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					FCC Group Code of Ethics




                           June 2008
Contents
FCC Group Code of Ethics

Message from the Chairman

1. Objective

2. Mission, vision and values

3. Scope of application

4. Acceptance and compliance

5. Reporting procedures

6. Guidelines of conduct
     6.1. Basic principles of conduct
     6.2. Relations with and between employees
     6.3. Internal control and fraud prevention
     6.4. Commitment to the market, the company and the
     community

7. Code of Ethics responsibilities

8. Validity of the Code

9. Help and information




                                                      2
Message from the Chairman
Showing and commanding respect for the values and principles included in this Code of Ethics
is essential for the FCC Group’s growth and success.

Our company’s growth, internationalisation and diversification has led us to integrate
organisations with different cultures and backgrounds. Diversity is an asset that strengthens
and improves us but we have to be sure that values and principles of conduct are in place and
shared by all the organisations and people forming the FCC Group.

This Code of Ethics has been prepared to unify and underline the FCC Group’s identity,
culture and guidelines of conduct. We feel certain that a single culture based on shared values
enhances our virtues and capacities and helps create value for our shareholders and all our
stakeholders.

Our commitment is to show and command respect for this Code of Ethics, applied to all our
initiatives and based on strict compliance with all applicable legislation in our fields of activity.

The Code of Ethics sets out to anticipate the possible events and circumstances in which we
could find ourselves as FCC Group employees. However, not all eventualities are covered. The
Code is a tool for directing and guiding our initiatives on certain social, environmental or
ethical aspects of particular importance to our Group and to all of us.

Respecting the provisions of this Code takes us forward and helps us grow as a company.
Everybody is involved. Our reputation and our future as a standard-bearing international
group depends on everybody continuing to conduct themselves in an honest, upright and
transparent manner; every day and in all our activities and in all the countries in which we
operate.

Finally, I cannot emphasise enough that living and working according to the values and
principles of this Code lends us dignity and makes us better; as individuals and as the FCC
Group.


Madrid
June, 2008




                                                                                                   3
1. Objective
The objective of the Code of Ethics is to establish the values which should govern conduct
within the FCC Group, consolidating a shared culture and guidelines of behaviour that are
accepted and respected by all its employees.

This Code is intended to provide guidance in the relations of Group employees, both with
their colleagues and with other Group stakeholders. The expected conduct reflects the ideals
of the FCC Group, as defined in the section on its Mission, Vision and Values.

2. Mission, Vision and Values
The company creates value for society and its shareholders, designing, constructing and
managing works, infrastructures and services which contribute to the wellbeing of individuals
in a safe, efficient and sustainable manner.

The FCC Group aspires to be a standard-bearer for excellence in the design and
implementation of solutions for advancing public wellbeing, social progress and sustainable
development. FCC is a diversified and cohesive group, committed to its employees and
admired for its capacity to create value and find innovative responses to the new needs of
society.

The values shared by the individuals who comprise the FCC Group are efficiency,
excellence, innovation, commitment, integrity, responsibility and teamwork.

This Code of Ethics should be a reference for all FCC Group activities and for the conduct of
its employees. The Group will also promote awareness of the Code amongst its customers,
suppliers, collaborating companies and other stakeholders.



                                               FCC Group                                              “We aspire to be a standard-bearer for
                                                                                                      excellence in the design and implementation
                                                                                                      of solutions for advancing public wellbeing,
                                                Vision                                                social progress and sustainable development.
                                                                                                      A diversified and cohesive group, committed
                                                                                                      to its employees and admired for its capacity
                                                                          Responsibility
        Commitment




                                                                                                      to create value and find innovative responses
                     Efficiency




                                                 Innovation
                                  Excellence




                                                                                           Teamwork
                                                              Integrity




                                                                                                      to new social needs”


                                                                                                      “We create value for society and for our
                                                                                                      shareholders, designing, constructing and
                                                                                                      managing works, infrastructures and
                                                                                                      services which contribute to the wellbeing
                                                Mission                                               of individuals in a safe, efficient and
                                                                                                      sustainable manner”




                                                                                                                                                      4
3. Scope of application
This Code of Ethics is addressed to all the directors, managers and personnel (hereinafter,
referred to generally as “individuals” or “employees”) of the companies forming the FCC
Group, irrespective of their terms of contract, position or the geographical area in which they
work.

