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Ethics and Compliance


COMSA Corporación considers it essential to develop its activity based on ethical and regulatory compliance criteria. The group first approved its Code of Ethics in 2011 and since then, it has been revised on several occasions by the Board of Directors. The purpose of this document is to establish the values, commitments and principles of action that should guide the daily work of all members of the Group’s management bodies, executives and employees.

You can consult COMSA Corporación’s Code of Ethics here.

Furthermore, in accordance with Law 2/2023 of 20 February (“Whistleblower Protection Act”), the Whistleblowing Management System Policy (Ethics Channel) is made available to you, which defines the general principles that COMSA Corporación defends, promotes and adopts in the process of receiving, processing, recording, investigating and responding to communications received through the Ethical Channel, which you can access at the bottom of this page.

COMSA Corporación ensures knowledge, understanding and compliance with the provisions of the Code of Ethics and the Protocols, Policies and other internal regulations that develop it, through its Ethics Commission, which has been constituted and its members appointed by the Board of Directors and has autonomous powers of initiative and control in the development of its functions. The Ethics Commission is also the body responsible for ensuring the proper functioning of COMSA Corporación’s ethics channel.

Consult here some of the main policies, protocols and other documents that make up the group’s Compliance model.


Jorge Miarnau, Chairman of the Board of Directors
Chairman of the Commission

Guillermo Lorenzo, Infrastructure and Enginnering General Director
Board Member

Manuel Fonseca, Corporate Economic Services General Director
Board Member

Santiago Sanjosé, Director of Administration and Corporate Control
Board Member

Ignacio Ponz, Human Resources Director
Board Member

Carles Mases, Legal Department director
Ethics Commission Secretary

The Ethical Channel

The ethical channel is a communication tool that allows both the internal personnel of COMSA Corporación and the group’s companies and third parties to inform the Ethics Commission of any situation of non-compliance with the law, the Code of Ethics or the internal rules that develop it.