Anti-Corruption Framework

The Anti-Corruption Framework consists of the set of documents containing the principles, guidelines and rules on anti-corruption:
  •  at Group level:
    • Group Code of Ethics;
    • Anti-Corruption Policy of Ferrovie dello Stato Italiane Group;
  •  at Company level:
    • Organisation, Management and Control Model pursuant to Italian Legislative Decree 231/2001;
    • Anti-Corruption Management Model (first edition published in 2018 under the name “Anti Bribery&Corruption management system” or ABC system).

The Anti-Corruption Framework:

  • is based on the international standard defined by UNI ISO 37001:2016 “Anti-Bribery Management Systems” and relevant national and international best-practices;
  • pursues the principle of continuous improvement.

FS Group Anti-Corruption Policy

The "Anti-Corruption Policy of the Ferrovie dello Stato Italiane Group, updated by the Board of Directors of FS SpA on 27 February 2024, unifies and integrates into a unified framework, for all Italian and foreign companies of the FS Group, the principles and measures for preventing and combating corruption, and communicates to all stakeholders the FS Group's strategy of “zero tolerance for corruption”.

The Policy identifies transversal control principles and standards of conduct for 14 risk areas, promotes training and awareness-raising on corruption prevention, supports reports and provides for the application of sanctions and contractual remedies, and pursues continuous improvement also through periodic reviews.

Compliance with the Policy is mandatory for all Group personnel, wherever they operate (including abroad), and for third parties with whom the Group establishes professional or business relations (e.g. suppliers, business partners, consultants).

The FS Group does not permit any conduct in conflict with the principles, prescriptions and prohibitions of the Policy and of applicable anti-corruption legislation.

The Policy is adopted by FS S.p.A. and by its Italian and foreign subsidiaries.

Anti-Corruption Management Model

The strategies defined at Group level in the Anti-Corruption Policy are adapted and implemented in the individual FS Group companies in the corporate Anti-Corruption Management Model (formerly the Anti Bribery&Corruption management system, ABC system) through the use of specific corruption risk analyses to identify the most risk-exposed corporate areas and the relevant prevention, control and organisational tools, and to establish the governance of the corruption prevention management process with associated planning, monitoring and reporting activities.