Ethical compliance and human rights


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2015 milestones
  • Board of Directors' approval of the Risk Control and Management Policy. 
  • Board of Directors' approval of the Anti-Fraud, Corruption and Bribery Policy. 
  • Continuous training in and dissemination of the Crime Prevention Model and Code of Ethics in all companies of the Group. 
  • Development of internal rules and procedures in the control and management of risks and taxation. 
  • Approval of the Enagás Group's Crime Prevention Model and adaptation to the Federal District Criminal Code (Mexico) and to US anti-bribery regulations.
Lines of progress 2016 
  • Review and implementation of the Ethics And Compliance Model in companies of the Group and investees.  
  • Continuous training in and dissemination of the Criminal Liability Programme and Code of Ethics. 
  • Implementation of the Crime Prevention Model in Mexico and the US. 
  • Adherence to the Code of Good Tax Practices. 
  • Training in Human Rights at global level (guiding principles applied to the company).

4 communications received via the Ethics Channel.

91% of employees took the Code of Ethics course.

96% of employees received training in Human Rights (15,442.74 hours).

94% of employees received training in anti-corruption policies and procedures.

(1) Training in at least one of the following types of courses: Equality and Anti-corruption, Human Rights (general) and Prevent and the Environment.

Ethics and Compliance model 

The Enagás Ethics and Compliance model is the primary tool for ensuring that our activities are carried out ethically and with integrity. It comprises the following elements:

See the ‘Code of Ethics and Policies’ section on the corporate website.


Ethics and Compliance Model: Governing Bodies, Codes of Conduct and Policies and Procedures.

Awareness and training 

The Code of Ethics course encompasses such key issues as the fight against fraud, corruption and bribery, fiscal responsibility and respect for human rights, among others. 

It is a tool for preventing irregularities, including those that could constitute crimes, in those spheres. The course is arranged as follows: 

  • Practical cases for each guideline on conduct in the Code of Ethics. 
  • Procedures for reporting and querying cases of non-compliance. 
  • Responsibility for the management of reports (Ethical Compliance Committee).

91% of employees took the Code of Ethics course, revealing the level of familiarity with the principles and guidelines on conduct expected by Enagás. 

Next year, training in and dissemination of the Code of Ethics will continue, with particular emphasis on conduct constituting a crime (Criminal Liability Programme). 

Ethics Channel 

Enagás' Ethics Channel is a platform for querying and reporting irregularities or breaches of the Code of Ethics. The channel adheres to the following principles: 

  • Only reports that involve irregularities for which the company may be liable are processed. 
  • Access to the Ethics Channel and the processing of reports is procedurally regulated by and restricted to members of the Ethical Compliance Committee. 
  • Information concerning dismissed reports is deleted. 
  • Confidentiality prevails over anonymity. 
  • Reports received anonymously and/or via the channel are only processed if well-founded. 
  • The procedure for managing reports and consultations about irregularities or breaches of the Code of Ethics complies with the Personal Data Protection Act as regards the preserving, cancelling and blocking of data. 

Buzón electrónico.

Correo postal.


Electronic mailbox:

Post addressed to any member of the Ethical Compliance Committee.

Form available on the corporate Intranet.

In 2015, four communications were received via the Ethics Channel. Three were consultations unrelated to breaches of the Code of Ethics. The fourth was a report concerning the 'Generate a culture of innovation' conduct guideline in the Code of Ethics, specifically with regard to collaboration and team work, whereupon an investigation was launched.

Investee companies
Adaptation of the Enagás Group's Crime Prevention Model to the Federal District Criminal Code (Mexico) 

In 2015, Enagás approved the adaptation of the Enagás Group's Crime Prevention Model to the Federal District Criminal Code (Mexico). This Code introduces the criminal liability of legal persons when crimes are committed by workers for the benefit of the legal person, without "proper control". Within this context, an Enagás Group Crime Prevention Model has been developed in Mexico. The aim of the model is to define rules of action and conduct in criminal matters that regulate the Enagás Group's activity in Mexico, as well as defining control systems to prevent crime for which the legal person may be held liable, typified in Mexican criminal law.

Adaptation of the Enagás Group's Crime Prevention Model to US anti-bribery regulations

The Enagás Group's Crime Prevention Model encompasses the provisions of the U.S. Foreign Corrupt Practices Act (FCPA) as regards applicable criminal conduct, liability regime and penalty system.

