAL COLLABORATORS

MONITORING AND EVALUATION

The monitoring and evaluation of the supplier companies with which COMSA The result of the evaluation process allows classifying the vendors as advisable, Corporación collaborates is a key aspect in the management of the value chain, those with which orders can be placed, and inadvisable. Among the latter, there and aims to ensure compliance with the following criteria throughout the con- are three categories: with incidents, which means that orders can be placed, but

4. SOCIAL SPHERE tractual relationship. their evolution must be analysed; undesirable, for which only orders previously approved by management can be placed; and blocked, with which no contrac- Quality management tual relationship can be established. In the event of negative performance by a supplier, a specific action plan is devised. The supplier evaluation process does not generally provide for on-site audits.

Occupational Environmental Risk Prevention management

To review the supplier evaluation criteria to increase the weight of social and environmental criteria EVALUACIÓN Need for DE PROVEEDORES OBJECTIVE follow-up in Cost management

Supply Design

In 2019, more than 1,000 suppliers were evaluated in Spain (1,500 in 2018), considered critical due to the type of supply or volume of turnover. As a result of these assessments, no significant negative environmental impacts, actual or potential, were identified in the supply chain in 2019. With regard to social aspects, only the requirements for occupational risk prevention are included in the supplier evaluations, since issues relating to human rights are established in the group’s Code of Ethics, compliance with which and acceptance of which is indispensable for working together. Corrective maintenance on FM radio broadcast antennas, Pic de Carroi (Andorra)

82 COMSA CORPORACIÓN EXTERNAL SELECCIÓN Y EVALUACIÓN CULTURA CLIENTS SOCIAL DIGITALIZACIÓN TEAM COLLABORATORS DE PROVEEDORES PREVENTIVA CONTRIBUTION

EXTERNAL COLLABORATORS

INTERNAL DIGITALISATION

Since 2017, the Purchasing area has been immersed in a digitalisation process Along the same lines of internal optimisation of the different operations, through- with the aim of optimising internal processes and working in a more agile and out 2019 the materials database was optimised, on the one hand, in the case effective way with the different collaborators in today’s globalised world. Under of strategic materials, defining specific parameters on which to base purchasing decisions, and on the other, establishing broader categories of materials that

4. SOCIAL SPHERE this premise, in 2019 work began on updating the Purchasing Procedure, which will be linked to different tools under development: encompass products of similar types.

Supplier Portal: It will allow more agile management of orders and invoices, both internally and externally, while providing greater traceability to different transactions.

Approval Portal: It will allow the pre-registration of new suppliers with which to collaborate. Each interested supplier will be able to upload to the platform business information and specific requirements according to their type of supply, and based on this information, they will be given a score.

Tender Portal: This tool will be fed by the database of existing and new suppliers invited to participate in tenders. It will allow a greater number of suppliers to participate in the group’s tenders, as well as much more agile and transparent management of the information collected.

Purchasing Planning: This tool will allow optimising and forecasting purchases for projects for a better search of the most suitable materials and services. COMSA Corporación Supplier Portal Homepage

83 COMSA CORPORACIÓN EXTERNAL SELECCIÓN Y EVALUACIÓN CULTURA CLIENTS SOCIAL DIGITALIZACIÓN TEAM COLLABORATORS DE PROVEEDORES PREVENTIVA CONTRIBUTION

EXTERNAL COLLABORATORS

PREVENTIVE CULTURE IN THE VALUE CHAIN

COMSA Corporación works to ensure and promote a preventive culture throughout the entire value chain, establishing cross-cutting measures that apply to all workers in its workplaces, whether they are its own or those of collaborating

4. SOCIAL SPHERE companies.

Overall accident rates1:

year accident rate

Frequency rate 2019 19.37 (number of accidents per million hours worked) 2018 20.03

2018 sectorial2 46.1

Severity rate 2019 0.40 (number of accidents per million hours worked) 2018 0.41

2018 sectorial2 1.51

Incidence rate 2019 30.01 (number of accidents per million hours worked) 2018 30.29

2018 sectorial2 79.82

The above figures show the correct performance in terms of occupational risk prevention carried out by the group throughout 2019.

Substations and associated transmission lines of four ENEL Green Power Iberia wind farms (Spain)

1 Both own and subcontracted personnel are included. 2 Data on the Construction Sector in Spain for 2018 (latest available at the date of preparation of this report). Source: Ministry of Labour and Social Economy.

84 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

CLIENTS

COMSA Corporación has a history of more than 125 years as a reference com- COMSA Corporación has a Quality Policy and a Quality Management System in pany in the sector, in which its client focus stands out, aimed at permanently place based on the ISO 9001:2015 standard, thanks to which the group guaran- satisfying their expectations and needs, both current and future, and involving tees clients that the projects executed comply with the highest quality standards them from the very beginning of their projects. and with the regulations in force at any given time.

To this end, the group promotes the following aspects: 4. SOCIAL SPHERE The Quality Management System is systematically verified by internal and external audits.

Professionalism of the human team to offer agile solutions to in- The quality management system aims to ensure compliance with and control of creasingly demanding challenges, in a climate of mutual trust that the parameters established by ISO 9001 certification. This procedure is closely guarantees communication and fluid treatment with the client. linked to sales by business division. Thus, the percentage of sales governed by this system was 86% in 2018 and 80% in 2019.

It is committed to innovation and technological development to In all projects a Quality Plan is developed, which includes both the requirements improve project efficiency and even the client’s own expectations. of the applicable regulations and the specific demands of the clients through the so-called Inspection Point Programmes (IPPs). The IPPs detail the sequence and scope of the checks on the work units and processes previously listed in the Quality Plan. Fostering the global vision within the group, taking advantage of the resources and diversity of the group to offer integrated solu- Checking for strict compliance with the IPPs. (Inspection Points Programme) and tions, through synergies that enhance the added value for the client. the Test Plans ensure that the execution of the processes is carried out in accordance with the regulations and legislation in force.

Commitment to quality as a sign of identity, planning rigorously and In addition, once the project is completed, the “as built” file is generated, which fulfilling the commitments made. allows the client to know all the final characteristics of the project, facilitating its preservation and maintenance.

