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Annual Report 2022

Annual Report
2022

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ESG: Sustainability

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ESG: Sustainability

Corporate
governance

Respect for human rights is one of the main obligations that Saba takes on in the development of its operations and actions. The Group uses as its benchmark the regulations set forth in the United Nations Guiding Principles on Business and Human Rights and in the Guidelines of the Organisation for Economic Co-operation and Development (OECD). In addition, the main conventions of the International Labour Organization (ILO) in the field of labour rights are strictly followed, as well, in general, as the legal requirements of each country in which Saba operates.

Saba has a Code of Ethics, approved in 2013, that establishes the benchmark ethical framework that must govern the behaviour of the company and its employees, which is also available on the corporate website.

www.sabagroup.com/en/group/what-is-saba

As established in Article 5 of the Code of Ethics, Saba undertakes to act at all times in accordance with current legislation and with respect for human rights and the freedom of individuals. Specifically, with respect to human rights, Article 6 of the Code of Ethics establishes that Saba does not accept any conduct when dealing with consumers or third parties that may be interpreted as discrimination based on race, ethnicity, gender, religion, sexual orientation, union affiliation, political ideas, convictions, social origin, family situation or disability, or as intimidating or offensive behaviours. Saba also has a Prevention and Action Protocol against Workplace and/or Sexual Harassment, available to all employees.

In the development of the principles of the Code of Ethics, Saba has approved a Policy for Prevention of Corruption and for Relations and Correspondence with the Authorities and third parties, as well as internal regulations developing that policy, in order to set the criteria that the companies that make up the Group must meet in dealing with Public Authorities and both domestic and foreign officials and authorities, as well as in their relations with other companies.

Objectives of the internal regulations for the
Prevention of Corruption



  • Establish principles of action for employees in their dealings with Public Authorities and private companies.
  • Protect free competition and participation in the acquisition and/or delivery of goods and/or services.
  • Implement a Zero Tolerance with anti-corruption policy both in relations with public authorities and with private business.


The Code of Ethics and the Anti-Corruption Policy is are applicable to all employees of companies in Spain, Italy, Portugal, Chile, the United Kingdom, Germany, Slovakia, the Czech Republic and Andorra, in which the Group has a majority or exercises control, without prejudice to the adjustments that may be made to the regulations in order to respect the specific legislation of each of the countries in which these companies are located. It is binding for the members of Saba's Management Bodies, its directors and all its employees. The behaviour of all employees must fully respect the legal provisions in force in any part of the world in which Saba is active.

Due diligence

Since 2011, Saba has approved and implemented different regulations and procedures with the aim of establishing transparency, efficiency, responsibility and sustainability as the basic pillars that guide the company's performance. Similarly, it has implemented a series of crime prevention measures.


  • Due diligence, approved in its initial version by Saba Infraestructuras' Board of Directors in March 2017 and subsequently updated in 2019 and 2021.

    - Updating of Saba's Criminal Risk Matrix and existing controls and the Crime Prevention Handbook. Extending this to all the countries where the company operates.
  • Crime Prevention Modelcontrol structure.
    - Board of Directors.
    - Ethics Committee.
    - Criminal Risk Prevention Committee.
    - Ethical Channel. Through which indications or suspicions of behaviours contrary to the law and/or an infraction of the Code of Ethics can be reported.
  • Specific training for employees, in person and also online through the Saba Campus. During 2022, 168 hours of training were given, 87 hours through the e-learning platform and 81 hours as face-to-face training in Spain.
  • Membership of ASCOM (Spanish Compliance Association) since 2018.
  • Performance in Saba group countries. In reference to the rest of the countries, Portugal, Chile and Italy (the latter, through “Modello di organizzazione”) have a prevention model adapted based on the possible crimes attributable in each of the jurisdictions and existing controls in each country, as well as their own reporting channels. Additionally, there are local ethics committees that also meet periodically and report to the Ethics Committee in Spain and have their own complaint channels. Training sessions are also held In Portugal, Italy and Chile to raise awareness in this area.
Social and institutional action
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