Indra Sistemas SA

Lobbying Governance

AI Extracted Evidence Snippet Source

### 7. Governance and Oversight Model

In accordance with current law, the Board of Directors has the non-delegable power to approve the Sustainability Policy, relying upon the Sustainability Committee for its review, updating and oversight.

The Sustainability Policy serves as a framework for action for other set of policies related to the company's social and environmental management, which are therefore subject to the same monitoring process described in this document. These policies include the Human Rights Policy, the Modern Slavery Statement, the Sustainability Policy for Suppliers, the Environmental Policy, and the Energy Policy.

For Indra, the development of a sustainable business model and the principles of action that comprise it implies that they are part of the processes and objectives of the different business areas and inform the decision-making of the company's governing and management bodies.

The Strategy Department is responsible of implementing the company's sustainability strategy, executing the Sustainability Master Plan, and establishing oversight, control, and reporting mechanisms in these areas, reporting to the Sustainability Committee.

The Sustainability Master Plan is updated periodically and reflects the specific sustainability objectives and initiatives that the company puts forth to meet the commitments set out in this Policy. The design of the Sustainability Master Plan is based on the company's Materiality Analysis, and considers the company's risk map, the evolving stakeholder expectations, the company's strategy, and applicable law.

Indra monitors compliance with the Sustainability Master Plan annually, with the results reported through the Sustainability Report (Non-Financial Report). This report is drafted by the Board of Directors, is part of the Management Report, and is submitted for approval at the Annual Shareholders' Meeting as a separate item on the agenda.

Indra's Global Risk Management Department performs its risk management and control function under the direct supervision of the Audit and Compliance Committee.

Regarding the identification and management of non-financial risks, the Audit and Compliance Committee is supported by the Sustainability Committee.

Both committees report regularly to the Board of Directors, which is ultimately responsible for determining risk control and management policy and overseeing internal information and control systems.

https://www.indracompany.com/sites/default/files/indra_sustainability_policy_270224.pdf

The Sustainability Committee is responsible for monitoring and supervising the objectives and principles of this policy and for reporting its conclusions to the Board of Directors. [...] The Sustainability Committee, tasked with the strategic role of tracking the Master Plan's progress, kept the Board of Directors regularly informed during 2023 of the company's initiatives and any progress made towards achieving the objectives set out. [...] In accordance with the legislation in force, the Board of Directors has the non-delegable power to approve the Sustainability Policy, and it is assisted in its review, updating and monitoring of this Policy by the Sustainability Committee. [...] Compliance with the Sustainability Master Plan is reviewed on an annual basis, and the results of this review are reported in the Sustainability Report (Non-financial Information Statement) that is prepared by the Board of Directors. This forms part of the Management Report and is submitted for approval by the General Shareholders' Meeting in a separate item on the agenda. [...] The Board focuses on supervising and controlling the executive bodies and the Management Committee, to which it delegates the company's day-to-day management. [...] The structure, composition, duties and rules of operation of the Board and its Committees are also outlined in sections C.1 and C.2 of the Annual Corporate Governance Report.

https://www.indracompany.com/sites/default/files/sustainability_report_en_2023_290524.pdf

At Indra, the Board of Directors is the highest and most important body responsible for Climate Change governance and supervision of the company's sustainability management, including the climate strategy. To this end, in December 2019 the Board approved the creation of a Sustainability Committee which reports to the Board of Directors. The Sustainability Committee aims to tackle the climate challenges that arise over the coming years and facilitates the inclusion of climate related criteria as part of the decision-making process of the company. It centralizes and oversees the performance of key indicators, as well as the management of climate-related risks and opportunities. Its functions include tracking the ESG Plan progress, designing the ambitious emissions reduction roadmap for the company, and supervising the objectives and principles of the Sustainability Policy. The Sustainability Committee holds five scheduled sessions every year in order to monitor Climate Change performance and climate-related issues, therefore in all meetings Climate Change issues are part of the agenda. The Board of Directors and the Sustainability Committee are Indra's largest decision-making and supervisory bodies on Climate Change. The management of climate issues is under the direction of the Chief Strategy Officer who belongs to the Management Committee and regularly reports to the Sustainability Committee and the Board on the policies, the main risks and opportunities and the company's performance and objectives in this area. All aspects related to Climate Change are fully integrated into the company's strategy through the initiatives defined within the framework of the ESG Plan 2024-2026, which has a specific pillar of Planet and climate action. The Group's new Strategic Plan 2024-2026 has integrated these aspects into the cross-cutting Sustainability pillar. The Corporate Sustainability Unit contributes to set the emissions and renewable energy targets in collaboration with other corporate units and defines the actions needed to meet the targets set and coordinates the monitoring procedures. The Sustainability Unit oversees the implementation of the initiatives included in the ESG Plan and monitors the progress of the KPIs set, planning corrective actions if needed. Close cooperation is established with the corporate units that have more impact in the achievement of the emission reduction targets of the company. [...] Climate risk management in Indra is integrated into the multi-disciplinary company-wide risk management process and global risk map. The results of this analysis are presented to the Sustainability Committee and decisions are agreed to mitigate them or to take advantage of the opportunities identified. This analysis is reviewed annually to adapt the risks and opportunities to the company's circumstances, such as changes in the market, stakeholder requirements or possible changes in the organization (e.g., new locations or business units).

