3 Setembro 2019Espanha

Central Criminal Court no. 6 of the Spanish National High Court has summoned Indra to appear as party under investigation in Preliminary Investigation Proceedings 85/2014 -Preliminary Investigation Proceedings - Summary Proceedings 91/2016 (‘Púnica’ Case).

Given these circumstances, Indra makes the following statements:

  1. As far as this company is aware of, all investigated facts are prior to year 2015, when the president and management of the company were replaced. Moreover, none of the managers and employees appearing as investigated parties in the proceedings is currently providing services to Indra.
  2. The status as investigated party requested by the Public Prosecution and ordered by the Investigation Judge does not entail in this proceeding stage the charge regarding any offence, or has any effect on Indra's legal capacity to conclude agreements.
  3. The company has a crime prevention system in place since 2011, when the 2010 Criminal Code reform entered into force by means of Organic Law 5/2010, 22 June, introducing legal person criminal responsibility into the Spanish legal system.
  4. Since 2015, after the replacement of its president and management team, Indra has updated and reinforced its system to prevent the commission of offences by its directors and employees, and, to that end, among many other measures, it has reviewed and strengthen its Code of Conduct and Compliance and its Criminal Prevention Model, in respect of which there is a permanent improvement and training process; Compliance Unit and Internal Audit function have been granted a greater independency and resources; punitive and disciplinary measures have been adopted when any irregular action has been detected; and the Audit and Compliance Committee and Board of Directors carry out a continuous monitoring on this regard.
  5. Hence, the company maintains thorough controls of its managers and employees actions' legality and of the accountability of potential irregular conducts.
  6. In view of the analysis carried out internally, Indra claims that, in the event that any irregular conduct had eventually taken place during the investigated period, it would be attributable to managers or employees in breach the organisation, management and surveillance models adopted in 2011, which have been reinforced and improved since 2015.
  7. Indra has closely collaborated with the criminal investigation, providing all the documents requested, and submitting to the Court, on its own initiative, each and all the documents and information obtained in the detailed internal investigations performed by the company's Compliance Unit. Indra will continue to actively collaborate with the Spanish Justice to shed light on the circumstances.
  8. Indra has the utmost confidence in the Spanish Justice and deems that the fact that the presumed conducts under investigation are attributed to former managers and employees who are no longer providing services to the company, together with the major shift in the management and control model since the replacement of the management team, and Indra's collaboration with the Spanish Justice, should determine that no harmful consequences derived from those conducts affect Indra and its more than 47,000 employees.
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