In line with the ethical-social values that inspire the achievement of its business objectives, Ferrovie dello Stato Italiane SpA (FS SpA) prohibits the offer, promise and giving, as well as the solicitation, acceptance and receipt, direct or indirect, of money, economic advantages or other benefits in relations with public officials/public service officers or private counterparts.
In order to strengthen its commitment to fighting all forms of corruption, in compliance with the "zero tolerance for corruption" principle, FS SpA has chosen to voluntarily equip itself with the Anti Bribery&Corruption management system (ABC system) which, together with the 231 Organizational Model and the Guidelines on Anti Bribery and Corruption Policy, is an integral part of the Single Anticorruption Framework.
The ABC system focuses on prevention, in the belief that an effective anti-corruption policy must create an unfavourable environment for offences to be committed, by promoting "good conducts" and by raising awareness, including through communication and training initiatives, towards a widespread culture of integrity and ethics.
For this reason, the corruption that it is intended to fight and prevent is understood "in a broad sense”, to include not only specific types of crimes but also acts and conducts that constitute cases deviating from internal regulations and procedures that - while not constituting an illicit/crime - can prejudice the good functioning and the general interest of the Company to a correct, transparent, impartial and ethical management (so-called mala gestio and malfunctioning).
Prevention instruments
With these objectives, the ABC system defines the following instruments for the prevention of the risk of corruption:
- general principles (transversal control principles) which include: segregation of duties and responsibilities; traceability of processes and activities; respect for process roles and responsibilities; provision of process rules; absence of conflict of interest; not-disclosure; transparent and collaborative relationships with Public Institutions/Authorities;
- rules of conduct (standards of conduct) and other measures of analysis and monitoring (indicators of possible anomalies) for each of the processes at risk considered.
Processes at risk of corruption
For these areas, the ABC system integrates the rules for preventing and fighting corruption into an organic framework, asking the entire company organisation to:
- act in accordance with the rules established in relation to gifts, entertainment expenses and hospitality;
- declare any conflict of interest, even potential, that may interfere in the conduct of their activities and to verify the possible existence of conflict situations in the third parties with whom FS intends to enter into relations;
- not to make Facilitation Payments to public officials or public service representatives, both in Italy and abroad;
- to comply with the control measures provided for sponsorship activities and charitable donations;
- not to make political contributions;
- commit third parties, in their relations with FS, to respect the ethical, anti-bribery and confidentiality principles adopted by the Company;
- report any unlawful or contrary behaviour to the Organisational Management and Control Model pursuant to Legislative Decree no. 231/2001, the ABC system and the Code of Ethics of the FS Group, according to the procedures and with the tools made available by the Company.