https://www.indracompany.com/sites/default/files/indra_tcfd_report_en_2024.05.14.pdf

At Indra, the Board of Directors is the highest and most important body responsible for Climate Change governance and supervision of the company's sustainability management, including the climate strategy. To this end, in December 2019 the Board approved the creation of a Sustainability Committee which reports to the Board of Directors. The Sustainability Committee aims to tackle the climate challenges that arise over the coming years and facilitates the inclusion of climate related criteria as part of the decision-making process of the company. It centralizes and oversees the performance of key indicators, as well as the management of climate-related risks and opportunities. Its functions include tracking the ESG Plan progress, designing the ambitious emissions reduction roadmap for the company, and supervising the objectives and principles of the Sustainability Policy. The Sustainability Committee holds five scheduled sessions every year in order to monitor Climate Change performance and climate-related issues, therefore in all meetings Climate Change issues are part of the agenda. The Board of Directors and the Sustainability Committee are Indra's largest decision-making and supervisory bodies on Climate Change. The management of climate issues is under the direction of the Chief Strategy Officer who belongs to the Management Committee and regularly reports to the Sustainability Committee and the Board on the policies, the main risks and opportunities and the company's performance and objectives in this area. All aspects related to Climate Change are fully integrated into the company's strategy through the initiatives defined within the framework of the ESG Plan 2024-2026, which has a specific pillar of Planet and climate action. The Group's new Strategic Plan 2024-2026 has integrated these aspects into the cross-cutting Sustainability pillar. The Corporate Sustainability Unit contributes to set the emissions and renewable energy targets in collaboration with other corporate units and defines the actions needed to meet the targets set and coordinates the monitoring procedures. The Sustainability Unit oversees the implementation of the initiatives included in the ESG Plan and monitors the progress of the KPIs set, planning corrective actions if needed. Close cooperation is established with the corporate units that have more impact in the achievement of the emission reduction targets of the company. [...] Climate risk management in Indra is integrated into the multi-disciplinary company-wide risk management process and global risk map. The results of this analysis are presented to the Sustainability Committee and decisions are agreed to mitigate them or to take advantage of the opportunities identified. This analysis is reviewed annually to adapt the risks and opportunities to the company's circumstances, such as changes in the market, stakeholder requirements or possible changes in the organization (e.g., new locations or business units). [...] Due to the increasing importance of ESG issues for customers, investors and society, Indra needs to address reputational and market risks related to Climate Change, which also represents an opportunity to be more prepared, resilient, transparent and reinforce investor confidence. Thus, the company is proactively working to improve transparency in reporting on climate-related targets and initiatives. The company has included Climate Change action plans as a key pillar of the company's ESG Plan 2024-2026. One of the strategic pillars is the Planet and climate action Pillar, which relates to the environment and Climate Change and aims to "combat Climate Change and protect the environment" in line with the company's Sustainability Policy. To manage these actions plans, the company has established the following actions: ▪ Leadership and accountability; in 2019 the company established the Sustainability Committee at the heart of the Board of Directors as a strong driver in the sustainability performance of the company. ▪ Informing investors; one of the fundamental roles that Indra must play with respect to climate is the provision of information, helping to ensure material information gets to the investor community in a timely manner. Indra's sustainability performance is regularly assessed by the market's leading ESG analysts, such as S&P, FTSE4Good, MSCI, CDP or Sustainalytics, and the company carefully studies the areas for improvement highlighted by these assessments. In fact, Indra is already well positioned thanks to its ESG efforts and has been recognised by several ESG analysts and indices.

https://www.indracompany.com/sites/default/files/indra_tcfd_report_en_2024.05.14.pdf

