December 21, 2018

M nica Miloslavich
Chief Financial Officer
Grana & Montero S.A.A.
Avenida Paseo de la Rep blica 4667
Surquillo
Lima 34, Per

       Re: Grana & Montero S.A.A.
           Form 20-F for the Fiscal Year Ended December 31, 2017
           Filed July 2, 2018
           File No. 001-35991

Dear Ms. Miloslavich:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for the Fiscal Year Ended December 31, 2017

Financial Information, page 1

1.    Please update the current status of your request for relief from the
financial statement
      filing requirements for GPS. In this regard, we note your disclosure in
your Form 6-K
      dated October 29, 2018. Please ensure your disclosures address the
implications of not
      complying with Rule 3-09 of Regulation S-X.
Item 15. Controls and Procedures
D. Changes in Internal Control Over Financial Reporting, page 196

2.    You disclose that "We identified material weaknesses in our internal
control as described
      in Item 15.B. above. There were no other changes in our internal control
over financial
      reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange
Act) that
      occurred during the year ended December 31, 2017 that have materially
affected, or are
 M nica Miloslavich
FirstName LastNameM nica Miloslavich
Grana & Montero S.A.A.
Comapany21, 2018
December NameGrana & Montero S.A.A.
December 21, 2018 Page 2
Page 2
FirstName LastName
         reasonably likely to materially affect, our internal control over
financial reporting." It is
         not clear that the identification of material weaknesses is an actual
change in your internal
         control over financial reporting. Please disclose any change in your
internal control over
         financial reporting identified in connection with the evaluation
required by paragraph (d)
         of 17 CFR 240.13a-15 or 240.15d-15 that occurred during the period
covered by the
         annual report that has materially affected, or is reasonably likely to
materially affect,
         your internal control over financial reporting. For example, we note
that certain material
         weaknesses you identified as of December 31, 2016 were no longer
identified as material
         weaknesses as of December 31, 2017. Please expand your disclosures to
explain how
         your internal controls over financial reporting where changed such
that you were able to
         remediate prior material weaknesses.
Consolidated Financial Statements
Note 16   Investments in Associates and Joint Ventures, page F-65

3.       Please explain how you determined the impairment charge of S/593
million and the
         resulting S/218 million GSP investment balance as of December 31, 2016
and 2017. In
         this regard, the information presented in your footnotes should be
sufficiently clear and
         appropriately refer to related Pervian Sol amounts. Please also
provide us a
         comprehensive explanation of how you determined your GSP investment
was recoverable
         as of December 31, 2017. In this regard, we note your reference to
political uncertainty
         and the Peruvian government's failure to hire an audit entity to
calculate the Net Book
         Value and lack of the subsequent call for three public auctions.
Please tell us the status of
         any discussions and/or negotiations with the Peruvian government.
Please also tell us the
         status of any public auctions.
4.       You disclose on page 110 that you assumed your proportional obligation
to repay the
         project's bridge loan in an amount of US$129 million (S/.433 million)
and the project's
         performance guarantee in amount of US$52.5 million (S/.176 million)
and recorded them
         in your consolidated financial statements as of December 31, 2017. You
further disclose
         that you recorded an account receivable for the same amounts, since
you have the right to
         collect these amounts from GSP. Please address the following comments:
           Reconcile these amounts to the receivable amounts reflected in Note
13. Transactions
             with Related Parties and Joint Operations. Based on the
disclosures you recorded in
             Note 13, it appears that the receivable from GPS was discounted;
and
           In light of GPS's bankruptcy and disagreements with the other GPS
shareholders,
             please tell us how you concluded that an asset should be
recognized. Specifically
             address how you determined it was probable that future economic
benefits will flow to
             the Company and that its value can be measured reliably. Please
refer to CF 4.44.
Note 19   Other Financial Liabilities, page F-83

5.       Please confirm, and revise to clarify, if true, that your Credit
Suisse Syndicated
         Loan, your GSP Bridge Loan and any other debt for which you were in
default were
 M nica Miloslavich
FirstName LastNameM nica Miloslavich
Grana & Montero S.A.A.
Comapany21, 2018
December NameGrana & Montero S.A.A.
December 21, 2018 Page 3
Page 3
FirstName LastName
         classified as current liabilities at December 31, 2017. Refer to IAS
1.74. Please tell us
         whether you have obtained waivers for the debt instruments where you
were in default at,
         and subsequent to, December 31, 2017. To the extent you have not
received waivers,
         please tell us the current status of negotiations with your lenders
and whether any of them
         have demanded payment. Please ensure you adequately discuss in
Management's
         Discussion and Analysis the impact that your default on these loans
has had and may
         continue to have on your liquidity.
Note 37   Discontinued Operation, page F-105

6.       Please tell us how you determined that GMD S.A. met the criteria of
being a separate
         major line of business or geographical area of operations in order to
be classified as a
         discontinued operation as defined in IFRS 5.33(a)(ii).


7.       Please tell us how the discontinued operations line item on your
income statement
         reconciles to your footnote. Additionally, please revise future
filings to reconcile the profit
         or loss from discontinued operations on your income statement to your
footnote as
         required by IFRS 5.33(b).
8.       On page 126, you indicate that your S/ 274.4 million gain from sale of
investments
         includes the profits from your sale of GMD and COGA. Please quantify
the gains related
         to the sale of entities and explain why these gains are not reflected
within discontinued
         operations. Please refer to IFRS 5.33(a). In addition, please clarify
where the proceeds
         from your sale of investments are reflected in your statement of cash
flows. If they are
         included in sale of available-for-sale investments, please consider
presenting these cash
         flows separately to avoid confusion with your sale of
available-for-sale financial assets.
9.       Please reconcile the "Revenues from services provided" and "Revenue
from real estate
         and sale of goods" for the years ended December 31, 2016 and 2015 as
reflected in your
         Consolidated Statement of Income on page F-4 to the amounts presented
in your Form 20-
         F for the year ended December 31, 2016. We note the difference in
these revenues are in
         excess of the revenues related to your discontinued operations. Please
address this
         comment as it relates to the respective cost of sales for these
revenue line items.
Note 38. Events After The Date Of The Statement of Financial Position, page
F-106

10.      Please tell us why your investment in Stracon GyM S.A. did not meet
the criterion to be
         classified as assets held for sale and reflected as discontinued
operations as of December
         31, 2017. In this regard, we note that prior to December 31, 2017 your
board approved
         the sale of non-strategic assets. Please refer to IFRS 5.6 through 8A
and IFRS 5.30.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
 M nica Miloslavich
Grana & Montero S.A.A.
December 21, 2018
Page 4

       You may contact Dale Welcome at 202-551-3865 or Jeanne Baker at
202-551-3691 with
any questions.



                                                       Sincerely,
FirstName LastNameM nica Miloslavich
                                                       Division of Corporation
Finance
Comapany NameGrana & Montero S.A.A.
                                                       Office of Manufacturing
and
December 21, 2018 Page 4                               Construction
FirstName LastName