The FCC Group operates in a number of different countries, where existing standards and
regulations may differ from this Code of Ethics. When discrepancies arise between local
standards, laws and regulations and the present Code, employees will give preference to the
more rigorous of the two standards.

It is the responsibility of all Group employees to know and comply with those laws applicable
to their duties, position and place of work. In all cases the FCC Group will provide them with
the resources necessary to acquire appropriate knowledge and understanding of the local
legislation applicable to their professional duties.

When queries arise, FCC Group employees may seek advice and clarification from their
immediate superiors as well as the other resources established to further awareness and
understanding of the Code of Ethics and adherence to its principles, as described below.

The FCC Group will provide employees with the resources necessary to comply with the
principles of conduct contained in the present Code of Ethics and ensure that they are adhered
to by others.




                                                                                             5
4. Acceptance and compliance
Compliance with this Code of Ethics is mandatory for all Group personnel.

The FCC Group undertakes to ensure that all its employees are familiar with the content of the
Code and adhere to its principles.

The FCC Group expects honest, upright and transparent conduct from all its personnel, in line
with the company’s Code of Ethics. All employees may be evaluated in regard to their
compliance with this Code. Possible infringements will be analysed in accordance with internal
regulations, current labour agreements and, where applicable, prevailing legislation.

Any uncertainties concerning the interpretation or application of this Code of Ethics should be
made known to employees’ superiors or, where applicable, any other individuals or authorities
designated by the FCC Group to promote awareness of its Code of Ethics and safeguard its
integrity.

No one, irrespective of their position in the Group, is authorised to ask an employee to violate
the Code of Ethics. No employee may justify malpractice on the grounds that they were acting
on the orders of a superior or lacked familiarity with the principles of the Code.

Infractions of the Code of Ethics could potentially jeopardise the stability of the FCC Group
and compromise its reputation, and Group employees are therefore obliged to report any
breach or violation they may observe.

The FCC Group has provided its employees with different channels for reporting possible
breaches of the present Code of Ethics.




                                                                                              6
5. Reporting procedures
In addition to their own adherence to its principles, FCC Group employees have a duty to
ensure global compliance with the company’s Code of Ethics.

The Group has established channels of communication which allow its employees to submit,
in good faith and without fear of reprisal, confidential notifications of inappropriate conduct.

General reporting procedure on matters relating to the Group’s Code of Ethics

The FCC Group has implemented a reporting procedure to allow all of its employees to
submit confidential notifications of those acts which they believe to constitute inappropriate
conduct or behaviour as defined by the company’s Code of Ethics. Employees may also make
use of the procedure to submit queries or propose improvements to the company’s existing
systems regarding matters relevant to the Code.

The procedure for reporting matters relating to the Group’s Code of Ethics is supervised by
the Internal Code of Conduct Monitoring Committee, which is also responsible for the
application, interpretation and monitoring of compliance with the rules included in the
company’s internal code of conduct 1.

With respect to the Code of Ethics of the FCC Group, the duties of the Monitoring
Committee are as follows:

         Safeguard effective operation of the channels of communication available to FCC
         Group employees for reporting on matters relating to its Code of Ethics.

         Process the notifications received so that they may be appropriately resolved by the
         corresponding FCC Group units.

         Further awareness of the Code of Ethics amongst Group employees and third parties
         outside the company.

         Prepare regular reports on the Group’s level of compliance with its Code of Ethics,
         making the recommendations it considers necessary to improve its contents, facilitate
         its understanding or safeguard its integrity.



Employees may submit confidential notifications on matters relating to the Code of Ethics, in
good faith and without fear of reprisal, to the Secretary of the Monitoring Committee through
the following channels:

         A html page on the Group’s Intranet.

