March 25, 2019

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 reviewed your March 1, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
December 21, 2018 letter.

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

Consolidated Financial Statements
Note 16   Investments in Associates and Joint Ventures, page F-65

1.    You indicate in your response to prior comment four that the Company's
ability to collect
      the receivable from GSP is subject to the Peruvian bankruptcy proceeding
and the
      Peruvian government meeting its obligations under the concession
contract. As such,
      please tell us what consideration you gave to viewing this receivable as
a contingent asset
      as defined by IAS 37.10. If this receivable is within the scope of IAS
37, please tell us
      how you considered the guidance in IAS 37.31 through .35. In addition to
CF 4.44, please
      identify any additional authoritative literature you relied on in
determining the
      appropriateness of recognizing this receivable.
 M nica Miloslavich
Grana & Montero S.A.A.
March 25, 2019
Page 2
Note 37   Discontinued Operation, page F-105

2.       We note your response to comment eight where you commit to reclassify
the S/274.4
         million gain on the sale of GMD to "Profit or loss from discontinued
operations" in
         accordance with IFRS 5.33(a). Please tell us the type of change to
your financial
         statement this represents and provide us with your analysis under IAS
8, specifically
         addressing, without limitation, paragraphs 5, 41, 42 and 49.
       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
March 25, 2019 Page 2                                         Construction
FirstName LastName