Promoting organisational learning, sharing information and detecting aspects of the organisation’s performance that allow new opportunities thanks to the cycle of continuous improvement. Quality politics of COMSA Corporación

85 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

CUSTOMERS

CLIENT SATISFACTION

In order to guarantee client satisfaction, COMSA Corporación carries out evaluations systematically and continuously, either at the end of the project or dur- To increase the response rate of our clients in the satisfac- ing the provision of the service, establishing specific action plans when deemed tion questionnaires in order to optimise and objectify the

4. SOCIAL SPHERE necessary. implementation of improvement plans.

These evaluations are carried out by means of satisfaction surveys, which include OBJECTIVE assessments of aspects such as the technical capacity of the teams, compliance with deadlines and commitments, the capacity to respond to unforeseen events, contributions for improvement, the fluidity of communication, the final quality of Likewise, in order to guarantee the analysis of the most significant information, the project, the safety of execution, and environmental management. In addition, the Quality Management Systems implemented establish mechanisms that en- clients are periodically asked to weigh up the importance of these criteria for sure the adequate handling of the claims and complaints received, following the them, so that new criteria can be introduced into the evaluation. stages detailed below:

»»Identification and communication of claims and complaints received. 2019 2018 »»Analysis of provisions to be adopted for their resolution. »»Approval, depending on their significance, of the proposed provisions. »»Adoption of the adopted provisions. »»Verification of the effectiveness of the provisions and closure of the claim or Response Response complaint. rate rate 405 (73%) 305 (54%) This system is designed to deal with any claim or complaint from the client or their representative, as well as from any other interested party, such as neigh- bours, associations, environmental organisations, etc. The process is systematically supervised by internal audits, carried out by both our own auditors and Surveys sent Surveys sent 556 563 specialised companies, and by external audits.

Average Client Average Client All the above allows COMSA Corporación to identify and evaluate its strengths Satisfaction Satisfaction 8.23/10 8.18/10 and weaknesses, as well as the risks and opportunities of the different projects. Once analysed, if it is considered that additional competences to those of COM- SA Corporación are required, partnerships are established with partners and In this regard, the group fulfilled the objective set the previous year of increas- consultants of proven experience and with affinity in corporate principles and ing the percentage of client response in satisfaction surveys, achieving a 32.8% values, especially regarding ethical and honest behaviour. increase.

86 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

SOCIAL CONTRIBUTION

In 2019 COMSA Corporación has made donations in various areas worth 423,600 euros.

COMSA Corporación’s family nature makes it especially sensitive to the environ- SOCIAL ACTION MANAGEMENT ment in which it carries on its activity and to the people who are part of it. This 4. SOCIAL SPHERE particularity can be seen in the group’s philosophy, “We take care of people in COMSA Corporación has aligned the social action initiatives it undertakes with the same way that we take care of our projects”, and it is materialised through the activities related to the core business, prioritising, moreover, those actions different actions, both internal and external, in the companies and subsidiaries where the group’s professionals can play a leading role. Therefore, in 2020 the located in the different regions where the group operates. group has planned to carry out an internal survey to ascertain the concerns and main interests of the group’s professionals in this field. COMSA Corporación’s fundamental objective is to create value in the territory, maintaining active relations with the community, supporting local development At the same time, it is working on a standardised methodology to help quantify and meeting the needs of each region. the positive impact of the various social action initiatives on the environment, regardless of the location and type of action carried out, in order to disseminate This contribution is materialised both on a global scale through partnerships that it among the various countries and businesses of the group. seek to achieve the main objectives of the Agenda 2030, such as the group’s adhesion to the Global Compact, or the collaborations with the Olof Palme Inter- national Foundation, which strives to ensure that human rights are respected, or the MIESES Global in the area of business sustainability, as well as on a local scale with networks such as Barcelona+Sostenible.

To improve the overall management of social action, through the implementation of a Social Action Policy and setting indicators to measure the positive impact generated. OBJECTIVE

Throughout 2019, different actions were carried out, adapted to the specific needs of each territory, for which an amount of 423,600 euros has been allo- cated.

87 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

SOCIAL CONTRIBUTION

PARTNERSHIP WITH UNHCR – SOLIDARITY PAYROLL PROGRAM

4. SOCIAL SPHERE COMSA Corporación and the Spanish Committee for UNHCR, the United Nations High Commissioner for Refugees, have signed a collaboration agreement with the aim of helping to improve the coverage of the basic needs of refugees.

This collaboration is materialised through the “Solidarity Payroll Program”, which consists of voluntary monthly contributions from the salary of the group’s professionals, which COMSA Corporación simultaneously matches. The funds are intended to support UNHCR in its mission of ensuring access to adequate housing in humanitarian emergencies, specifically in the provision of:

»»Emergency shelter kits. »»Distribution of emergency tents for refugee families. »»Complete rehabilitation of houses destroyed by violence for refugee families. »»Rehabilitation of buildings with private rooms for families, with common facilities (kitchens, bathrooms).

This collaboration, which began in Spain, will be extended in the short term to the rest of the countries where the group is present, with the aim of generating awareness and sharing positive values both within and outside the group.

88 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

SOCIAL CONTRIBUTION

CULTURAL FIELD

The group makes various contributions to cultural institutions to make culture accessible to the population, including sponsorship of 4. SOCIAL SPHERE the 2019-2020 season of the Teatre Nacional de Catalunya and the Fundació Gran Teatre del Liceu.

At the same time, in some countries such as Brazil and Colombia, it carries out actions to raise awareness of the archaeological heritage linked to the projects, both for employees and for the communities surrounding the projects.

Awareness of archaeological heritage for high school students (Brazil)

SPORTS FIELD

COMSA Corporación promotes the values and health benefits of sport. Thus, in addition to supporting the participation of employees in some sporting events, such as the Company runs in Barce- lona and Madrid (with the registration for which we contributed to the TV3 Fundació de la Marató and Arrels Fundació, as well as the Intheos Foundation, respectively), it has also sponsored other sporting events such as the Rovira i Virgili University Charity Run and the Port Aventura Foundation golf tournament, all of which were held for charity.

In the case of Brazil, the group has made a contribution in kind, through the provision of rehabilitation services, as well as the do- nation of materials for the restoration of a local Judo association, Runners reaching the finish line in a Business Race (Barcelona) closely linked to the community in which the Line 4 metro works are being carried out.

89 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

SOCIAL CONTRIBUTION

CHILDREN AND EDUCATION FIELD

To promote equal opportunities, especially among the youngest, both the group and its employees participate in different local ac- 4. SOCIAL SPHERE tions, such as sponsoring more than 100 children in Brazil during the Christmas campaign or collecting dance uniforms in the case of Co- lombia.

Another of the actions carried out within the framework of the schools in these two countries are the awareness campaigns for the promotion of recycling and efficient water use in which more than 300 schoolchildren have participated, with the aim of promoting respect for the environment among the very young.

