Together with the entire FS Group, we promote the dissemination of a corporate culture marked by ethics, transparency, legality, and the creation of shared value for all stakeholders. In order to facilitate informed decision-making processes and safeguard the Company’s assets, its efficiency and lawfulness, and reliable information flows, we have implemented a series of Governance tools to disseminate the common and shared policy of legality.
"Charter of Fundamental Rights and Duties" through which the Ferrovie dello Stato Italiane Group sets out and clarifies its responsibilities and ethical/social commitments towards all Stakeholders.
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By resolution of the Board of Directors of 19 October 2020, we appointed our Ethics and Reports Committee, which supervises compliance with its rules, by providing consultancy and guiding services in the company's activities. In particular, the Code provides for the need to behave with absolute honesty, loyalty, good faith, balance, fairness, diligence, cooperation and transparency.
The Ethics Committee is composed as follows:
Chairperson: Carlo Marcone, Head of the 'Legal Affairs' staff structure
Member: Sandro Starace, Head of the 'Personnel and General Services' staff structure
Member: Francesco Corvo, Head of the 'Administration, Finance and Control' staff structure
To report an issue: comitatoetico@infrarail.it
Model 231 is the system of internal controls adopted by each Company to prevent the risk of offences being committed by someone operating within or on behalf of the Company (Management, Employees, Collaborators, etc.) in the interest of or to the advantage of the Company.
The adoption and effective implementation of Model 231 is an essential condition to exclude the Company's administrative liability pursuant to Legislative Decree No. 231/2001.
In order to strengthen the Internal Control and Risk Management System of the Company, and prevent corruption phenomena, by resolution of the Board of Directors of 10 February 2022, we have establish the Anti Bribery & Corruption management system (ABC system), in accordance with Group Provision No. 290 /P / AD of 04 August 2020, "Anti-Bribery and Corruption Policy Guidelines and Anti Bribery & Corruption Management System of Ferrovie dello Stato Italiane S.p.A.", and CO/I No. 21/P / AD of 18 Feb. 2021, "Anti-Bribery and Corruption Policy Guidelines and Anti Bribery & Corruption Management System of RFI S.p.A.".
The ABC system is a management and control tool for corruptive hypotheses in the 'broadest' sense, i.e. for acts and conduct which deviate from internal rules and procedure, even if they do not constitute a specific offence, and may jeopardise the good performance and general interest of the Company (cases of mismanagement and malfunctioning).
In order to prevent and combat corruption, we have also adopted, by resolution of the Board of Directors of 24 July 2024, the FS Group Anti-Corruption Policy, as an expression of the "zero tolerance for corruption" principle on which the FS Group bases its business
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FS Italiane Group's Antitrust Compliance Programme consists of a set of rules, standards of conduct, compliance tools (Antitrust Compliance Manual, Code of Conduct), training and communication activities and initiatives aimed at identifying, overcoming and preventing antitrust risks in the main business sectors in which FS Italiane Group companies operate, in order to ensure full compliance with antitrust regulations and to spread a culture of fair competition within the Group.
Our Compliance Model defines the principles and rules of conduct acting as crime-risk prevention and control aids, including for anti-corruption purposes, by implementing the provisions of: • the Group's Code of Ethics, • Model 231, • the ‘Guidelines on the Anti-Corruption Policy’, • the company's Anti Bribery & Corruption Management System, • the Group's Antitrust Compliance Programme, • the Data Protection Framework.
The Model is inspired by the principles of value creation, stakeholder transparency and protection, and risk identification and mitigation to promote the dissemination of a culture of ethics, integrity and compliance, which will characterise and direct management and operational approach and choices while pursuing our objectives. The main ones include:
Stimulating the onset of specific organisational safeguards to identify, assess, mitigate and monitor compliance risks and to intercept unlawful conduct in a preventive manner and ensure strict compliance.
Whisteblowing - segnalazioni
In order to contribute to the prevention of offences, irregularities or conduct in violation of the Organisational, Management and Control Model, pursuant to Legislative Decree No. 231/2001, the Anti Bribery&Corruption Management System, FS Group’s Code of Ethics, and laws or regulations, Infrarail S.r.l. has adopted a process for receiving, analysing and processing reports (including anonymous ones) concerning Infrarail S.r.l. and sent by Third Parties or by FS Italian Group's Persons".
The whistleblowing management process - an integral part of Model 231 - provides for the transmission and communication of whistleblowing also in anonymous form. The FS Group ensures the confidentiality of the identity of the whistleblower and prohibits any form of retaliation or discrimination against anyone who makes a report.