1Internal code of conduct for the securities market of Fomento de Contrucciones y Contratas, S.A. and its
corporate group.



                                                                                                            7
        By e-mail

        By letter, addressed to a PO box.


All notifications received through these channels of communication will be treated
confidentially.

Once the Monitoring Committee has seen and evaluated a notification it will determine the
following:

    a) The admissibility of the notification.
    b) Whether it should be forwarded to one of the channels described below (“specific
       procedure regarding potentially serious irregularities, especially those of a financial or
       accounting nature”; “specific procedure for the prevention of workplace and sexual
       harassment”), if, due to its content, the committee considers that this would be
       appropriate. In this event the employee who issued the notification would be duly
       informed.

Once the admissibility of a notification has been determined, the Committee, after following
the necessary procedures, may:
    a) adopt the corresponding solution.
    b) submit the proposal to the head manager of the area involved, or, where applicable, to
       the managing director of the Group.


Specific procedure regarding potentially serious irregularities, especially those of a
financial or accounting nature

The Audit and Control Committee of the FCC Group has a specific procedure for reporting
potentially serious irregularities, especially those of a financial or accounting nature, as well as
possible improvements to the internal control system, procedures and accounting practices.
The procedure is a response to the requirements established in article 41.3 of the regulation
governing the board of directors of FCC and to recommendation 50.d of the Unified Code of
Good Governance of the Spanish National Securities Market Commission.

Employees may submit their confidential notifications on the aforementioned matters, in good
faith and without fear of reprisal, to the representative of the Audit and Control Committee
through the following channels:
        An html page on the corporate intranet: internal communication channel.
        By post, addressed to the stated PO box number and clearly marked Personal-
        Confidential.

Notifications received by this means will be dealt with according to the corresponding specific
procedure.




                                                                                                  8
Specific procedure for the prevention of workplace and sexual harassment

Similarly, the FCC Group has a specific protocol for the prevention of workplace and sexual
harassment, which is included on its intranet. This protocol establishes the obligation for
employees to report any possible violation of its principles to the General Director of Human
and Other Resources, or to the Human Resources manager of their work centre. The
principles of the protocol relate to issues such as the prevention of harassment, the obligation
to treat others with impartiality, fairness and respect, and equal opportunities for training and
promotion.

Employees can send their confidential notifications on the aforementioned matters, in good
faith and without fear of reprisal, to the established e-mail address.

Notifications received by this means will be resolved according to the procedure established in
the aforementioned protocol.

Commitment to furthering awareness of the Code of Ethics and adherence to its
principles

The FCC Group will provide employees with the resources necessary to further awareness of
the principles of conduct which comprise the present Code of Ethics and ensure that they are
globally respected.

Commitment to preventing reprisals

The FCC Group has formally declared that it will not tolerate reprisals against those
individuals who make use of the procedures established for reporting irregular conduct.

The right to privacy

The right to privacy is one of the rules of conduct of the FCC Group. The Audit and Control
Committee, its representative, and any of the other Group authorities responsible for
managing issues relating to this Code of Ethics will exercise the greatest vigilance in defending
this right.




                                                                                               9
6. Guidelines of conduct
Everybody in the FCC Group is required to follow the principles of conduct described below.

6.1. Basic principles of conduct

Regulatory compliance and respecting ethical values

The FCC Group undertakes to carry out its business and professional activities in line with
prevailing legislation wherever it operates. Legal compliance is always the starting point for
ethical conduct in the Group.

The Group’s activities absolutely respect human rights and public liberties, in accordance with
internationally accepted laws and practices. Conduct in the Group is guided by the Universal
Declaration of Human Rights, the Tripartite Declaration of the ILO, OECD Guidelines for
Multinational Enterprises and the United Nations Global Compact.

The FCC Group also uses resources to oversee compliance with the provisions of the
International Labour Organisation (ILO), particularly with regard to minors, avoiding any
practices in the Group’s companies or collaborators that breach these or other ILO principles.

