Ethics, Transparency and Accountability

Group Companies Careers Whistleblowing Reports

Home About us Organisation and Governance Ethics, Transparency and Accountability

Together with the entire FS Italiane Group, RFI has always encouraged and fostered the dissemination of a corporate culture based on ethics, transparency, legality and the creation of shared value for all stakeholders.

We carry out our activities in accordance with an approach founded on social, economic and environmental sustainability based on values of responsibility, ethics, integrity, fairness, transparency and legality with the objective of providing quality services at the lowest cost to the community and capable of generating shared value for all stakeholders. The FS Italiane Group’s fundamental values and standards of conduct are summarised in the Code of Ethics, a veritable charter of fundamental rights and duties that dictates the rules by which the FS Italiane Group – from management to employees – exercises its role responsibly, together with its partners and suppliers. As an Infrastructure Manager, we offer our services to customers, passengers and the community in respect of the principles stated in our Service Charter.

Together with the entire FS Italiane Group, we adhere to the United Nations Global Compact, which promotes the construction of a sustainable global economy based on respect for human and labour rights, environmental protection, and the fight against corruption, as well as the Transparency International’s Business Integrity Forum (BIF), which sees large national companies commit to preventing and combating corruption as well as to the dissemination – including to small- and medium-sized enterprises – of anti-corruption tools and practices along with the dissemination of a common and shared culture of legality. In order to prevent and combat corruption, we have also adopted the FS Group Anti-Corruption Policy, as an expression of the zero tolerance for corruption principle on which the FS Group bases its business. We have then voluntarily adopted the Anti Bribery & Corruption management system.

With this in mind, we guarantee our stakeholders a healthy, fair and consistent conduct of business in line with the corporate objectives defined by the Board of Directors, aware of the risks that may impact the achievement of such objectives and affect the value and reputation of the company. We contribute to defining, updating and incentivising the constant implementation and strengthening of the system of internal controls and risk management, as well as compliance and anti-corruption programmes in line with the highest national and international standards and best practices, aware of the importance of the culture of internal control and risk prevention in order to ensure: • compliance with laws, Articles of Association and procedures; • the protection of company assets; • the efficient and effective management of activities; • the reliability and comprehensiveness of accounting and financial data.

CODE OF ETHICS

MODEL 231

ANTI-BRIBERY & CORRUPTION

ANTI-TRUST

COMPLIANCE MODEL

SERVICE CHARTER

The Code of Ethics is the “Charter of Fundamental Rights and Duties”, dictating the ethical rules by which the FS Group exercises its role responsibly, producing quality services at the lowest possible cost to the community. It enhances and supports teamwork as a pre-requisite for effectively carrying out complex tasks, involving multiple parties, according to clear and shared rules and with roles based on ethical and social responsibility and engagement with internal and external stakeholders.

Code of Ethics(.pdf — 2042 KB)

Model 231 forms an integral part of the Company’s Internal Control System and has been drawn up in accordance with, in addition to the regulatory requirements of Legislative Decree no. 231/2001, the “Guidelines for constructing the organisation, management and control models pursuant to Legislative Decree No. 231/2001” prepared by Confindustria, the trade association to which the FS Group belongs. The Model, which we adopted in 2004, represents the set of rules, procedures, protocols and organisational measures enacted by RFI to prevent the risk of the offences referred to in Legislative Decree no. 231/2001.

Model 231 is part of the Unified Anti-Corruption Framework we adopted as a consolidated self-regulatory tool for the prevention of corruptive phenomena. This Model protects us from offences of corruption being committed in the interest/advantage of the entity by senior or subordinate officers, with the fraudulent evasion of company procedures.

In addition, as set out in Legislative Decree 231/2001, we entrusted the task of supervising the effectiveness of Model 231 to a Supervisory Board endowed with autonomous powers of initiative and control and characterised by: • the professionalism of its members; • independence; • continuity of action. The Body is appointed by the Board of Directors (BoD) and reports to the Corporate Bodies (Managing Director, BoD and Board of Auditors) on implementation of the Model and the detection of any critical issues related thereto, for the purpose of its timely adaptation.

Model 231 (only Italian version)(.pdf — 1049 KB)

As of 2018, we have approved and adopted the Anti-Bribery & Corruption (ABC) management aystem, an integral part of the Consolidated Anti-Bribery Framework, together with Model 231 and the Anti-Bribery Policy Guidelines, identifying a set of tools and behavioural rules inspired by national and international best practices. The intent is to progressively expand in support of conscious and responsible decision-making processes, with a view to continuous improvement.

As a fundamental element of the Internal Control and Risk management system (ICRMS), the ABC system aims to enhance the transversal scope of the control systems already existing within the company through a process of progressive optimisation and operational and documentary synergy amongst the various control models.

The ABC system is a management and control tool for any eventual corruption in the “broad” sense, thus for acts and conduct (even if not constituting a specific offence) that qualify as instances of deviation from internal rules and procedures and able to jeopardise the good performance and general interest of the Company (cases of bad management and malfunction). It responds to general objectives such as: • preventing and mitigating the risks of corruption and equipping the company with measures and tools suitable for the purpose; • promoting the proper functioning of internal processes through the full awareness of management and employees of the risks related to corruption phenomena; • strengthening the principles of legality, integrity, correctness and transparency in the management of company activities and resources; • enhancing the gradual rationalisation, simplification, optimisation and operational and documental synergy of the control structures already existing within the company, avoiding redundancies and promoting coordination between the players involved.