Environmental themed games to raise awareness among schoolchildren, São Paulo (Brazil)

HEALTH FIELD

In the field of health, the group has made financial and material donations to support treatment and research into different pathologies. Among other entities, the group has collaborated with the Mexican Association of Aid to Children with Cancer (AMANC) and the Tamariz Oropeza Foundation in Mexico.

In the case of Spain, the contribution made has been in kind, providing its services free of charge for the second consecutive year in the telecommunications facility for the development of the TV3 Marató (marathon), whose mission is to raise funds for research into different diseases.

La Marató TV3 campaign on minority diseases in 2019 (Spain)

90 COMSA CORPORACIÓN EXTERNAL CLIENTS SOCIAL TEAM COLLABORATORS CONTRIBUTION

SOCIAL CONTRIBUTION

SOCIAL FIELD 4. SOCIAL SPHERE The group works closely with local communities to understand their needs and contribute to their development.

Thus, in some territories, essential infrastructures have been rehabili- tated, such as in the vicinity of the Amagá Tunnel in Colombia, where the group has contributed to the improvement of the sewage system.

Furthermore, the group also watches over the social rights of people, especially the most disadvantaged. In the case of Spain, COMSA Corporación has collaborated with the Prevent Private Foundation, whose aim is the social integration of people with functional diversity, while in Mexico it has continued to support the Puebla Foodbank and the Mexican Red Cross.

Volunteers sorting and distributing donated food to the Puebla Food Bank (Mexico)