All FCC employees are required to conduct themselves ethically in all activities and avoid any
behaviour which, even if not illegal, could harm the Group’s reputation and have a negative
effect on its interests and public image.

All Group employees should also be familiar with the applicable rules and regulations for their
professional activity and, where necessary, request the necessary information from senior staff
or the corresponding FCC Group units or authorities.

No employees will knowingly collaborate with third parties in breaching the law or in activities
that compromise the principle of legality or that could, if they became public, harm the
reputation of the FCC Group or its perception by the markets, customers, suppliers or
regulators, for example.

The FCC Group also undertakes to provide all the resources necessary for its employees to
know and understand the legal provisions applicable to their field of responsibility.




                                                                                             10
6.2. Relations with and between employees

Respect for people

In the FCC Group, management of human resources and relations between employees is
always based on respect for people’s dignity and the principles of trust and mutual respect.

The Group expressly prohibits abuses of authority and any other type of harassment, whether
physical, psychological or moral, and any other conduct that could lead to an intimidating,
offensive or hostile working environment.

All FCC Group employees are required to conduct themselves in a respectful, professional and
considerate manner to create a pleasant, rewarding and safe working environment that brings
the best out of people. Relations between FCC and collaborating company personnel are also
based on the above criteria, professional respect and mutual assistance.


Professional development, equal opportunities and non-discrimination

The FCC Group guarantees equal opportunities and undertakes to provide resources to help
its employees develop professionally and personally.

The Group does not tolerate any type of discrimination based on gender, race, sexual
orientation, religious beliefs, political opinions, nationality, social background, disability or any
other circumstance that could be a source of discrimination.

The FCC Group supports and undertakes to implement and develop public policies aimed at
promoting more equal opportunities and a merit-based culture.

Recruitment and promotions in the FCC Group are always based on merit and in objective
and transparent situations and evaluations. The Group’s employees are informed of the
methods and procedures used for professional advancement and development in the Group.

FCC also undertakes to provide resources to further the knowledge and training of its
employees and update their skills, in order to facilitate their professional development and
contribute greater value to customers, shareholders and the general public.

The FCC Group also understands the importance, for people’s full development, of a balance
between professional and personal life. Measures and initiatives are implemented to help
employees achieve such a balance.




                                                                                                  11
Teamwork, collaboration and dedication

The FCC Group considers that collaboration, teamwork and finding synergies are vital for
achieving its objectives and taking full advantage of the capacities, resources and diverse
knowledge, skills and experience within the Group.

The FCC Group therefore promotes, facilitates and provides incentives for collaboration and
teamwork among the employees forming part of the company and between the Group’s
different units and departments.

All employees are encouraged to act in a collaborative spirit, making their knowledge, skills and
talent available to whoever needs it and thereby help achieve the global interests and objectives
of the FCC Group.

FCC Group employees work efficiently, making the most of their time and company
resources.

The Group earmarks resources and carries out initiatives and activities to promote cultural
cohesion in the organisation, to encourage loyalty, satisfaction and pride amongst its
employees.

Health and safety

The FCC Group dedicates the resources necessary to provide its employees with a healthy and
safe working environment, based on thorough observance of applicable legislation. The Group
also undertakes continuously to improve measures for preventing occupational risks and for
encouraging health in the workplace in each of the sectors and locations where it operates.

The FCC Group also promotes and encourages the adoption of the most up-to-date health
and safety practices in its suppliers, contractors and collaborating companies in general.

All staff are responsible for rigorously complying with occupational health and safety
standards, for their own safety and the general safety of anybody affected by their activities.
Personnel should also make responsible use of any equipment assigned to them when carrying
out risky activities and share risk prevention and health and safety practices and knowledge
with their colleagues.

The FCC Group undertakes to provide the necessary knowledge and resources for its
employees to perform their duties in a healthy and safe environment.




                                                                                              12
6.3. Internal control and fraud prevention

Manipulation of information

The forgery, manipulation or deliberate use of false information constitutes fraud.

