One of the objectives of Trenitalia S.p.A., a wholly-owned subsidiary of FS Italiane S.p.A., is to guarantee that Italy has quality services available that satisfy the transport needs of travellers, both on a national level and European level. It is committed to making its industrial structure increasingly more modern and functional and to directing the company towards its goals of technological development and cost-efficient turnover, by working with loyalty and professionalism to compete in a global market.

Trenitalia S.p.A. conducts its business operations in accordance with a vision of corporate social responsibility based on the values of responsibility, ethics, integrity, fairness, transparency and lawfulness, in the knowledge that this is reflected in the objectives and reputation of the Company and the Group, generating value and meeting the highest expectations of its stakeholders.

Trenitalia S.p.A. encourages and promotes a corporate culture that is based on ethics and integrity, and inspired by the principle of “zero tolerance for corruption”.

The Code of Ethics of the FS Italiane Group, approved by the Board of Directors of Trenitalia S.p.A., is the shared core of the Ferrovie dello Stato Italiane Group’s fundamental values and standards of conduct, and the compass that guides the behaviour of all the individuals within the Group (corporate bodies, management, employees) and of all those who, directly or indirectly, permanently or temporarily, establish relations or have dealings with the Companies in the Group.

Integrity and honesty are fundamental values that are enshrined in the FS Italiane Group’s Code of Ethics, which demonstrates its commitment to act in full compliance with the law and the principles of transparency and to repudiate and discourage corruption in any form, at any level, both in Italy and abroad, as well as repudiating and discouraging acts of abuse or maladministration.

Trenitalia S.p.A. recognises and promotes healthy and fair competition between competitors, and is committed to complying with the antitrust laws in force in each of the countries in which it operates, as well as the instruments and decisions issued by the regulatory and competition authorities, and to promote the dissemination of the value of fair competition – as a decisive and strategic element for a sustainable business.

Trenitalia S.p.A., as a Company of the FS Italiane Group, adheres to the United Nations Global Compact, which promotes the construction of a sustainable global economy that respects human and labour rights, environmental protection and the fight against corruption, and to Transparency International’s Business Integrity Forum (BIF), which requires large national companies to commit to preventing and combating corruption, as well as disseminating anti-corruption instruments and practices, including to small and medium-sized enterprises, and the spreading of a common and shared culture of lawfulness.

Trenitalia S.p.A. guarantees its stakeholders that the management of the Company shall be in alignment with the established strategic objectives and cognizant of the risks that may influence the achievement of these objectives and affect the value and reputation of the Company. To this end, it encourages the development, constant implementation and strengthening of internal controls and risk management systems and of compliance and anti-corruption programmes, in line with the highest standards and best practices, cognizant of the importance of the culture of internal control and risk prevention in facilitating informed decision-making and helping to ensure the preservation of company assets and maintaining the efficiency and effectiveness of corporate processes, the reliability of financial information, compliance with laws and regulations and the protection of the Company’s reputation and the Group in Italy and abroad.

The Anti corruption policy of the FS Group is a clear and unequivocal expression of the principle of zero tolerance for corruption on which the FS Group bases its business, in the belief that acting in accordance with the law and with integrity, besides being a legal obligation and a moral duty, is reflected in the achievement of the objectives and the reputations of the individual Companies involved, as well as the Group as a whole, and contributes to creating value, also with regard to stakeholders, in the pursuit of sustainable success.

Organisation, Management and Control Model

The Organisational, Management and Control Model, pursuant to Legislative Decree no. 231/2001, adopted by Trenitalia S.p.A., consists of a series of rules, protocols, instruments and codes of conduct that are designed to provide the Company with an effective and suitable organisational, management and control system capable of identifying and preventing the risk of crimes being committed pursuant to Legislative Decree no. 231/2001 by individuals from the Company, or persons functionally linked to the Company, in the interest or to the advantage of the Company itself. The adoption and effective implementation of Model 231 is an essential condition for exoneration from administrative liability pursuant to Legislative Decree No. 231/2001. Model 231, which has been implemented by Trenitalia S.p.A. since 2005, has been progressively updated in the face of the organisational and regulatory changes that have affected the Company over the years, with a view to continuous improvement.

The Anti-Bribery and Corruption Management System

The Anti Bribery and Corruption management system (ABC system) is the model adopted on a voluntary basis by Trenitalia S.p.A. for the prevention of corruption in a “broad” sense, i.e. including cases of maladministration and malfunctioning. The ABC system identifies an organic apparatus of principles and standards of conduct for the company processes that are most exposed to risk, guided by national and international best practices on the subject, with the aim of strengthening the company’s anti-corruption policies, supporting staff in their daily operations and promoting a corporate culture inspired by integrity, fairness and lawfulness.

The ABC system, along with Model 231, is a key element in Trenitalia S.p.A.’s Unified Anti-corruption Framework .

Management of reports

In compliance with current legislation, Trenitalia S.p.A. has adopted a report management process, regarding the company sent by third parties or by people within the FS Italiane Group, including those sent anonymously.

The process complies with the new legislation introduced by Italian Legislative Decree No. 24 of 10 March 2023, implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, on the protection of persons who report breaches of Union law and including provisions regarding the protection of persons who report breaches of national legislative provisions (the so-called “Whistleblowing Decree”).
The report management process is an integral part of Trenitalia S.p.A.’s Model, pursuant to Legislative Decree no. 231/2001.
Trenitalia S.p.A. has implemented a dedicated IT platform for sending and managing reports, which is the preferred channel for sending such reports.

The following do not constitute whistleblowing reports: disputes, claims or requests linked to a personal interest of the Whistleblower, which pertain exclusively to his/her individual working relationship, or regarding his/her relationship with the figures above him/her in the hierarchy; communications or complaints concerning activities of a commercial nature or public services.