91 ABOUT THE REPORT 93 5. ABOUT THE REPORT REPORT ABOUT THE personnel, thefollowing companies wereof included: volume and turnover their to year,due past this in scope, the to relation In Denmark, France, Mexico, Peru, Portugal andSweden. Colombia, Brazil, Argentina, in branches and subsidiaries its are included Also » » » » » » » » » » area activitiesofthefollowing Spanishcompanies: business the on focuses report this regard, this In subsidiaries. its and poración CorCOMSA- of 2019 December 31 ended year the for data and information the referredInformation,also ThisStatementNon-Financial report, of showsa to as bribery. group’s workforce, respect for human rights and the fight against corruption and the and issues social and environmental to relating information with formation, transparencysecondthis Statementof In- publication Non-Financial the of with of area the in efforts its redoubling is group”, “the or Corporación”“COMSA as COMSACorporación Infraestructuras,de referredS.L., tothroughoutreport this Reports, Responsibility Social Corporate the through information non-financial of reporting the to relation in 2017 in initiated commitment the with keeping In SCOPE ANDCOVERAGE » » » » » » » » » » Comsa SecurityService, S.L.U. Comsa Auxiliary Solutions,S.L. Generación deEnergías Sostenibles, S.L. TFM Energía SolarFotovoltaica, S.A. Gestión MedioambientaldeNeumáticos, S.L. COMSA Renovables, S.A.U. COMSA Service Facility Management,S.A.U. COMSA Instalaciones ySistemas Industriales, S.A.U. COMSA, S.A.U. COMSA Corporación deInfraestructuras, S.L. ABOUT THEREPORT INFORMATION ADITIONAL CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE standards GRI isincludedintheAnnex. the and 11/2018 Law cor- Spanish the of requirements with the table between a respondences information, the of traceability the facilitate to order In 11/2018, theinformation hasbeenadapted where necessary. and timeliness. However, in order to respond to the requirements of Spanish Law clarity,balance,comparability, precision, of reliability principles the considering materiality and exhaustiveness, and with regard to the quality of the information, content with regard the to the of inclusion of definition stakeholders, the the context for of sustainability,both considered, been have standards (GRI) Initiative Reporting Global the in requirementsincluded and guidelines the report, the of preparation the ForDiversity. and Information Non-Financial on December 29 pared in compliance and in line with the requirements of Spanish Law 11/2018 of pre - been has and Group Subsidiaries and Infraestructuras,S.L. de Corporación COMSA the of Report Management Consolidated the of part forms report This included. the scope of consolidation, the information relating to the Trakcja Group was not in change report.to2019,the the due In in restincluded datathe the with of ed the on data included Trackja Group’s Report activity in Poland, although this information was not consolidat- Information Non-Financial 2018 the addition, In ed intheprevious year. For this reason, the data are not strictly comparable with the information report- 94 5. ABOUT THE REPORT REPORT ABOUT THE Report ofCOMSA Corporación, theresults ofwhichare shown below. CSR first the preparationof the of part as out carried analysismateriality the in identified issuesmaterial main the topreparedrespond to been has reportThis MATERIAL ISSUES RELATED TO SUSTAINABILITY * Prevention ofbribery * Riskmanagement ABOUT THEREPORT and corruption GOVERNANCE * Compliance CORPORATE * Integrity INFORMATION ADITIONAL * Fiscalresponsibility * Competitiveness CONTENTS ANNEX I:GRITABLE OF ECONOMY * Water management * Circular economy OF CONTENTS ANNEX II:SDGSTABLE * Acoustic impact * Climate change ENVIRONMENT biodiversity * Impacton * Equalityanddiversity * Healthandsafety retention oftalent * Attraction and OBJECTIVE LABOUR stakeholders. of material issues for COMSA Corporación andits process is planned for 2020 to update the identification responsible andsustainable management,anew In linewiththegroup’s commitment to ethical, * Supplychainrisks * Clientsatisfaction * Qualityofservice * HumanRights SUPPLY CHAIN * Relationship withthe * Institutional relations * Socialcommitment * Volunteer program * Socialimpact community SOCIAL 95 5. ABOUT THE REPORT REPORT ABOUT THE holders into itssustainability strategy. stake- of expectations and needs integratingthe toCorporación’s commitment COMSA reaffirms 2020, in out carried be will study,which materiality new The enable thecommunication ofconcerns andexpectations. the same different channels of communication, both internal and external, which stable and transparent relationships with its stakeholders. In this regard, it offers maintaining to committed is group the model, business the of aspect key a As DIALOGUE WITHTHESTAKEHOLDERS ABOUT THEREPORT INFORMATION ADITIONAL CLIENTS EMPLOYEES SOCIETY PUBLIC ADMINISTRATION CONTENTS ANNEX I:GRITABLE OF COMSA Corporación stakeholders andcommunication channelsestablished OF CONTENTS ANNEX II:SDGSTABLE INTERNAL APPLICATIONS ETHICAL CHANNEL COMMUNICATION CHANNELS: CSR EMAIL INTRANET PORT-LET WEBSITE CONCORDANCE WITHOTHER DOCUMENTS comsa.com regardingresponsabilidad.social@contactquestionsanyForreport, please this Spanish Law 22/2018. has it as prevails been verified report by an independent this verification service in provider, information in compliance with the documents, two the between information divergenceof eventof the In website.group’s 2020 the on available April and in published 2019 Summary Annual the on expands and plements sup- here presented data the of Much stakeholders. main the on repercussions their and issues materialCorporación’ssustainability, COMSAits contextof the exhaustivean preparedmanner,in been account has into document taking This BUSINESS PARTNERS SHAREHOLDERS FINANCERS SUPPLIERS 96 5. ABOUT THE REPORT REPORT ABOUT THE » nancial information are highlighted: non-fi- regarding issues following the evaluation, this of results the From plete. incom- be may information such considerations, above-mentioned the to Due available.information best the of basis the on situation current the of sessment as- preliminary a made have Management and Directors Group’sHowever, the surrounding itsconsequences intheshort,mediumandlongterm. the possible impacts that Covid-19 of will havequantification on the or group, due assessment to the detailed uncertainty a out carry to premature is it mation, Infor- Non-Financial of Statement this of preparation of date the at Therefore, of alltheeconomic players affected. well as the capacity to react, the decisions taken to contain it, and the adaptation extent on the evolution and extension of the pandemic in the coming months, as consequences for the group’s operations are uncertain and will depend to a large the and absence, for the time being, globalisation of effective medical treatment against their the virus, the to due markets the of complexity the Considering the World HealthOrganization on11March. to a large number of countries, led to the virus being classified as a pandemic by The Covid-19 outbreak in China in January 2020, and its recent global expansion SUBSEQUENT RELEVANT FACTS » of operations. continuity the guarantee and business the on impact the reduce to medium-term measures and short- of implementation and analysis evaluation, the for Committeea up regard,groupimmediatelyset