The FCC Group treats transparency of information as a principle of conduct; understood as
the commitment to providing markets and society with reliable information that fairly presents
the Group’s activities, strategy and financial, social and environmental performance.

Personnel are required to give full, accurate and comprehensible information. Under no
circumstances can staff knowingly provide incorrect or imprecise information that could lead
to errors on the part of the recipient.

All the FCC Group’s transactions are to be reflected clearly and accurately in the company’s
records. Specifically, all accounts have to be recorded correctly, together with all operations
carried out and all expenses incurred.

In general, FCC Group personnel will abstain from any practice that contravenes the
commitment to reflect transactions clearly and accurately in the Group’s records and will take
particular care to ensure that the information entered in the Group’s IT systems is reliable.

Use and protection of assets

The FCC Group makes the necessary resources available for its employees to carry out their
professional activities. The improper appropriation and inappropriate use of these assets
constitutes fraud.

All personnel are required to protect and make good, responsible use of the Group’s resources,
which are to be protected against any loss, damage, theft or inappropriate use that could result
in damage to the Group’s interests.

Unless expressly permitted otherwise, the Group’s resources are to be used solely and
exclusively for employees to carry out their professional duties and cannot be used for
personal benefit or that of third parties unrelated to the FCC Group's business objectives.

The obligation to protect resources extends to the information and knowledge generated
within the FCC Group, under its ownership or held by the Group.




                                                                                             13
FCC Group personnel also undertake to preserve confidentiality and to make discrete use, in
line with respective internal regulations, of the information to which they have access in
fulfilling their professional responsibilities.

Where in doubt, and unless indicated otherwise, FCC Group employees are to consider the
information to which they have access in the course of their professional duties to be restricted
information.

The FCC Group undertakes to offer its personnel the information, knowledge and resources
necessary to comply with the laws on data protection and information management applicable
in their different fields of activity.

Corruption and bribery

The FCC Group understands corruption as the use of unethical practices to obtain a particular
benefit. Corruption is a category of fraud.

Under no circumstances will FCC Group personnel engage in unethical practices to influence
persons outside the company, for their own benefit or that of the Group. Staff are also to
remain vigilant to ensure that no cases arise in which other persons or organisations make use
of these practices in their relations with the company.

The FCC Group expressly forbids non-contractual or illicit payments to any public or private
individual or entity with the intention of procuring or maintaining business or other benefits or
advantages.

FCC Group personnel will not directly or indirectly make, offer or receive any payment in cash
or in kind or any other benefit that due to its value, nature or circumstances could reasonably
alter the development of the relevant commercial, administrative or professional relations.

Staff will also refrain from facilitation payments or those made to speed up administrative
processes, comprising the delivery of money or other objects of value, regardless of the
amount, in exchange for a guaranteed or streamlined process or action in any judicial body,
public administration or official organisation anywhere in the world.

Money laundering and irregularities in payments

FCC Group employees are required to pay close attention to any possible indications of a lack
of integrity in the individuals or entities with which the company has relations.

FCC Group personnel should pay particular attention to payments in cash unusual for the type
of operation, bearer cheques or payments in currencies different to that previously agreed,
reporting irregularities through the channels and procedures established in this Code of Ethics.
Personnel should also remain vigilant regarding payments made to or from third parties not
mentioned in corresponding contracts, as well as those made in accounts other than those
usually used in relations with a particular entity, company or individual.




                                                                                              14
Payments to individuals, companies, entities or accounts in tax havens and payments made to
entities for which it is not possible to identify the shareholder, owner or ultimate beneficiary
should also be carefully controlled.

Finally, FCC Group personnel will closely review extraordinary payments unforeseen by the
corresponding contracts or agreements.


6.4. Commitment to the market, the company and the community

Respect for free competition and conduct in the market

All FCC Group employees are committed to free competition and compliance with respective
laws in the different countries where FCC operates and avoid any activities that constitute an
implicit restriction or abuse of competition. Employees will also refrain from misleading
advertising of company activities.

