Governance and integrity policy

Index

1. Target
2. Scope and Scope of application
3. Reference frameworks
4. Principles of action
5. Updating and revision
6. Communication and dissemination

1. Objective

This policy of good governance and integrity is the embodiment of the firm commitment of Grupo de ingeniería y arquitectura cañas y asociados S.L.P. hereafter ICA-GRUPO with integrity and transparency in its business activities. All the people who make it up, and especially the management, are committed to complying with it and making it known to its stakeholders.

It seeks to promote the management of ICA-GRUPO The company ensures that its employees and companies with which it has commercial ties are guided by criteria of honesty, integrity, transparency and efficiency, and that their actions are oriented towards the fulfilment of the foundational objectives and goals.

• Good governanceThe capacity to direct the entity towards the achievement of its strategic objectives and goals, promoting the fulfilment of ethical principles and values and the prioritisation of the general interest over the particular, making visible to the community the way it is managed and the results obtained.
• Conflict of interestThe situation whereby a person, by virtue of his activity, is in a position to benefit himself or a third party from the choices he makes in relation to different behavioural alternatives.
• Corporate governanceThe way in which entities are managed, improving their internal and external functioning, seeking efficiency, transparency and integrity, in order to respond adequately to their stakeholders, ensuring ethical organisational behaviour.

2. Scope and Scope of application

The integrity and governance policy stands as our moral compass, together with established labour standards and procedures, to ensure integrity and prevent any wrongdoing in our company.

It is aimed at all employees of ICA-GRUPOregardless of the type of contract, hierarchical position or work location. All employees must comply with the laws in force in the place where they carry out their activity and must know, observe and comply with the provisions of this code of ethics.

Reference frameworks

• Good Governance Code of the Comisión Nacional del Mercado de Valores (CNMV).
• Capital Companies Act, Royal Legislative Decree 1/2010, of 2 July.
• Audit Law 22/2015, of 20 July 2015; and Royal Decree 2/2021, of 12 January.
• Law on transparency, access to public information and good governance, Law 19/2013 of 9 December.
• Law 2/2023 of 20 February on the protection of persons who report regulatory infringements and the fight against corruption.

4. Principles for action

• Legalityall professional relationships are based on respect for constitutional principles, laws and the dignity of individuals with the promotion of transparent, responsible and ethical governance practices in the management of the company, ensuring accountability and the protection of the interests of its stakeholders.
• TransparencyThe annual accounts are made accessible to anyone who requests them. In addition, through the Global Compact Progress Report, we report on our activities in the areas of human rights, labour standards, environment and anti-corruption. As an entity, we are committed to accountability, to provide accurate and real information on management and results on an ongoing basis.
• Efficiency and professionalismThe staff of the ICA-GRUPO puts its professional and human skills and abilities to carry out all that has been entrusted to us; giving more than what is expected of us and exercising our functions and activities in strict compliance with the law.
• ConfidentialityWe are committed to professional secrecy and data protection law and maintain the confidentiality of information relating to the company at all times. We undertake not to disclose, either internally or externally, confidential information about persons or activities related to the company. We do, however, provide the information necessary for other employees to properly perform their duties, in strict compliance with this duty of confidentiality. We avoid any conduct that violates free competition or constitutes an act of unfair competition.
• Honesty and avoidance of conflict of interestWe are committed to disclosing any personal or professional relationships that may influence our job performance. We reject any form of improper compensation or benefit, and encourage honesty and ethics in all our business and professional interactions, both in the private sector and in our dealings with public entities. We do not offer gifts or promise undue favours to third parties, whether public or private, in order to gain undue advantage. We promote transparency by reporting any gifts or benefits received from third parties and making them available to the company. Any personal or professional relationship that may affect the interests of the company is reported to our line manager. We do not allow personal or family relationships within a direct reporting line or within the same organisational unit.

In line with the above, we recognise and adhere to the following integrity guidelines:

• We avoid any situation in which direct or indirect personal interests conflict with those of the company or could interfere with the ethical and transparent performance of our duties, objectivity and professional impartiality.
• We have zero tolerance for corruption.
• We give more than is expected of us and exercise strict compliance with the constitution and the law in the exercise of our duties.
• We denounce illegalities and irregularities.
• We do not use privileged or confidential information for our own benefit or for the benefit of others.

5. Updating and revision

This Policy is developed by the Directorate of  ICA-GRUPO  and is reviewed on a regular basis annual and whenever deemed advisable, due to major changes in the activity or structure of the company or changes in legislation and market rules.

6. Communication and dissemination

ICA-GRUPO disseminate the policy internally and externally through:

1. Regular internal communications to all employees.
2. Making it available and permanently updated on the corporate website.
3. The location of this policy on the corporate intranet.
4. The ICA-GRUPO provide regular training and awareness-raising sessions on the subject.

The Company will not tolerate discrimination or retaliation against employees who report violations in good faith, and will take disciplinary action against those who violate this Policy, including dismissal if necessary.

This Policy was approved by the Directorate General from ICA-GRUPO, the day 28 April 2025.