this the markets.In and ations oper- of location the of terms in mainly model, business the characteristicsof some of rethinking a to lead may circumstances current the model: Business ABOUT THEREPORT INFORMATION ADITIONAL CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE » » » » » » » » » » impact onitsoperations. their minimise to order in times, all at operations its of evolution the manage the Therefore, Group production. has established specific working of groups and procedures interruption to monitor temporary and of risk events a to of lead nature could unpredictable and changing the operations: of Continuity ply service provision inany significant way. health crisis generated by Covid-19 is not having an impact on the group’sconsequently,the sup- and, group the of those to slowdowns similar suffered has activity whose suppliers are suppliers main group’s the issues: chain Supply on indicators related to occupational health andsafety. havemay actions these that impacts reviewingpossible as the well as clients, employeesand of safety and health the ensure to measuresnecessary the ed Health and safety issues: since the beginning of the crisis, the group has adopt- an impactonthemainindicators relating to theworkforce for 2020. havewill which employment,regulating forpractices adopted also has group The operations. support business core of continuity the enabled largely have (teleworking),which workingremote facilitating as innovativesuch practices, Covid-19resultthe a of as issues: Personnelgroup implementedthe has crisis, respect to climate change. tions are planned for continuity in pollution prevention policies, as well as with low,ac- considered is activity group’s the to related issues environmental on Environmental issues: although the analysis of the impact of the Covid-19 crisis 97 5. ABOUT THE REPORT REPORT ABOUT THE may arise. to thatsuccessfully non-financial, and orderaddressfinancial both anyimpacts, possible in situation the of evolution the monitoring constantly and tinuously con- are Management Group’sand directorsthe that noted be Finally,should it indicated intheConsolidated FinancialStatements, remains valid. as principle, going-concern the of application the on conclusion the that sider Takingabove,factorsmentioned Group’sthe accountthe intoall Directors con - pected to bepartiallyoffset by costex containment measures. are projects some of implementation the in halt the and/orslowdown the activity,in fall the of results on effects the case, any In 2020.expectedfor pact im- the quantify objectively to possible being it without group, the by planned activity the slowdownin a of something been recently has thereregard, this In SUBSEQUENT RELEVANT FACTS ABOUT THEREPORT INFORMATION ADITIONAL CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE - Delivery ofpersonalprotective equipmentin themaintenance ofLineAtheMetro (Mexico) 98 5. ABOUT THE REPORT REPORT ABOUT THE Distribution of employees by professional category COMSA CORPORACIÓN TEAM Distribution ofemployees by gender, ageand professional category inSpain Total Category 5 Category 4 Category 3 Age Category 2 Category 1 category Professional Category 3 Category 2 Category 1 Professional category Category 5 Category 4 Total ADDITIONAL INFORMATION INFORMATION ADITIONAL 306 (34.3%) 495 (55.4%) % Women 73 (8.2%) 16 (1.8%) 3 (0.3%) 893 2019 2,244 (67.7%) Women 660 (19.9%) 291 (8.8%) 102 (3.1%) 15 (0,5%) CONTENTS ANNEX I:GRITABLE OF 46 30 % Men 14 0 0 2 3,312 under 30 518 (81.7 %) 66 (10.4 %) % Women 33 (5.2%) 14 (2.2%) 3 (0.5 %) 634 Men 108 174 63 0 0 3 OF CONTENTS ANNEX II:SDGSTABLE 2018 2,950 (70.8%) 277 (6.7 %) 109 (2.6%) 811 (19.5 %) 18 (0.4 %) % Men 4,165 Women 477 293 113 55 14 2 30 -50 Distribution of employees by country Argentina Country Brazil Spain Denmark Colombia Mexico France Peru Total Sweden Portugal 1,671 1,126 Men 312 172 55 6 Women 239 166 70 0 2 1 Employees 2019 3.393 (80.69%) 451 (10.73%) 120 (2.85%) 20 (0.48%) 39 (0.93%) 30 (0.71%) 12 (0.29%) 57 (1.36%) 76 (1.81%) 7 (0.17%) over 50 4,205 Men 786 599 99 54 26 8 Employees 2018 3.013 (62.76%) 992 (20.66%) 362 (7.54%) 182 (3.79%) 104 (2.17%) 26 (0.54%) 32 (0.67%) 13 (0.27%) 74 (1.54%) 1 (0.02%) 4,799 3,393 2,126 Total 867 288 95 17 99 5. ABOUT THE REPORT REPORT ABOUT THE Number ofdepartures by genderandage COMSA CORPORACIÓN TEAM 2018 2019 ADDITIONAL INFORMATION >50 30 -50 <30 <30 30 -50 Total by type >50 Total by type Men Women Men Women Women Men Women Men Women Men Women Men INFORMATION ADITIONAL CONTENTS ANNEX I:GRITABLE OF Dismissals Dismissals 7.5% 7.5% 170 112 34 29 53 23 16 16 16 81 4 6 2 2 Voluntary departures Voluntary departures OF CONTENTS ANNEX II:SDGSTABLE 35.9% 37.2% 553 474 819 147 312 152 42 36 92 55 32 10 17 3 End ofcontracts End ofcontracts 55.3% 53.7% 1,261 454 280 665 798 158 197 59 24 76 35 87 23 1 Retirements Retirements 1.6% 1.3% 30 24 24 25 0 0 0 0 0 0 0 0 4 1 2,280 1,487 Total Total 1,221 309 367 461 169 819 147 96 54 43 72 6 100 5. ABOUT THE REPORT REPORT ABOUT THE COMSA CORPORACIÓN TEAM Number ofdepartures by country Number ofnew hires by gender, ageandcountry Mexico Portugal Sweden France Peru Spain Denmark Colombia Argentina Brazil Country Argentina Country Colombia Brazil Denmark Spain France Mexico Peru Total Sweden Portugal ADDITIONAL INFORMATION INFORMATION ADITIONAL 2019 42 76 32 15 0 0 0 0 3 2 Dismissals new hires 2019 1,504 205 257 912 29 47 10 13 17 2018 7 7 78 13 12 0 0 0 6 1 1 1 2019 246 481 57 12 0 8 8 5 1 1 new hires 2019% departures Voluntary CONTENTS ANNEX I:GRITABLE OF 60.64% 13.63% 17.09% 0.66% 0.86% 0.47% 0.47% 100% 1.93% 3.13% 1.13% 2018 230 220 23 52 18 4 2 2 1 1 2019 End ofcontracts 662 353 148 92 0 0 0 0 4 2 new hires 2018 2,136 935 793 144 105 30 24 37 57 10 1 2018 307 311 56 97 13 0 0 9 3 2 OF CONTENTS ANNEX II:SDGSTABLE new hires 2018% 2019 22 Retirements 0 0 0 0 0 0 6 100.00% 1 1 43.77% 37.13% 0.05% 0.47% 4.92% 6.74% 2.67% 1.40% 1.73% 1.12% 2018 18 0 0 0 0 0 2 2 1 1 Number ofmedicalleave peryear 30 170 819 1261 2,280 1.3% 7.5% 35.9% 55.3% 2019 TOTAL Retirement Dismissal Voluntary departur End ofcontract 24 112 553 798 1,487 1.6% 7.5% 37.2% 53.7% TOTAL 2018 Retirement Dismissal Voluntary departur End ofcontract 101 5. ABOUT THE REPORT REPORT ABOUT THE COMSA CORPORACIÓN TEAM Average remuneration by country and gender workers. Insome countries, categories are grouped to guarantee theprotection of personal data. Categories 1:Directors; Category 2:Managers,Delegates, Area Heads,Department Heads;Category 3:Construction Managersand UnitManagers.Category 4:Technical andAdministrative staff. Category 5:Side Average remuneration by country andprofessional category: 2019 Sweden Portugal Peru Mexico France Spain Denmark Colombia Brazil Country Sweden Argentina Portugal Peru Mexico France Spain Denmark Colombia Brazil Argentina Country ADDITIONAL INFORMATION INFORMATION ADITIONAL 25,578.06 28,728.30 10,039.36 40,892.91 15,048.33 12,026.95 Cat. 1 51,091.51 7,583.47 18,861.11 N/A N/A N/A N/A N/A N/A N/A N/A N/A 2019 --- 87,806.10 Women 44,775.54 64,246 Cat. 2 N/A N/A N/A N/A 42,384.80 10,942.90 28,265.92 28,322.38 CONTENTS ANNEX I:GRITABLE OF 15,030.75 10,418.29 7,930.89 17,355.14 8,759.97 40,925.63 37,556.39 71,701.04 2018 - 23,808.54 48.587.24 31,405.93 46,534.13 26,671.75 Cat. 3 14,840.24 72,700.99 47,423.95 13,560.39 32,690.16 14,507.42 29,318.63 17,680.52 32,361.21 14,141.29 9,381.54 2019 44,702.68 58,279.02 28,172.22 