The Sustainability Committee is responsible for monitoring and supervising the objectives and principles of this policy and for reporting its conclusions to the Board of Directors. [...] The Sustainability Committee, tasked with the strategic role of tracking the Master Plan's progress, kept the Board of Directors regularly informed during 2023 of the company's initiatives and any progress made towards achieving the objectives set out. [...] In accordance with the legislation in force, the Board of Directors has the non-delegable power to approve the Sustainability Policy, and it is assisted in its review, updating and monitoring of this Policy by the Sustainability Committee. [...] Compliance with the Sustainability Master Plan is reviewed on an annual basis, and the results of this review are reported in the Sustainability Report (Non-financial Information Statement) that is prepared by the Board of Directors. This forms part of the Management Report and is submitted for approval by the General Shareholders' Meeting in a separate item on the agenda. [...] The Sustainability Master Plan sets out the Company's specific sustainability targets and the initiatives it has developed in order to meet the commitments set out in the Sustainability Policy.

https://www.indracompany.com/sites/default/files/sustainability_report_en_2023_05042024.pdf

The Sustainability Committee is responsible for monitoring and supervising the objectives and principles of this policy and for reporting its conclusions to the Board of Directors. [...] The Sustainability Committee, tasked with the strategic role of tracking the Master Plan's progress, kept the Board of Directors regularly informed during 2022 of the company's initiatives and any progress made towards achieving the objectives set out. [...] The Board and the Sustainability Committee are the most important decision-making and supervisory units at Indra in terms of Climate Change. The sustainability management team reports regularly to the Sustainability Committee and to the Board on the policies, main risks and opportunities and the performance of the company's objectives in this respect. [...] Indra is not aware of having collaborated with any type of organisation whose objective could be understood to be political influence and has therefore made no contribution to lobbying or representation of interests, organisations or similar; to political campaigns, organisations or candidates; or any other expense associated with political influence. When Indra enters into agreements with different kinds of associations or engages in direct contact with governments or their representatives abroad, it is careful to ensure that their lobbying activities conform to the same principles of cooperation and transparency that are set out in Indra's own Code of Ethics and Legal Compliance. [...] The Code of Ethics and Legal Compliance sets out the following obligations for Indra's employees in this regard: - The prohibition of donations to political parties: the Code of Ethics and Legal Compliance prohibits any direct or indirect financing of political parties, their representatives or candidates. - The prohibition of facilitating payments and restrictions on corporate hospitality: under the appendix on corporate hospitality, the Code of Ethics and Legal Compliance prohibits so called facilitating payments and limits the conditions and amounts in which Indra employees are allowed to offer business gifts to public officials. - As the Code of Ethics and Legal Compliance sets out, Indra's internal procedures and processes include certain additional control measures relating to the engagement of politically exposed persons, given the greater risk of bribery and corruption to which these kinds of relations are subject. Indra is committed to complying with the legislation in force regarding transparency of lobbying activities.

https://www.indracompany.com/sites/default/files/indra_sustainability_report_en_2022_250423.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Indra is part of Forética's 'Climate Change Cluster', which comprises more than 50 large companies, and which is trying to drive the leadership of the private sector in climate matters, as well as value good practices, facilitate the dialogue and exchange of ideas between companies and be a reference interlocutor with public authorities.

Indra is also part of the Spanish Platform for Climate Action, which aims to promote compliance with the Paris Agreement. The companies which are members of the initiative commit to setting absolute emission reduction targets, to including data on their carbon footprint in Spain's Ministry of Agriculture, Fisheries, Food and the Environment (MAPAMA in its Spanish acronym) Carbon Footprint, Compensation and CO2 Absorption register, and to participating in Global Climate Action.

In addition, Indra cooperates with Foundations whose purpose is the development and promotion of corporate responsibility and in this context; they also promote initiatives to boost policies about climate change. These foundations are:
Argentine Business Council for Sustainable Development (CEADS), Department of Environment and Natural Resources (DERN) and EnergyLab (Spain).

Indra is a member of the Environmental Committee of the TEDAE (Spanish Association of Defence, Aeronautic and Transportation Companies) and is also a member of the Environmental Committee of the AEC (Spanish Quality Association).

Finally, Indra is also committed to the 'Business Ambition for 1.5°C' an urgent call to action from a global coalition of UN agencies, business and industry leaders, in partnership with the Race to Zero.

CDP Questionnaire Response 2022

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Indra is committed to the fight against climate change in line with the objectives of the Paris Agreement.

CDP Questionnaire Response 2023

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023