FS Italiane has long encouraged and promoted the spread of a corporate culture based on ethics, integrity, fairness and legality, inspired by the Zero Tolerance for Corruption principle, of which the Group’s top management is a primary proponent and promoter.
GIANFRANCO BATTISTI, FS ITALIANE’S CEO AND GENERAL DIRECTOR
Ferrovie dello Stato Italiane SpA carries out its activities according to a vision of corporate social responsibility founded on values of responsibility, ethics, integrity, fairness, transparency and legality in the knowledge that such reflects on the objectives and reputation of Company and Group, generating value and meeting the highest expectations of all stakeholders.
Ferrovie dello Stato Italiane SpA encourages and promotes the dissemination of a corporate culture based on ethics and integrity, one inspired by the principle of “zero tolerance for corruption”.
The Code of Ethics represents the common basis of the fundamental values and standards of conduct for the Ferrovie dello Stato Italiane Group and the compass that must direct the conduct of all parties within the Group (corporate bodies, management, employees) and all those who – directly or indirectly, permanently or temporarily – establish rapports and relations with the Group Companies.
Integrity and honesty are fundamental values enshrined in the FS Italiane Group’s Code of Ethics, manifesting the commitment to act with complete respect for legality and transparency and in repudiating and disincentivising all forms of corruption, abuse or mismanagement at any level, both in Italy and abroad.
The Group recognises and promotes fair and healthy competition between competitors, undertaking to comply with the antitrust legislation in force in each of the countries in which it operates, as well as the deeds and decisions issued by the regulatory and competition authorities and to promote the dissemination of fair competition values – as a decisive and strategic element for a sustainable business.
Ferrovie dello Stato Italiane SpA adheres to the United Nations Global Compact, which promotes the construction of a sustainable global economy that is respectful of human and labour rights, environmental protection and the fight against corruption, as well as the Transparency International Business Integrity Forum (BIF), which engages the major national companies in the prevention and fight against corruption and in the spread of a common and shared culture of legality and the dissemination of anti-corruption instruments and practices, including in favour of small and medium-sized enterprises.
Ferrovie dello Stato Italiane SpA guarantees business management for its stakeholders consistent with the defined strategic objectives and aware of the risks that can influence the achievement of these objectives as well as affecting the value and reputation of the company. To this end, it encourages the development, constant implementation and strengthening of the system of internal checks and risk management together with compliance and anti-corruption programmes, in line with the highest standards and best practices, being aware of the importance that the culture of internal checks and risk prevention has in encouraging conscious decisions being made and helping to ensure the protection of corporate assets, the efficiency and effectiveness of company processes, the reliability of financial information, compliance with laws and regulations and the protection of the Company and Group reputation in Italy and abroad.
Pursuant to Legislative Decree no. 231/2001, the Organisation, Management and Control Model consists of a series of regulations, protocols, tools and pipelines that serve to equip the Company (and the Group Companies) with an effective and adequate organisational, management and control system able to identify and prevent the risk of pertinent crimes being committed, pursuant to Legislative Decree no. 231/2001 by persons of the entity or functionally connected to the entity in the interest of or benefit to the Company itself. The adoption and effective implementation of Model 231 is necessary to exempt the institution from administrative responsibility pursuant to Legislative Decree no. 231/2001. The Model, adopted by the Company in 2003, has been progressively updated in view of organisational and regulatory changes affecting the Company throughout the years, with a view to continuous improvement.
The Anti-Bribery & Corruption Management System (ABC System) is the model adopted on a voluntary basis by Ferrovie dello Stato Italiane SpA to prevent corruptive phenomena in a “broad” sense, being inclusive of acts of maladministration and malfunction. The ABC System determines an organic apparatus of principles and standards of conduct for the most risk-exposed business processes, inspired by national and international best practices in such matters, with the aim of strengthening corporate anti-corruption principals, supporting staff in daily operations and promoting a corporate culture inspired by integrity, fairness and legality.
Together with Model 231, the ABC System forms the central component of Ferrovie dello Stato Italiane SpA’s Unified Anti-Corruption Framework.
The FS Italiane Group’s Antitrust Compliance Programme consists in a series of regulations, standards of behaviour, compliance tools (including the Antitrust Compliance Manual and Code of Conduct), training and communication activities and initiatives aimed at identifying, overcoming and preventing antitrust risks in the main business sectors in which the FS Italiane Group companies operate, in order to ensure full compliance with antitrust legislation and to disseminate a culture of fair competition within the Group.
The FS Italiane Group’s Compliance Model is aimed at preventing the risk of incurring legal or regulatory violations at a national or international level or in terms of self-regulation and the possible consequences of such, consisting of two separate but complementary components of:
In respect of the legislation in force, Ferrovie dello Stato Italiane SpA has adopted a process for the management of reports made – even anonymously – able to contribute to the prevention of and impediment to conduct that is unlawful or contrary to the Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001, to the Anti Bribery & Corruption Management System and the FS Group’s Code of Ethics.
The process for managing reports is an integral part of the FS SpA Model pursuant to Legislative Decree no. 231/2001. In implementation of Law no. 179/2017 (known as the Whistleblowing Law), FS SpA has set up a dedicated computer platform (https://www.segnalazione-whistleblowing.fsitaliane.it) for submitting and handling any reports.
The FS Italiane Group Companies have then adopted autonomous systems for managing any reports.