16,378.91 31,471.26 9,073.58 12,523.21 Cat. 4 OF CONTENTS ANNEX II:SDGSTABLE Men 15,060.07 15,904.91 32,339.53 27,334.54 Cat. 5 75,957.84 27,484.14 12,666.61 9,954.95 8,858.63 26,809.67 9,426.21 7,532.75 21,430.88 10,328.85 9,349.28 6,107.20 2018 7,811.32 N/A - Average remuneration by country andprofessional category: 2018 Average remuneration by country and age Denmark Brazil France Colombia Argentina Country Mexico Spain Portugal Peru Argentina Sweden Portugal Peru Mexico France Spain Denmark Colombia Brazil Country/Age 40,778.04 56,893.85 12,043.55 21,858.02 31,483.33 9,420.60 5,464.38 8,876.36 16,410.91 7,169.72 2019 56,642.55 54,847.33 29,089.41 72,176.72 Cat. 1y2 N/A N/A N/A N/A N/A <30 25,242.98 21,466.90 61,334.08 16,489.79 9,048.56 4,982.02 5,386.88 7,964.23 6,521.11 2018 - 16,008.68 42,014.59 82,278.74 27,883.33 18,393.86 44,814.10 20,713.73 41,691.20 Cat. 3 N/A 14,387.48 67,202.03 21,893.88 30,174.43 47,351.02 14,410.65 28,771.37 12,175.57 10,107.14 31,121.58 2019 30-50 60,242.66 24,815.46 32,027.57 13,333.45 27,135.90 10,524.10 11,434.29 7,802.83 9,411.15 2018 28,440.87 55,709.56 29,328.37 14,487.48 13,938.73 14,085.16 11,703.99 9,444.27 8,124.26 - Cat. 4 24,601,64 16,826,08 14,553,39 13,622,25 16,574,33 35,179,27 19,076.91 56,213,61 29,198,14 2019 - >50 30,281.33 19,369.77 9,834.65 6,956.93 21,607.14 5,237.73 8,825.17 6,375.15 Cat. 5 N/A 24,247.09 34,597.68 93,608.13 29,716.48 13,939.97 12,783.05 16,861.73 9,620.10 8,266.13 2018 - 102 5. ABOUT THE REPORT REPORT ABOUT THE 2 Onlythe data ofFergrupo, SA Portugal company are included,the data oftheother companies are notavailable. 1 Onlythedata oftheEOLISMéxico company are included,thedata oftheother companies are notavailable. COMSA CORPORACIÓN TEAM Percentage ofemployees covered by collective agreement by country Mexico France Denmark Colombia Brazil Argentina Sweden Portugal Spain Country Peru ADDITIONAL INFORMATION 1 2 INFORMATION ADITIONAL Women 100% 100% 100% 100% 100% 99% 0% 0% - - 2019 CONTENTS ANNEX I:GRITABLE OF 100% 100% 100% 100% 100% 99% 43% Men 17% - - Women 100% 100% 100% 100% 100% 98% 50& 0% - - OF CONTENTS ANNEX II:SDGSTABLE 2018 100% 100% 100% 100% 99% 89% Men 74% 41% - - 103 5. ABOUT THE REPORT REPORT ABOUT THE Below isasummarytablewithalltheGRIindicators discussed throughout thisreport to facilitate theiridentification. This report hasbeenprepared inaccordance withtheGlobalReporting Initiative (GRI) Standards initsessential version. GRI 102-15 GRI 102-14 GRI 102-12 GRI 102-11 GRI 102-10 GRI 102-09 GRI 102-08 GRI 102-07 GRI 102-05 GRI 102-03 GRI 102-06 GRI 102-04 GRI 102-02 GRI 102-01 GRI 102 GRI 101 GRI 101 RI Standard GRI 102-13 ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Key impacts,risksandopportunities Statement from senior decision-maker Strategy External initiatives Precautionary principleorapproach Significant changes to theorganization anditssupply chain Supply chain Information on employees andotherworkers Scale oftheorganization Markets served Ownership andlegalform Locations ofoperations Location ofheadquarters Activities, brands, products andservices Name oftheorganization Organizational profile GENERAL DISCLOSURES Principles FOUNDATION Name oftheindicator Memberships ofassociations CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 29-30 5-6 57 40 29 31 80 33-34, 60-62 33-35 26 26, 33 26-28 Limited Society España C/Viriato, 47, 08014, Barcelona. COMSA Corporación deInfraestructuras S.L. Page number orexplanation , 87 , 30 , 47 , 6888-91 , 37-38 , 73 104 5. ABOUT THE REPORT REPORT ABOUT THE GRI 102-18 GRI 102-34 GRI 102-33 GRI 102-32 GRI 102-31 GRI 102-30 GRI 102-29 GRI 102-28 GRI 102-27 GRI 102-26 GRI 102-25 GRI 102-24 GRI 102-23 GRI 102-22 GRI 102-21 GRI 102-20 GRI 102-19 GRI 102-17 GRI 102-16 RI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Governance structure Governance Number andnature ofcriticalconcerns Communication ofcriticalconcerns Highest governance body’s role insustainability reporting Review ofeconomic, environmental and socialtopics Effectiveness of riskmanagementprocesses Identifying andmanagingeconomic, environmental andsocialimpacts Evaluating thehighest governance body’s performance Collective knowledge ofthehighest governance body Role ofthehighest governance bodyinsettingpurpose, values andstrategy Conflicts of interest Nominating andselectingthehighest governance body Chair ofthehighest governance body Composition ofthehighest governance bodyanditscommittees Consulting stakeholders oneconomic, environmental andsocialtopics Executive level responsibility for economic, environmental andsocialtopics Delegating authority Mechanisms for advice andconcerns aboutethicsandintegrity Values, principles,standards andnormsofbehaviour Ethics andintegrity Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 13, 1516 13, 15 15 30 29-30 15 13-15 13-15 18-20 13 13 14 15 13-15 13-15 13-14 18, 21-22 8, 9 Not reported Page number orexplanation , 59 105 5. ABOUT THE REPORT REPORT ABOUT THE GRI 102-45 GRI 102-40 GRI 102-48 GRI 102-47 GRI 102-46 GRI 102-44 GRI 102-43 GRI 102-42 GRI 102-41 GRI 102-39 GRI 102-37 GRI 102-36 GRI 102-53 GRI 102-52 GRI 102-51 GRI 102-50 GRI 102-49 GRI 102-38 GRI 102-35 RI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Entities includedintheconsolidated financial statements List ofstakeholder groups Reporting practices Stakeholder engagement Contact pointfor questions regarding thereport Reporting cycle Date ofmost recent report Reporting period Changes inreporting Restatements ofinformation List ofmaterial topics Defining report content and topic boundaries Key topics andconcerns raised Approach to stakeholder engagement Identifying andselectingstakeholders Collective bargaining agreements Percentage increase inannualtotal compensation ratio Annual total compensation ratio Stakeholders’ involvement inremuneration Process for the determination ofthe remuneration Remuneration policies Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 94 93 93 94 95 95 72 95 66 66 65 65 [email protected] Annual July 2019 From January1to December 31,2019. COMSA and Solutions Security activities. COMSA also from directly it data 2019 not in includes are 2018, report report in those this to comparable in reported data The No restatements in2019 Stakeholders are notinvolved intheretribution Page number orexplanation , 102 106 5. ABOUT THE REPORT REPORT ABOUT THE GRI 103-03 GRI 103-02 GRI 103-01 GRI 103 GRI 102-56 RI Standard GRI 102-55 GRI 102-54 ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Evaluation ofmanagementapproach Management approach anditscomponents Explanation ofthematerial topic anditsboundaries MANAGEMENT APPROACH Review external GRI content index Claims ofreporting inaccordance withtheGRIStandards Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE Introduction ofthedifferent sections Introduction ofthedifferent sections Introduction ofthedifferent sections not required intheseregulations. information additional includes report this However, verification service provider Deloitte. which hasbeenverified by theindependent Statement required by Royal Decree Law 11/2018, Corporation’s 2019 Non-FinancialInformation This report hasbeenprepared basedonCOMSA 109-121 GRI standards: Essential option This report hasbeenprepared inaccordance withthe Page number orexplanation ABOUT THE ADITIONAL ANNEX I: GRI TABLE OF ANNEX II: SDGS TABLE REPORT INFORMATION CONTENTS OF CONTENTS

