Code of Ethics and Direct Channel

Indra has a Compliance Model comprising the Criminal Risk Prevention Model and the Competition Law Risk Prevention Model, aimed at promoting a culture of compliance and preventing any activity that violates the law within the scope of our business. The Audit and Compliance Committee of the Board of Directors is the highest control body of the Model and the Compliance Unit is responsible for the implementation and execution of the Model.

Both Senior Management and the Board of Directors are firmly committed to fostering a strong culture of compliance and integrity. This culture is based on "doing the right thing" and applies to all Indra Professionals and Collaborators (representatives, suppliers and other third parties who provide services for Indra or who, in any way, act on its behalf), who, as a whole, are responsible for carrying out their activity in compliance with current legislation and applying Indra's principles of action.

In order to comply with these principles of action and with the aim of maintaining an environment of control and continuous improvement in this area, Indra has a Code of Ethics and Legal Compliance, with a Whistleblower Channel (Direct Channel), both of which are the controls par excellence of our Compliance Model:

Code of Ethics and Legal Compliance

Indra's Code of Ethics and Legal Compliance provides an unbreakable frame of reference, establishing the following Corporate Principles and Standards of Conduct: 

Corporate Principles:

  • Integrity: acting in good faith and establishing professional relationships based on transparency and ethics.
  • Professionalism: maintaining a proactive attitude aimed at excellence in our performance.
  • Respect: facilitating an attitude of recognition of the value of people and their work, the environment and the social environment in which we operate.

Standards of conduct relating to:

  • Compliance with the law
  • Rejection of corruption and bribery. In this regard, Indra has internal procedures that regulate the hiring of business consultants and strategic advisors, as well as the request for donations and sponsorships.
  • Conflicts of interest
  • Information Security
  • Equality and non-discrimination
  • Foreign trade in defence and dual-use material
  • Public subsidies and grants
  • Sustainability
  • Good tax practices
  • Economic and financial information management
  • Protection of competition
  • Money laundering and terrorist financing
  • Occupational health and safety
  • Relations with governments and authorities

The Code of Ethics also reflects the company's commitment to respect the Human Rights recognised, within the framework of the United Nations Guiding Principles on Business and Human Rights, in the International Bill of Human Rights and the principles relating to rights established in the Declaration of the International Labour Organisation.

Likewise, the Code of Ethics, the Criminal Risk Prevention Model, the Competition Law Risk Prevention Model, Indra's procedures and policies establish a series of guidelines for action and controls that are executed periodically in the different areas of the company in order to mitigate potential risks of crimes being committed, either by Indra professionals or by third party collaborators.

Direct Channel

The Direct Channel (, also available on the Company's internal and external website and including the possibility of anonymous communications, is the mechanism made available to Indra Professionals and Collaborators, as well as other third parties with a legitimate interest, to communicate to Indra any doubts regarding the interpretation and application of the Code of Ethics and its implementing regulations, and to which they must report any infringement of the Code of Ethics and its implementing regulations, as well as other infringements or offences under the terms set out in Appendix 4 of the aforementioned Code.

In compliance with Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption, Indra has appointed the Chief Compliance Officer as the person responsible for the internal information system, who carries out his functions independently and autonomously. He also has the active involvement and supervision of the Company's Compliance Model by its governing body and Senior Management. To this end, and as mentioned above, la Indra's Audit and Compliance Committee is responsible for supervising the operation, effectiveness and compliance of this Model.

Indra has defined an organisation chart and organisational model that establishes the functions, responsibilities and reporting lines of each of the organisation's departments in all the businesses and countries in which it operates. This organisational chart is available internally to all professionals on a global scale through the corporate Intranet. This, together with the Code of Ethics and Legal Compliance, allows us to establish a regulatory and behavioural framework throughout the organisation.

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