Conflicts of interest and loyalty to the Group

Conflicts of interest arise in circumstances in which the interests of FCC Group personnel are
contrary to those of the company, interfere with their duties or lead them to act according to
motives other than fulfilment of their duties.

Relations between the FCC Group and its staff should be based on the loyalty generated by
common interests. The Group respects its employees’ involvement in other financial or
business activities, provided that these are not restricted by internal regulations, that the
activities are legal and do not concur or give rise to possible conflicts of interest with their
responsibilities as FCC employees.

All FCC personnel should avoid situations of possible conflict between their personal interests
and those of the company. Staff will also refrain from representing the company or
participating in or influencing decision-making in situations where they directly or indirectly
have a personal interest.

Political neutrality

The FCC Group develops its business model without interference or involvement in political
processes in those countries and communities where it operates.

Any relations between the FCC Group and governments, authorities, institutions and political
parties are based on the principles of legality and political neutrality.




                                                                                             15
The FCC Group recognises its employees’ right to freedom of expression, political thought
and, in general, involvement in public life, provided that such involvement does not interfere
with their activity in the company, takes place outside working hours and off FCC Group
premises and no external observer could ever associate the FCC Group with a particular
political party.


Relations with customers, contractors and suppliers

The FCC Group works toward the goal of offering the highest levels of quality and achieving
excellence in its services. Its employees are therefore given the necessary resources in their
activities to meet the expectations of the Group’s customers.

The FCC Group will make particular effort to anticipate the needs of its customers and to
place products and services on the market that are better and more suited to customers’
demands.

The FCC Group also considers its contractors, suppliers and collaborating companies in
general as vital for achieving its growth and development goals.

The Group undertakes to put its principles into practice in relations with collaborating
companies and to work actively to pass on its values and principles for action. The Group will
also promote and provide incentives for collaboration with those suppliers and contractors
with proven advanced ethical, environmental and social standards.

All FCC Group personnel that take part in selecting contractors, suppliers and external
collaborators are required to act impartially and objectively, applying transparent criteria in line
with respective internal regulations.

The FCC Group will promote and spread the contents and principles of this Code of Ethics
among its suppliers and contractors, particularly those explicitly referring to the Group's
relations with collaborating companies.



Corporate image and reputation

Responsible public relations in the communities where the FCC Group operates are one of the
key elements of its reputation and image. The FCC Group considers social trust and its
reputation as one of its most valuable assets.

All staff are required to take the maximum care in preserving the company’s image and
reputation in all their professional activities, including those in the public domain. Personnel
will also oversee respect for the Group's reputation and image on the part of contractors,
suppliers and collaborating companies in general.




                                                                                                 16
Respect for the environment

The FCC Group is committed to sustainable development. The FCC Group fulfils its
environmental commitment based on strict compliance with applicable legislation in this
respect in all its fields of operation.

The Group undertakes to carry out its activities with the greatest respect for the environment,
minimising any negative effects these could have.

The Group will also help preserve natural resources and areas of natural beauty or ecological,
scientific or cultural interest. Best practices will be implemented and its employees given the
training necessary to preserve the environment.

These principles will be passed on to contractors, suppliers or external collaborating
companies, which will be required to comply with the environmental requirements and
procedures applicable in each case and will be provided with the necessary resources for
suitable compliance.


Social commitment

The FCC Group undertakes to act responsibly, starting with regulatory compliance in all the
countries where it operates. In particular, it assumes the responsibility to respect cultural
diversity and the customs and principles of the individuals and communities affected by its
activities.

As part of its social commitment, the FCC Group will also evaluate the non-financial aspects
of business projects in which it could become involved and material investments undertaken.
The Group understands that this analysis lends cohesion to the company's commitment to
society and sustainable development.

The FCC Group’s commitment to society takes the form of sponsorships and collaborations,
which are channelled by means of agreements and assigning resources to community
organisations, in line with the company’s strategy.

Based on this commitment and its values of transparency and integrity, all donations made by
the FCC Group require the necessary internal and, where applicable, external authorisations.

Under no circumstances can donations be made to any political parties or their representatives,
except where expressly foreseen by applicable legislation.




