June 20, 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 Year Ended December 31, 2018
           Filed May 1, 2019
           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 Year Ended December 31, 2018

2.26 Revenue recognition from contracts with customers, page 25

1.    For each of your revenue streams please further expand your disclosures
to highlight:
        Whether any of the consideration included in your arrangements is
considered variable
         and, if so, the nature of such variable consideration. Refer to IFRS
15.119(b); and
        Identify the methods, inputs and assumptions used for determining the
transaction
         price, assessing whether an estimate of variable consideration is
constrained,
         allocating the transaction price, and measuring obligations for
returns, refunds and
         other similar obligations. Refer to IFRS 15.126(a)-(d).
Engineering and construction, page 26

2.    Given the long term nature of your engineering and construction
arrangements, please
 M nica Miloslavich
Grana & Montero S.A.A.
June 20, 2019
Page 2
         further clarify the following:
           Whether your contracts contain a significant financing component. If
a material
             portion of your contracts contain a significant financing
component, please revise to
             disclose this information pursuant to IFRS 15.65. If you relied
upon the practical
             expedient based upon IFRS 15.63, disclose this pursuant to IFRS
15.129 and confirm
             the timing between progress payments and transfer of control and
payment was not
             expected to exceed one year;
           How you considered the disclosure requirements related to your
remaining
             performance obligations for the periods presented. Refer to IFRS
15.120 through 122;
             and
           Whether your arrangements give rise to any material contract assets
and liabilities. To
             the extent they do, please disclose the nature and amount of any
contract assets and
             contract liabilities along with the applicable disclosure
requirements in IFRS 15.116
             through 118.
Construction, page 26

3.       We note your disclosure that a modification is included in the
contract revenue when the
         customer is likely to approve the modification, as well as when the
amount of income
         arising from such modification can be measured reliably. Please tell
us how
         this accounting complies with IFRS 15.18 through 20. In providing your
response, please
         clarify how you considered whether such modifications were approved
and whether such
         modifications are typically considered to be separate contracts or
part of existing
         contracts. Furthermore, please tell us how you considered the guidance
in IFRS 15.50-54
         and IFRS 15.56-58 on estimating and constraining any variable
consideration related to
         such modifications.
       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.

       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
June 20, 2019 Page 2                                         Construction
FirstName LastName