ANTI-CORRUPTION SYSTEM

 

LOYALTY, FAIRNESS AND TRANSPARENCY

The top management, management and all the employees at Trenord are firmly committed to carrying out all the activities for which they are responsible with loyalty, fairness, transparency and honesty, and in compliance with the law. Trenord therefore unreservedly rejects and prohibits corruption.

In order to continuously strengthen and improve its governance system, Trenord has implemented an Anti-Corruption System, although it is not legally mandated. This system serves as a self-regulation tool within the company's broader ethical commitments.

 

THE PROJECT

The Anti-Corruption Project, launched in early 2018, involved Trenord's management in the process of identifying and evaluating the main corporate activities in which the risk of corruption could arise, and in preparing a compliance system to monitor at-risk processes. The project is intended to complement and optimise the company's pre-existing control system, focusing on the most important aspects from an anti-corruption perspective, in compliance with the company's Code of Ethics.

 

In this vein, the company's board of directors, in the meeting of 25 July 2018, approved the Trenord Anti-Corruption System, inspired by the national requirements and guidelines laid out in Italian Law no. 190/2012 and the Italian Anti-Corruption Authority (ANAC) guidelines, as well as by international best practices and standards, such as the OECD Convention and the ISO 37001 Standard.

 

This Anti-Corruption System allows the company to rely on effective measures to prevent corruption, while promoting an increasingly transparent business model, thereby bolstering Trenord's reputation and performance.

 

For Trenord, under no circumstances may the belief of acting in favour or to the advantage of the company justify, even in part, any attempt or act of corruption, any illegal behaviour, or any behaviour that is not in line with the company's Code of Ethics.

 

ADOPTION AND IMPLEMENTATION

The first element for the development of an effective strategy to combat corruption is an in-depth knowledge of prevention tools: to this end, an awareness-raising activity for Trenord personnel and a training activity for various professional figures have been launched.

 

In their everyday work activities, Trenord personnel are required to have strong commitments and to devote constant attention to understanding and implementing the control mechanisms established by the Anti-Corruption Policy and the regulatory instruments associated with the Trenord Anti-Corruption System.

 

In order to ensure the effectiveness of the Anti-Corruption System, a dedicated organisational unit has been established, whose mission is to provide effective support to corporate structures with regard to adopting the policy and spreading a culture of ethics and compliance.

 

WHISTLEBLOWING SYSTEM

In 2023, in accordance with Italian Legislative Decree no. 24/2023 implementing EU Directive no. 2019/1937, Trenord further strengthened its Whistleblowing System through the introduction of additional channels for reporting potential violations, thereby underlining its commitment to combatting illegal conduct and ensuring the highest standards of confidentiality with regard to the information transmitted and the identity of the whistleblower and reportee.

To this end, Trenord encourages users of the Whistleblowing System (exclusively legal representatives, directors, members of the supervisory bodies, managers, employees, collaborators, interns, suppliers and their collaborators, freelancers and consultants, self-employed workers, shareholders) to report any violation of Trenord's Anti-Corruption Policy of which they have become aware (or even have a reasonable suspicion) in accordance with the "Trenord Srl Internal Violation Reporting System".

 

The Trenord Whistleblowing System is made up of the following channels:

1. web platform, accessible at the following link trenordwhistleblowing.integrityline.com;
2. free recorded voicemail available at +39 (0)2 81480081, by entering the code 9548 as the "4-digit Company Access Pin";
3. the possibility to request a direct meeting by sending an email to the comitatowhistleblowing@trenord.it email address, including "whistleblowing" in the email subject.

 

In addition to the above, the following channels are also available:

1. Regular postal address: Trenord Srl, Piazzale Luigi Cadorna 14, 20123, Milan, Italy, For the attention of the Whistleblowing Committee (the report must be placed in two sealed envelopes: the first with the whistleblower's identification data and a photocopy of their identification document; the second with the report. Both must be placed in a third sealed envelope marked "confidential" on the outside).
2. Channel provided by Trenord for communications to the Supervisory Body within the scope of Model 231.

 

Trenord guarantees the confidentiality of the identity of the whistleblower and the information contained in report at each stage of the whistleblowing process, to the extent that anonymity and confidentiality are enforceable under the law.

Finally, Trenord protects whistleblowers against any direct or indirect retaliatory or discriminatory act for reasons connected, directly or indirectly, to the reporting of potential violations. This protection is guaranteed to the whistleblower even when the complaint is deemed to be unfounded, but is based on rational criteria and good faith. The commission of retaliatory or discriminatory acts against the whistleblower may result in the initiation of disciplinary proceedings against the perpetrator and the imposition of the relevant disciplinary measures, in accordance with the provisions of the applicable national employment law.