ANNEX I. GRI TABLE OF CONTENTS

ECONOMIC MATERIAL TOPIC

GRI Standard Name of the indicator Page number or explanation

GRI 201 ECONOMIC PERFORMANCE GRI 201-1 Direct economic value generated and distributed 33-35 GRI 201-2 Financial implications and other risks and opportunities due to climate change Not reported 5. ABOUT THE REPORT GRI 201-3 Defined benefit plan obligations and other retirement plans The company does not carry out this type of compensation. GRI 201-4 Financial assistance received from government Public grants received: 2019: € 2,386 thousand 2018: € 2,856 thousand GRI 202 MARKET PRESENCE GRI 202-1 Ratio of standard entry level wage by gender compared with local minimum wage 65 GRI 202-2 Proportion of senior management hired from the local community 60

GRI 203 INDIRECT ECONOMIC IMPACTS GRI 203-1 Investment in infrastructure and services of support 34, 91 GRI 203-2 Significant indirect economic impacts 34

GRI 204 PROCUREMENT PRACTICES GRI 204-1 Proportion of spending on local suppliers 80

GRI 205 ANTI-CORRUPTION GRI 205-1 Proportion of spending on local suppliers 20

107 108 5. ABOUT THE REPORT REPORT ABOUT THE GRI 206 GRI Standard GRI 206-1 GRI 205-3 GRI 205-2 ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Legal actions for anti-competitive behaviour, anti-trust, andmonopolypractices ANTI-COMPETITIVE BEHAVIOUR Confirmed cases of corruption andactionstaken Name oftheindicator Communication andtraining onanti-corruption policiesandprocedures CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE group company iscurrently beinginvestigated. in the past to any of the group companies. However, no natural persons who are currently or have been related affect that and corruption alleged to related sumably investigation,pre - under are that cases two areThere 20 19-23 obligations, payment ifapplicable. the of execution the of suspension judicial the of consisting measures precautionary of adoption the requested. be will or requested been has it dition, ate contentious-administrative appeals in which, in ad- resolution and have filed or intend to file the appropri- the with disagree companies affected the cases all in but cases, all in imposed been have Fines group). the ny that as of the date of this report is no longer part of ADASArelatedto(compaS.A.U. Sistemas,cases two - Fergrupo Construçoes e Técnicas Ferroviárias, S.A. and ciones y Sistemas Industriales, S.A.U., a case related to Instala - COMSA to related case A companies: lowing There are four ongoing files that correspond to the fol- Page number orexplanation 109 5. ABOUT THE REPORT REPORT ABOUT THE ENVIRONMENTAL MATERIAL TOPIC GRI 303-4 GRI 303-2 GRI 303 GRI 302-5 GRI 302-3 GRI 302-2 GRI 302 GRI 301-3 GRI 301-2 GRI 303-5 GRI 303-3 GRI 303-1 GRI 302-4 GRI 302-1 GRI 301-1 GRI 301 GRI Standard ANNEX I.SDGsTABLE OFCONTENTS INFORMATION ADITIONAL Water consumption Water discharge Water withdrawal Management ofwater discharge related impacts Interactions withwater asashared resource WATER ANDEFFLUENTS Reductions inenergy requirements ofproducts andservices Reduction ofenergy consumption Energy intensity Energy consumption outsidetheorganization Energy consumption withintheorganization ENERGY Reclaimed products andtheirpackaging materials Recycled inputmaterials used Materials usedby weight orvolume MATERIALS Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 42 42 42-43 46, 49 46 45 45 40-41 44 44 Not reported Not reported 2018: 410.17 2019: 434.19 In relation to theglobalenergy used: Page number orexplanation 110 5. ABOUT THE REPORT REPORT ABOUT THE GRI 306-3 GRI 305-6 GRI 305-5 GRI 305-4 GRI 305-3 GRI 305-2 GRI 304-4 GRI 304-3 GRI 306-5 GRI 306-4 GRI 306-2 GRI 306-1 GRI 306 GRI 305-7 GRI 305-1 GRI 305 GRI 304-2 GRI 304-1 GRI 304 GRI Standard ANNEX II.GRITABLE OFCONTENTS INFORMATION ADITIONAL Water bodiesaffected by water discharge and/or runoff Transport ofhazardous wastes Significant spills Waste by typeanddisposalmethod Water discharge by qualityanddestination EFFLUENTS ANDWASTE Nitrogen oxides (NOX), sulfuroxides (SOX), andothersignificantairemissions Emissions ofozone-depleting substances (ODS) Reduction ofGHGemissions GHG emissions intensity Other indirect (Scope 3)GHGemissions Energy indirect (Scope 2)GHGemissions Direct (Scope 1)GHGemissions EMISIONES affected by operations IUCN Red List speciesandnational conservation list specieswithhabitats inareas Protected orrestored habitats Significant impactsofactivities,products, and services onbiodiversity areas ofhighbiodiversity value outsideprotected areas Operational sites owned, leased,managedin,oradjacent to, protected areas and BIODIVERSITY Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 39 46, 48 47 47 47 47 50 50 Not reported Does notapply Not reported Not reported Not reported Not reported Not reported Not reported Page number orexplanation 111 5. ABOUT THE REPORT REPORT ABOUT THE GRI 308-2 GRI 308-1 GRI 308 GRI 307-1 GRI 307 GRI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Negative environmental impactsinthesupply chainandactionstaken New suppliersthat were screened usingenvironmental criteria SUPPLIER ENVIRONMENTAL ASSESSMENT Non-compliance withenvironmental laws andregulations ENVIRONMENTAL COMPLIANCE Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 82 81 2019 There have beennoenvironmental judgmentsduring Page number orexplanation 112 5. ABOUT THE REPORT REPORT ABOUT THE SOCIAL MATERIAL TOPIC GRI 403-10 GRI 403-09 GRI 403-08 GRI 403-07 GRI 403-06 GRI 403-05 GRI 403-04 GRI 403-03 GRI 403-02 GRI 402 GRI 401-3 GRI 401-2 GRI 403-01 GRI 403 GRI 402-1 GRI 401-1 GRI 401 GRI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Work-related illhealth Work-related accidents Employees covered by ORPmanagementsystems Prevention andmitigation ofhealthimpactsrelated to labourrelations Occupational healthpromotion Employee training inORP Employee participation inORP service Occupational healthservices: description andmechanismsto ensure quality Risk identification andincidentinvestigation ORP managementsystem OCCUPATIONAL HEALTH ANDSAFETY 2018 Minimum notice periodsregarding operational changes LABOUR RELATIONS Parental leave time employees Benefits provided to full-timeemployees that are