Code of Ethics and Professional Conduct

The revision and improvement of the Code of Conduct to adapt it to international best practices is another step forward in our policy of seeking excellence and positioning ourselves at the forefront of sustainability.

New Code of Ethics and Professional Conduct: at the cutting-edge of sustainability




The Code of Conduct includes new principles and creates a Direct Channel of confidential communication and a Monitoring Committee to deal with enquiries and receive information relating to irregularities.

The revision and improvement of the Code of Conduct to adapt it to international best practices is another step forward in our policy of seeking excellence and positioning ourselves at the forefront of sustainability.

In 2009, the Board of Directors approved a new Code of Ethics and Professional Conduct which is compulsory for all of the company’s professionals. The new Code of Conduct is a revised and improved version of the Code of Professional Conduct approved in 2000, bringing it in line with international best practices, in accordance with our policy of seeking excellence and positioning ourselves at the forefront of sustainability, corporate social responsibility and corporate governance. In drafting the new Code of Conduct, we took into account the requirements of the Unified Code of Good Governance as well as the criteria established by the Dow Jones Sustainability Indexes, the Global Compact and the FTSE4Good CSR Index, among others.

Improvements include the creation of a Direct Channel for confidential communication, through which Indra’s professionals can submit enquiries concerning the interpretation and application of the Code of Conduct, and report any possible irregularities.
A Monitoring Committee, comprising five of the company’s Directors plus other professionals, is commissioned with the task of clarifying doubts, investigating and resolving irregularities, and keeping a record of actions taken. It will also submit an annual report on the degree of compliance with the Code of Conduct to Indra’s administrative and governing bodies.

The Board of Directors’ Audit and Compliance Committee is responsible for supervising the Direct Channel and the actions implemented.

New principles

The new Code of Ethics and Professional Conduct also includes new principles and improves the way existing principles are implemented. This includes the explicit prohibition of corruption and bribery practices, as well as cooperation in the correct operation of internal control systems and other procedures designed to identify or correct deficiencies or weaknesses in compliance, integrity and control systems at Indra. Furthermore, the new document bolsters the protection of privacy, in particular in regard to personal data and the balance between work and outside obligations and activities. Similarly, the Code of Conduct envisages respect for legislation, transparent and truthful disclosure, quality, team work, protection and dissemination of knowledge, equal opportunities, and safeguards for diversity and for the environment.

The Code of Conduct is structured around three principles: integrity, professionalism and respect, which, in turn, are based on the values of determination, rigour, sensitivity and originality that define our conduct.

Link to new Code of Ethics and Professional Conduct