Antitrust Compliance Programme

The FS Group acknowledges a culture of integrity and the value of competition as decisive and strategic elements for a sustainable business, and is committed to applying Antitrust rules, the observance of which is one of the guiding principles of the Group's Code of Ethics.

The FS Group's commitment to raising staff awareness on antitrust issues, and promoting a culture of antitrust risk prevention and of competition in general, is fully accomplished in the Group's Antitrust Compliance Programme ("Antitrust Programme").

Purpose of the Antitrust Programme is to define a general compliance system, designed to identify, overcome and cover antitrust risks pertaining to the business sectors, across all FS Group companies, and this constitutes a further pillar of the Internal Control and Risk Management System.

The Antitrust Programme Framework, adopted by top management, is based on the following pillars:

• Antitrust compliance tools, after identifying the main risk areas to which FS Group companies appear potentially exposed:
  • the Code of Conduct contains practical indications of the behavioural rules that each FS Group employee is required to follow, in order to mitigate the risk of antitrust offences;
  • the Antitrust Compliance Handbook explains the basics of antitrust law, the different types of existing violations, the ways in which competition authorities can intervene, and the consequences of breaching the antitrust law.
• Internal and external communication aimed at spreading knowledge on FS Group initiatives concerning competition protection.
• Regular training for employees, in-person and/or remotely.

Compliance tools also include the specific procedures adopted, where necessary, by each FS Group company, in addition to and consistent with the Antitrust Programme.