Whistleblowing

Important: do not use this page for complaints, communications, or suggestions regarding services to the public of a commercial nature. They will not be taken into consideration.

For these purposes, consult the dedicated section of the website

WHISTLEBLOWING SYSTEM

Trenord carries out its own business with loyalty, fairness, transparency, honesty and integrity, and in compliance with applicable national and international laws, regulations, standards and best practices.

Trenord has therefore implemented an Anti-Corruption System since 2019, although it is not legally mandated. This system serves as a self-regulation tool as part of a virtuous path that the company has undertaken with the aim of continuously strengthening and improving its governance system.

As part of the Anti-Corruption System, Trenord has also implemented a system for reporting potential violations (Whistleblowing) through the adoption of tools for reporting potential illicit conduct and/or conduct in violation of the principles established in the company's Code of Ethics.

Furthermore, in 2023, in accordance with Italian Legislative Decree no. 24/2023 implementing EU Directive no. 2019/1937, Trenord has 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 certain categories of violations, as listed below, of which they have become aware.

REPORTABLE CONDUCT

Through the Whistleblowing System, it is possible to report behaviours, acts or omissions that:

• constitute criminal offences or civil, administrative or accounting violations;
• are likely to cause harm to public health or safety, or damage to the environment;
• are likely to constitute a violation of the rules established for the following sectors, among others: public procurement; prevention of money laundering and terrorist financing; consumer protection; transport safety; protection of privacy and personal data; security of networks and information systems; and, in general, national or European legislation;
• involve legal representatives, directors, managers and/or employees of Trenord, non-controlled companies in which Trenord holds significant shareholdings, or joint ventures, or – in any case – anyone acting in the name, on behalf and in the interests of Trenord;
• are likely to cause financial or reputational damage to Trenord;
• constitute potential violations of the Code of Ethics, Model 231, the Trenord Anti-Corruption Policy and related applicable legislation, and internal regulatory instruments (e.g. policies, guidelines, procedures);
• constitute potential conflicts of interest.

WHISTLEBLOWING CHANNELS

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.

Protection of the identity of the whistleblower and confidentiality of information

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.

 

Prohibition of retaliatory or discriminatory acts towards the whistleblower

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.