Responsible supply chain management
Impacts identified in terms of sustainability

One of the initiatives that we have undertaken within the framework of responsible supply chain management is the identification of the impacts of our supplies (mainly services) on sustainability and, therefore, the requirements associated with those impacts.

20 types of impacts on sustainability were identified as a result of this initiative: 7 in the area of ethics and working conditions, 4 in the area of occupational safety and health, and 9 related to the environment.

The main risks are handled through the current management systems and the audits carried out regularly, followed by recommendations and improvements that are studied internally and implemented as part of the continuous improvement of our processes.

The identification and prioritising of the risks and impacts on the supply chain has enabled the company to establish suitable controls to minimize them. In this sense, for each risk identified, the company works out stages for classifying, monitoring, developing and training suppliers.

When a high impact is identified, the company must establish an action plan with the supplier, with detailed monitoring of implementation and reserving the right to take action against the supplier when necessary.

Risks and impacts identified in the supply chain and mitigation measures

  Risks and impacts identified Mitigation measures

Risks and impacts regarding ethics and working conditions
  • Reputation
  • Bribery and corruption
  • Appropriation and misuse of information
  • Discrimination/equality
  • Violation of the fundamental rights of workers
  • Lack of ethics in remuneration
  • Impact on the well-being of the community
  • Legal/regulatory non-compliance
  • Certified quality system (ISO 9001)
  • Implementation of the Integrity Due Diligence Model for suppliers
  • Due diligence guidelines on integrity due diligence with counterparties. Criteria for determining inherent risk
  • Contracting of an information search service regarding integrity
  • Assessment of the likelihood of compliance with criminal prevention, privacy and cyber security regulations by a supplier
  • Acceptance of the Supplier Code of Conduct
  • Conducting business audits and establishing action plans

Risks and impacts regarding Occupational Health and Safety
  • Accidents in the workplace
  • Work-related illnesses
  • Inadequate training or experience / information
  • Legal / regulatory non-compliance
  • Occupational health and safety management system certified by a third party (OHSAS 18001 or similar). This requirement is compulsory for all supplies with an impact on occupational health and safety

Risks and impacts regarding the environment
  • Impact on biodiversity
  • Impacts on soil and water
  • Climate change
  • Air quality
  • Generation of non-hazardous wast
  • Generation of hazardous waste
  • Energy consumption
  • Water consumption
  • Legal/regulatory non-compliance
  • Environmental management system certified by a third party (ISO 14001 or similar). This requirement is compulsory for all supplies with an environmental impact

Risks and impacts due to non-compliance with legislation
  • Non-compliance with the requirements of EU Directive 2014/25 on procurement by entities operating in the water, energy, transport and postal services sectors.
  • General conditions of contract for equipment and materials, the supply of services and the provision of construction work
  • Proof of a civil liability insurance policy, being up to date on payments regarding Social Security, Tax Authority, Civil Registry, and accident insurance
  • Permanent monitoring of compliance with current legislation

Risks and impacts due to non-fulfilment of deadlines or incidents in the performance of the work
  • Inability of suppliers to complete the execution of the works
  • Certified quality system (ISO 9001)
  • Control and monitoring of suppliers in financial difficulties
  • Monitoring of the supplier during the term of the contract: verification of qualification requirements (business, environmental and occupational health and safety)
  • Establishment of KPIs and service level agreements in contracts, definition of specific clauses per contract, in addition to the General Terms and Conditions of Contract
  • Minimum requirements (depending on the supply)
  • Analysis of references and of previous track record relating to prior works
  • Comprehensive evaluation of the supplier prior to being included in the tendering process
  • Awareness and supplier development campaigns
  • Diversified contracts with various suppliers offering flexibility in the event that the supplies/services need to be reallocated

Risks and impacts associated with the supplier’s country of origin
  • Risks and impacts associated with the supplier’s country of origin
  • Incorporation of supplier location in determining inherent risk within the supplier integrity due diligence model