Ferrovie dello Stato Italiane S.p.A., in compliance with the values set out in the Code of Ethics, and aware that a proper tax management contributes to sustainable development, with the 'Tax Strategy of Ferrovie dello Stato Italiane Group’, identifies FS Group's objective in managing the tax variable, the consequent propensity to risk, and outlines the control methods and rules of conduct to be adopted to ensure its pursuit. The Tax Strategy is addressed to all of FS Group’s Department, Management or Control structures, to its employees, and to those who act on the Group’s behalf, despite not being part of it. FS Group's objective in managing the tax variable is to reduce the level of risk as much as possible. Consistently with this objective, the Group is characterised by a minimal risk appetite, adopting for this purpose behaviour informed by the principles of prudence, legality and correctness in the interpretation of tax regulations. In order to pursue this objective, the Tax Strategy provides for, among other things: -Compliance with laws, regulations and, in general, all applicable tax provisions, ensuring their consistent application at face value and with the ratio thereof:

• Prior involvement of the persons in charge of tax matters in the decision-making processes concerning business operations;
• Adequate prior information to management bodies on the tax consequences of strategically important transactions;
• Adequate attention and diligence in relation to all corporate processes that, directly or indirectly, may generate a tax-related risk, also guaranteed through the implementation - starting from the Parent Company and the Companies of significant relevance - of an effective control system (so-called Tax Control Framework).
   

FS Group establishes relations with tax authorities based on the principles of honesty, transparency, fairness and good faith. FS Group's Fiscal Strategy is issued by the Board of Directors of Ferrovie dello Stato Italiane S.p.A., the body in charge of which resides the ultimate responsibility for it and its compliance (so-called Tone at the top). All FS Group companies, subject to a resolution of their respective Boards of Directors, adopt the Tax Strategy and ensure its internal knowledge and application.