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The Anti-Bribery and Corruption Management System

In accordance with the ethical and social values that have inspired the achievement of its corporate objectives, Trenitalia S.p.A. prohibits the offer, promise and giving, as well as the solicitation, acceptance and receiving, whether direct or indirect, of money, economic benefits or other advantages in all its dealings with public officials/public servants or their private counterparts.

To reinforce its commitment to combating all forms of corruption, in compliance with the principle of “zero tolerance for corruption”, Trenitalia S.p.A. has voluntarily chosen to adopt the Anti-Bribery and Corruption Management System (the ABC system), which, along with the 231 Model and the Anti-Corruption Policy Guidelines, is an integral part of the Single Anti-Corruption Framework, despite the absence of a legal obligation.

The ABC system focuses its scope of operation on prevention, in the firm belief that the most effective anti-corruption policy is one that creates an environment in which it is not conducive to commit offences, through the promotion of “good conduct” and raising awareness, including by means of communication and training programmes, leading to the establishment of a widespread culture of moral and ethical integrity.

For this reason, what Trenitalia S.p.A. intends to counter and prevent is corruption “in a broad sense”, which thus comprises not only offences but also hypothetical deviations from the rules and procedures which – while not constituting an offence/crime – may undermine the proper performance and general interest of the Company in its sound, transparent, impartial and ethical management (so-called maladministration and malfunctioning).

  • Prevention tools

    With the aforementioned objectives in mind, the ABC system has established the following tools to prevent the risk of corruption:

    • general principles (cross-cutting control principles) that include: separation of duties and responsibilities; traceability of processes and activities; respect for process roles and responsibilities; provision of process rules; absence of conflict of interest; confidentiality; transparency and cooperation in dealings with public institutions/authorities;
    • code of conduct (standards of behaviour) and other analysis and monitoring measures (indicators of possible anomalies) adapted for each of the at-risk processes involved. 

  • Processes at risk of corruption

    For the processes that are at risk of corruption included in the scope of operation, the ABC system combines the rules for preventing and combating corruption into an organic framework, requiring the entire business organisation, among other things:

    • to act in accordance with the rules established in relation to gifts, entertainment expenses and hospitality;
    • to declare any conflict of interest – even if only potential – that may interfere with the conduct of its activities and to verify the possible existence of conflict-of-interest situations concerning third parties with whom Trenitalia intends to have dealings;
    • not to make facilitation payments to public officials or public servants, whether in Italy or abroad;
    • to comply with the control measures laid down for sponsorship activities and donations;
    • not to make political contributions;
    • to ensure third parties, in their dealings with Trenitalia, are committed to the anti-bribery and confidentiality principles adopted by the Company;
    • to disclose any unlawful conduct or behaviour contrary to the Organisation, Management and Control Model, pursuant to Legislative Decree no. 231/2001, the ABC system and the FS Group Code of Ethics, in accordance with the procedures and using the tools provided by the Company.