                                                                                            17
Donations can also only be made to those organisations with the appropriate organisational
structure to guarantee due administration of resources, and should be properly reflected in the
company's records.

As far as possible, the FCC Group will monitor donations made to verify that these are put to
best use.

The FCC Group will also provide incentives and promote its employees’ involvement with
organisations of social interest in those locations where it operates through corporate
volunteer programmes, for example.




                                                                                            18
7. Code of Ethics responsibilities
Understanding and complying with the principles of this Code of Ethics is a general
responsibility of all the individuals who comprise the FCC Group. However, certain
differences exist with respect to specific duties and positions.

Responsibilities of all employees

All members of the FCC Group and any of the other companies under its management must
comply with the following responsibilities:

   •   Understand and comply with the laws, regulations and standards applying to their
       position

   •   Comply with the principles and standards detailed in the Code

   •   Request advice and clarification, when necessary, from their superiors or the authority
       to whom the Group designates the responsibility of ensuring communication of the
       Code of Ethics and adherence to its principles

   •   Participate in the training activities offered by the company

   •   Report any breach or violation of the standards prescribed by this Code

   •   Collaborate, in good faith, in the development of the controls and internal audits which
       might be carried out to help identify and correct shortcomings or weaknesses in the
       Group.


Additional responsibilities of managers

Those individuals who supervise and manage the work of others have a number of additional
responsibilities.

   •   Lead by example. Their conduct must serve as a model of action with integrity

   •   Ensure that the individuals under their supervision understand the Code’s stipulations
       and have the necessary resources to comply with them

   •   Supervise adherence to the Code’s principles by the individuals they manage and
       supervise

   •   Oversee the conduct of third parties who represent the FCC Group, to ensure
       consistence with Group standards

   •   Enforce compliance with the Code of Ethics of the FCC Group


                                                                                            19
•   Render support to employees who consult them with their queries and concerns in
    good faith

•   Offer their collaboration to guarantee that those individuals who express their doubts
    or concerns in good faith do not suffer reprisals.




                                                                                       20
8. Validity of the Code
The present Code entered into force when approved by the board of directors of FCC, S.A. (in
the meeting held on 10 June 2008) and will remain in effect indefinitely, until the board
authorises that it be updated, reviewed or abolished.

The Code will be reviewed and updated with the regularity indicated by the board of directors.
Possible reviews and updates will depend on the undertakings assumed by FCC with respect to
corporate social responsibility and good governance.




                                                                                           21
9. Help and information
The Code of Ethics comprises the general guidelines which should govern the conduct of all
FCC Group employees.

Employees may address their queries to their superiors or to the authority designated by the
FCC Group to ensure global adherence to the Code’s principles.

If employees require specific advice or clarification regarding the matters included in the Code,
they may also seek assistance from the units and departments which are specialists in those
areas.


Principles of the Code of Ethics           Unit responsible                        Contact e-mail

Basic principles of conduct
Regulatory compliance and respecting Legal Advisory             and    Corporate
ethical values                       Responsibility
Relations with and between employees
Respect for people                         Human Resources
Professional       development,      equal Human Resources
opportunities and non-discrimination
Teamwork, collaboration and dedication     Human Resources
Health and safety                          Human Resources
Internal control and prevention of fraud
                                       Internal Audit – General Finance
Manipulation of information            Management – General Administration
                                       Management
                                       Internal Audit – General Finance
Use and protection of assets           Management – General Administration
                                       Management
                                       Internal Audit – General Finance
Corruption and bribery
                                       Management
Money laundering and irregularities in Internal Audit – General Finance
payments                               Management
Commitment to the market, the
company and the community
Respect for free competition           Legal Advisory
Conflicts of interest and loyalty to the Legal Advisory
Group
Political neutrality                      Secretary General
Relations with customers, contractors and General Services Management
suppliers
Corporate image and reputation            Corporate Social Responsibility
Respect for the environment               Corporate Social Responsibility



                                                                                              22
Social commitment   Corporate Social Responsibility




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