Action Plan resulting from the audit of TGP partners 

Enagás coordinated the audit of partners of the company Transportadora de Gas del Perú in 2013 and 2014, in which the company has a 24.34% stake. The audit, conducted by a team of auditors from Enagás, CPPIB and Sonatrach, was tasked with verifying that the operations were carried out in accordance with the partnership agreement and the existence and fulfilment of current internal control procedures. As a result, an action plan was agreed upon that consisted of approving the Code of Ethics and the process for declaring conflicts of interest, and presenting proposals for an action procedure in the event of fraud.

Respect for Human Rights 

In its Code of Ethics and the corporate policies which it comprises, Enagás sets out its commitment to ensuring compliance with human rights, in line with, among others: 

  • The International Bill of Human Rights. 
  • Fundamental Principles and Rights of the International Labour Organisation (ILO). 
  • OECD Guidelines for Multinational Enterprises.

See the Enagás Code of Ethics on the corporate website.

Right to decent workAs well as guaranteeing decent work for our employees, we ensure that our suppliers provide all workers at their facilities with legal employment status: we request the necessary documentation and conduct audits.

Right to rest and leisure

Enagás improves and extends the periods and conditions of rest and leisure established in current legislation (flexibility in start times and lunch break, shorter workday during the summer and every Friday throughout the year, division of annual leave into a maximum of 3 periods, etc.).

Abolition of child labour

The Enagás Collective Bargaining Agreement prohibits the Company from employing minors of under 16 years of age (Article 28).

Right to family life

Enagás improves and extends paid leave beyond the provisions of current labour regulations (birth of a child, marriage or death of a close relative, special circumstances, etc.). 

Maternity leave: 17. Paternity leave: 30.Return to work rate of employees who took leave prior to 31/12/14. Women: 94%. Men: 100%.Retention rate of employees in the company 12 months after returning. Women: 76%. Men: 100%.

Right to freedom of opinion, expression and information

Enagás has various clear and transparent internal communication channels that allow workers to communicate with senior management.

Right to a safe working environment

Enagás' occupational risk prevention management system, certified under OHSAS 18001, provides mechanisms for identifying and preventing incidents.

Freedom of association

Enagás employees can freely exercise their right to belong to trade unions in order to promote and defend their economic and social interests without this being the basis for discrimination, and any agreement or decision by the company contrary to this principle is deemed null and void (Article 64).

Right to collective bargaining

Enagás has a collective bargaining agreement and also enters into collective negotiations and carries out regular consultations with authorised representatives of the employees regarding working conditions, remuneration, dispute resolution, internal relations and issues of mutual concern.

57% of employees are covered by the collective bargaining agreement (100% of operational staff, 94% of administrative staff and 35% of technicians). 

Right to workplace non-discrimination and diversity

The company has a Diversity Plan and a Prevention and Action Protocol at the disposal of its employees for any situation of workplace harassment. This protocol provides a confidential channel for reporting workplace harassment (

Equal pay 

The Enagás remuneration model factors in considerations of equality and non-discrimination, establishing differences due solely to the worker's position in the organisation and professional experience. Furthermore, the Enagás Collective Bargaining Agreement sets out different salary levels based exclusively upon objective work criteria. 

Ratio of basic salary / average wage of women to men by employee category

Ratio of basic salary / average wage of women to men by employee category: Management, Technicians, Administrative Staff and Operational Staff.

Right to fair and favourable remuneration 

Part-time employees receive salaries and benefits proportional to those of full-time employees, as well as overtime pay. What is more, the minimum salary for an Enagás employee is more than double the minimum inter-professional salary in Spain. 

Right to life, liberty and security of person

The company exercises due diligence when rendering its services in order to avoid defects that could harm the life, health or security of consumers or others that could be affected by the defective product, and complies with nationals laws and relevant international guidelines. 

Right of minorities

Enagás ensures that owners and users of property affected by the company's acquisitions and activities receive appropriate compensation.

In 2016, an online training programme will be launched for all Enagás employees so they can learn the company's methods for ensuring compliance with human rights.

Human rights are addressed using a continuous improvement approach aligned with our Sustainable Management Model.


Human Rights Management Model. 1. Commitment. 2. Assessment. 3. Action Plan. 4. Grievance Mechanisms. 5. Compensation.