By identifying the addressees in the Directors, Top Management, Control/Vigilance Bodies, employees, external collaborators in any capacity whatsoever, auditors, suppliers, business partners and, in general, anyone who has direct or indirect, temporary or permanent relations with RFI, the ABC system highlights the transversal nature of the operating perimeter and the total involvement of the Company.

We have implemented and adopted the Ferrovie dello Stato Italiane Group’s Antitrust Compliance Programme, which consists of a set of rules, standards of conduct, compliance tools, training and communication activities and initiatives aimed at identifying, overcoming and preventing anti-trust risks.

In compliance with the Anti-trust Compliance Programme, we have adopted the compliance tools of the Anti-trust Compliance Manual and the Code of Conduct, representing further element of the set of regulations we have in place to ensure that our stakeholders conduct their business in a manner consistent with the defined objectives and aware of the risks that may affect the achievement of such objectives and impact the company’s value and reputation.

Our Compliance Model defines the principles and rules of conduct that constitute safeguards for the prevention of risk/offence and control mechanism also for anti-corruption purposes, implementing the provisions of: • the Group Code of Ethics; • the Model 231; • the “Guidelines on Anti-Corruption Policy”; - the company’s Anti-Bribery & Corruption Management System; • the Group Antitrust Compliance Programme; • the Data Protection Framework.

The Model is inspired by the principles of value creation, transparency and stakeholder protection, along with the identification and mitigation of risks to promote the dissemination of a culture of ethics, integrity and compliance that contributes to characterising and directing the management and operational approach and choices in pursuing our objectives. The main ones include:

Promote a corporate culture based on the principles of integrity, ethics, loyalty, fairness and substantial respect for the rules;
Enable RFI and all subsidiaries to avoid any sanctions due to non-compliance with laws, regulations and standards in their areas of competence;
Prevent reputational damage, protecting the corporate image and enhancing the trust of all stakeholders, in compliance with business ethics and the principles of corporate responsibility, thus contributing to the creation of corporate value;
Stimulate the activation of specific organisational safeguards to identify, assess, mitigate and monitor compliance risks and to intercept unlawful conduct in a preventive manner whilst ensuring strict compliance.

The “RFI Service Charter” is the official document with which we communicate each year our commitment to the quality of services offered to the public and set out the objectives that we aim to achieve in the areas of activity that are most relevant to the “end users” of the railway network and its stations. The principles that guide us in the provision of our services can then be summarised in four points.

1. Traffic safety and passenger protection

We are committed to adopting tools, processes and technologies that offer the highest levels of safety in train operations as well as in all other production activities, protecting all network users, passengers, workers and the environment. For the protection and safety of people in the station and the infrastructure assets, we cooperate with law enforcement and take the most appropriate preventive and surveillance measures.

2. Fairness, impartiality and non-discrimination

Access to the network is ensured for the various transport companies in accordance with the principles of fairness, impartiality and non-discrimination, also to protect the right of choice for passengers, without distinction of nationality, gender, race, language, religion or viewpoints. We are also committed to ensuring equal treatment between different geographic areas and the right of access to rail services for all categories of users, including by offering in-station assistance to people with disabilities and reduced mobility, along with promoting integration with other modes of transport.

3. Information and participation

We guarantee the utmost availability of information on our activities to all users of the infrastructure, businesses, travellers, station-goers and the community, in order to facilitate use of the services we offer and allow all stakeholders to participate in the choices affecting them. In encouraging and promoting opportunities for listening and discussion, we welcome any feedback, criticism, proposals and needs put forward by stakeholders in order to respond to their requirements with a view to continuous improvement.

4. Sustainability

We are committed to orienting the management and development of our services and assets towards the establishment of an infrastructure and mobility system that is more sustainable for people and the environment. To maximise our contribution to the achievement of the Agenda 2030 SDGs, we have chosen to adopt innovative methodologies and best practices inspired by sustainability criteria in all corporate investment and management processes – also with the involvement of stakeholders and going beyond legal obligations such as the efficient use of natural resources, circularity, climate change mitigation, improvement of environmental and social quality for the territory and community, as well as safety and inclusiveness in the workplace.

2023 Service Charter(.pdf — 1576 KB)

Management of Whistleblowing Reports

Pursuant to Legislative Decree No. 231/2001, the Anti Bribery&Corruption Management System, the FS Group's Code of Ethics, laws or regulations, Rete Ferroviaria Italiana S.p.A. has adopted a process for receiving, analysing and processing reports (including anonymous reports) on Rete Ferroviaria Italiana S.p.A. (hereinafter the “Company”) submitted by Third Parties or by FS Group's employees, to help prevent any unlawful acts, irregularities or conduct in breach of the Organisational, Management and Control Model.

The process complies with the regulatory changes introduced by 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 whistleblowers who report violations of European Union law and on provisions concerning the protection of whistleblowers who report violations of national laws (so-called “Whistleblowing Decree”).

RFI S.p.A. has a dedicated IT platform available to web users, which is the preferred channel for sending reports, as it is most suitable for guaranteeing, using IT methods, the confidentiality of the Whistleblower's identity and adequate information security measures.