notprovided to temporary orpart- New employee hires andemployee turnover EMPLOYMENT Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE of the 77 77 75-76 74 78 75 75 74 74 73 69 65 64, 98-99 Established by collective agreement Page number orexplanation , 78 113 5. ABOUT THE REPORT REPORT ABOUT THE GRI 406 GRI 405-2 GRI 405 GRI 404-3 GRI 404-2 GRI 407-1 GRI 407 GRI 406-1 GRI 405-1 GRI 404-1 GRI 404 GRI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL bargaining may beat risk Operations andsuppliersinwhichtherightto freedom ofassociation andcollective FREEDOM OFASSOCIATION ANDCOLLECTIVE BARGAINING Incidents ofdiscrimination andcorrective actionstaken NON-DISCRIMINATION Ratio ofbasicsalaryandremuneration ofwomen to men Diversity ofgovernance bodiesandemployees DIVERSITY ANDEQUAL OPPORTUNITY reviews Percentage ofemployees receiving regular performance andcareer development Programmes for upgrading employee skillsandtransition assistance programmes Average hoursoftraining peryear peremployee TRAINING ANDEDUCATION Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE They have notbeendetected. 80 66 60-63, 71 65 59 67 There have beennoincidentsin2018 orin2019. Page number orexplanation , 67-68 114 5. ABOUT THE REPORT REPORT ABOUT THE GRI 414-2 GRI 414 GRI 413-2 GRI 413 GRI 412-3 GRI 411 GRI 410 GRI 409 GRI 414-1 GRI 413-1 GRI 412-2 GRI 412-1 GRI 412 GRI 411 GRI 410-1 GRI 409-1 GRI 408-1 GRI 408 GRI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Negative socialimpacts inthesupplychainandactionstaken New suppliersthat have passed selection filters according to socialcriteria SOCIAL EVALUATION OFPROVIDERS communities Operations withsignificantactualandpotential negative impactsonlocal programmes Operations withlocalcommunity engagement,impact assessments, anddevelopment LOCAL COMMUNITIES that underwent humanrightsscreening Significant investment agreements and contracts that include humanrightsclausesor Employee training onhumanrightspoliciesorprocedures Operations that have beensubjectto humanrightsreviews or impact assessments HUMAN RIGHTS ASSESSMENT Cases ofviolations oftherightsindigenouspeoples RIGHTS OFINDIGENOUSPEOPLES Security personneltrained inhumanrightspoliciesorprocedures SECURITY PRACTICES labour Operations andsuppliersat significantrisk for incidentsof forced or compulsory FORCED ORCOMPULSORY LABOUR Operations andsuppliersat significantrisk for incidentsofchildlabour CHILD LABOUR Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 82 81 34, 50-51 34, 37 82 23 80 80 80 there isariskofhumanrightsviolations The company hasnotidentifiedsituations inwhich There isnorecord ofcasesin2019 Page number orexplanation , 87-91 115 5. ABOUT THE REPORT REPORT ABOUT THE GRI 416-2 GRI 419-1 GRI 419 GRI 418-1 GRI 418 GRI 417-3 GRI 417-2 GRI 417-1 GRI 417 GRI 416-1 GRI 416 GRI 415-1 GRI 415 GRI Standard ANNEX I.GRITABLE OFCONTENTS INFORMATION ADITIONAL Non-compliance withlaws andregulations inthesocial andeconomic area SOCIOECONOMIC COMPLIANCE losses ofcustomer data Substantiated complaints regarding concerning breaches of customer privacy and CUSTOMER PRIVACY Incidents ofnon-compliance concerning marketing communications Incidents of non-compliance concerning product and service information and labelling Requirements for product andservice information andlabelling MARKETING ANDLABELLING Assessment ofthehealthandsafety impactsofproduct andservice categories Evaluation oftheimpactsonhealthandsafety oftheproducts andservices CUSTOMER HEALTH ANDSAFETY Political contributions PUBLIC POLICY Name oftheindicator CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 85 5,120 euros field ofOccupational RiskPrevention amounting to Management, S.A.U. hasreceived asanctioninthe In 2019, thecompany COMSA Service Facility There isnorecord ofcasesin2019 Does notapply Does notapply Does notapply There isnorecord ofcasesin2019. No politicalcontributions were madein2018 nor2019. Page number orexplanation 116 5. ABOUT THE REPORT REPORT ABOUT THE to theUnited Nations SDGs”sectionofthisreport, aswell assomeSDGsto whichitcontributes indirectly: Below are thesectionsinwhichyou canfindmore information on COMSA Corporación’s contribution to eachoftheobjectives introduced inthe“Commitment SDG ANNEX II.SDGSTABLE OFCONTENTS sustainable industrialization andfoster innovation Build resilient infrastructure, promote inclusive and and decent work for all economic growth, fullandproductive employment Promote sustained, inclusive andsustainable and modernenergy for all Ensure access to affordable, reliable, sustainable water andsanitation for all Ensure availability and sustainable managementof and girls Achieve genderequalityand empower allwomen and promote lifelong learningopportunitiesfor all Ensure inclusive andequitablequalityeducation at allages Ensure healthy lives andpromote well-being for all nutrition andpromote sustainable agriculture End hunger, achieve food securityandimproved End poverty inallitsforms everywhere Implication INFORMATION ADITIONAL CONTENTS ANNEX I:GRITABLE OF OF CONTENTS ANNEX II:SDGSTABLE 10 73 11 11 11 11 59 87 11 87 87 Page , , , , , , 18 37 37 59 59 , , 37 87 87 , , , , 52 69 73 52 , , , 59 78 87 , , SDG resilient andsustainable Make citiesandhumansettlementsinclusive, safe, Reduce inequalitywithinandamongcountries the globalpartnershipfor sustainable Strengthen themeansofimplementation andrevitalize development Promote peaceful andinclusive societiesfor sustainable biodiversity loss tification, andhalt reverse landdegradation andhalt ecosystems, sustainably manageforests, combat deser- Protect, restore andpromote sustainable useofterrestrial marine resources for sustainable development Conserve and sustainably usetheoceans, seasand developments in renewable energy its impacts by regulating emissions and promoting Take urgent actionto combat climate changeand Ensure sustainable consumption andproduction patterns Implication 87 10 59 11 18 37 activity the company according to Out ofreach 10 10 Page , , , , 52 , , 37 37 37 87 87 , , , , 87 52 48 52 , HEADQUARTERS

Numancia Building 1 47 Viriato Street Barcelona, Spain 08014 T +34 933 662 100

6A Julián Camarillo Street, 2nd floor Madrid, Spain 28037 T +34 913 532 120 www.comsa.com