In 2022, Ferrovial’s Board of Directors approved a new Human Rights Policy that reaffirms the company’s commitment to not only respect, support and promote human rights, but also to identify, prevent and mitigate any potential negative impact. It is aligned with the main international standards such as the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the OECD guide for multinational companies and the regulations of the International Labor Organization. Of course, it is also aligned with the internal regulations that support Ferrovial’s Code of Ethics.

One of the pillars of Ferrovial’s strategy is the promotion of diversity and equality. The policy clearly defines the rejection of any type of discrimination in all the company’s activities and in all relations with its stakeholders. To guarantee this, the company has a Global Diversity and Inclusion Strategy, an Equality Plan that is periodically updated (its third version was approved in 2022) and an internal protocol for the Prevention of Workplace and Sexual Harassment. In line with SDG 5, since 2013 Ferrovial has joined the project “Companies for a society free of gender-based violence”, promoted by the Spanish Government. Along these lines, Ferrovial also carried out various actions to raise awareness among its employees on November 25, International Day for the Elimination of Violence against Women.

To reinforce its commitment to diversity, Ferrovial has agreements with organizations that specialize in promoting the incorporation and inclusion of people with disabilities in the different countries in which it operates.

Another of the key principles of the new policy is safety. Ferrovial is therefore committed to creating a safe and healthy working environment for its employees and contractors and promotes the safety of the users of its infrastructures.

The policy also reaffirms the commitment to transparency in all matters relating to the protection of human rights, and makes explicit with regard to the previous one approved in 2014, Ferrovial’s commitment to the right to digital disconnection, respect for confidentiality and the right to privacy and analyzes the implications for the company in relations with all its stakeholders:

• Employees: child labor, forced labor, modern slavery, human trafficking, sexual harassment, work-life balance, digital disconnection, right to association, etc.
• Customers: quality, health and safety standards.
• Communities: rights of indigenous and local communities, minorities and vulnerable populations. Environmental protection.
• Suppliers, contractors and partners: due diligence procedures in selection processes. Repair and remediation of negative impacts.

This policy is available to all of them. But it is especially employees and managers who are responsible for ensuring compliance in all Ferrovial activities. An internal communication campaign has been carried out to publicize this new policy and the tools available to ensure compliance. This dissemination reinforces other actions such as courses on the Code of Ethics and on anti-corruption, which are renewed and updated periodically and include specific modules to explain the possible implications on human rights.

The Ethics Line is available to employees and other stakeholders. It allows any interested party to report possible situations of harassment and other discriminatory practices. It is accessible by telephone, mail, intranet or the Ferrovial website, allowing communications to be made confidentially or anonymously if so desired. Ferrovial protects communicators or whistleblowers from any possible retaliation. Since 2017, the Ethics Line has incorporated several points related to Human Rights.

Dialogue with stakeholders is continuous. The company participates in various forums to improve the identification of key issues. Since 2021, Ferrovial has been involved in an investor dialogue program on modern forms of slavery led by Sustainalytics. Furthermore, in 2022 it has participated with third-sector organizations and universities in dialogue sessions on human rights and due diligence and continues to be involved in platforms, networks and working groups such as the Forética Business Council for Sustainable Development, the Human Rights Lab of the Seres Foundation, the Executive Committee of the Global Compact Network, the CEO Alliance for Diversity initiative or the Diversity Charter, a European initiative that is part of the European Union’s anti-discrimination directives.

COMMITMENT TO LABOR RIGHTS

The preservation of labor rights is of special relevance among Ferrovial’s commitments. It rejects any type of child or forced labor in any form, guarantees equal opportunities and non-discrimination, protection against harassment of its workers, the right to strike, freedom of association and the right to collective bargaining in all countries in which it operates, and promotes the work-life balance. Its employees are protected by the labor regulations of the different territories. Additionally, 59.2% of Ferrovial’s workforce is covered by collective bargaining agreements.

To meet the needs of its employees and promote healthy habits and healthy work environments, Ferrovial has internal communication channels and tools that facilitate the creation of collaborative and dynamic work environments. In 2022 Ferronet, Ferrovial’s intranet, registered 2,940,043 sessions and 4,499,139 page views.

Ferrovial has also analyzed internally that the remuneration of its employees is above the living wage in countries with the highest activity (Spain, United Kingdom, Chile, USA and Poland), understood as the remuneration that a person or family must receive to meet their basic needs for food, housing, transportation, clothing or health services, among others. After this analysis, it can be affirmed that all employees have a remuneration higher than the living wage corresponding to their country.

ENSURING DUE DILIGENCE IN HUMAN RIGHTS

Ferrovial has implemented a set of tools that promote the protection of and respect for human rights in order to ensure due diligence in human rights in the company’s activities.

As part of these due diligence mechanisms, Ferrovial periodically evaluates potential risks to human rights as part of the risk identification and assessment process known as Ferrovial Risk Management (FRM). The FRM process identifies and prioritizes risk events according to their probability and impact. FRM defines at least 8 categories related to human rights, which in 2022 have registered 33 potential risks in all the company’s projects, most of them related to data protection or security (79%). Most of the risks identified are slight or moderate (94%).

In addition to assessing the risk, the person in charge identifies for each risk the controls implemented to mitigate or eliminate it, either its impact or its probability of occurrence.

Moreover, the company has a procedure for approving capital allocation operations, so that the analysis of all corporate operations carried out takes into account whether they may undermine Ferrovial’s ethical principles, with special attention to human rights, social, good governance and environmental aspects.

HUMAN RIGHTS IN THE VALUE CHAIN

To ensure the effective preservation of human rights in the value chain and respect for the company’s ethical standards, Ferrovial has had a Supplier Code of Ethics in place since 2021 to establish the basic principles that should govern the behavior of suppliers in their commercial relationship with the company.

The Supplier Code of Ethics includes, among its principles, respect for human rights and the abolition of child labor. The procedure establishes the general criteria for the ethical integrity due diligence process in the selection of a supplier and its follow-up during the term of the business relationship.

Before signing the contract, acceptance of both the Supplier Code of Ethics and the Anti-Corruption Policy will be ensured and then monitored during the term of the contract.

Ferrovial has a due diligence procedure for ethical integrity of third parties. This procedure must be followed prior to reaching a collaboration, partnership or any other type of agreement with a third party (non-supplier). It aims to prevent attitudes and actions contrary to human rights in relations with third parties. To facilitate compliance in 2021, an online tool was implemented to facilitate the process. In 2022, 199 third parties have been analyzed, and 10% have had a high final risk rating.