Ferrovie dello Stato Italiane SpA has adopted a procedure for managing any reports, including in anonymous form, that is able to contribute to the prevention of offences, irregularities or conduct carried out in violation of the Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001, the Anti-bribery & Corruption Management System, the FS Group’s Code of Ethics, the internal regulations and/or external regulations (related to corruption, antitrust) or whereby capable of causing damage or prejudice, even if only in terms of image or reputation, to the FS Italiane Group.

The procedure for managing reports forms an integral part of the Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 of FS SpA in implementation of Law no. 179/2017 (known as the Whistleblowing Law).

FS SpA has implemented a dedicated IT platform for sending and managing reports.

If you would like to file a report with FS SpA, access the platform.

FS SpA subsidiaries have adopted independent reporting management systems. To submit a report to a subsidiary, please consult the relevant corporate pages.

Who can submit a report?

Anyone can submit a report and in particular:

  • FS Group Personnel – employees, with permanent or fixed-term contracts, as well as members of the administrative and control bodies;
  • Third Parties – people who, for whatever reason, have/have had or intend/intended to enter into working, collaborative or business relationships with the FS Italiane Group.

FS SpA hopes that the identity of the whistleblower will be made explicit in the reports (whose confidentiality is in any case guaranteed throughout all phases of the process of receiving and managing the report). Knowing the whistleblower’s identity makes it easier to verify the facts reported and renders it possible to guarantee protection of the whistleblower, as well as keeping them informed of the results of the investigations carried out. Nonetheless, anonymous reports are permitted.

What to report

The reports relate to facts (of any nature, even purely omissive) that have already occurred or which could very likely occur, in regard to FS Group personnel or to Third Parties that may involve illicit deeds, irregularities or, in any case, conduct that is in violation of:

  • The Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 and the procedures that constitute its implementation;
  • The Anti-Bribery & Corruption Management System;
  • The FS Group’s Code of Ethics;
  • Laws, internal regulations (related to corruption, antitrust, recycling);
  • provisions of the authorities;
  • In any event, the aim of preventing damage or prejudice, even if only in terms of image or reputation, to the FS Italiane Group.

The reports must concern facts of which the whistleblower has direct knowledge, having well-founded reasons to believe that the information reported is true at the time of communication.

Reports must be made promptly upon becoming aware of the facts in order to make verification concretely possible.

Communications, grievances, claims and requests concerning topics other than those of the reports are to be excluded. Reports must not involve personal grievances.

The whistleblowing platform

In implementation of Law no. 179/2017 (the Whistleblowing Law), FS SpA has created an IT platform for sending reports even anonymously. The platform is the preferential tool for submitting and managing reports, being better equipped to protect the confidentiality of the whistleblower’s identity and ensure adequate safety measures regarding the information.

Through the platform it is possible to:

  • Send a report;
  • Modify or update a submitted report;
  • Determine the status of a submitted report;
  • Receive feedback on the results of the assessments, where the whistleblower has made their identity known.

This platform is able to:

  • Separate the identifying data of the whistleblower from that contained in the report, providing for the adoption of replacement codes for the identifying data, so that the report can be processed anonymously;
  • Keep the content of the report confidential during the entire management phase, allowing access only to authorised parties;
  • Adopt secure protocols for transporting data on the network as well as the utilisation of cryptographic tools on that contained in the report and any attached documentation;
  • Interact with the whistleblower, ensuring their anonymity.

Alternative channels

Alternatively, reports can be sent:

  • By ordinary mail, to the address:
  • FS SpA, Segreteria Tecnica Comitato Etico presso la Funzione Audit di FS SpA - Piazza della Croce Rossa 1 – 00161 Roma; or FS SpA, Organismo di Vigilanza c/o Funzione Audit di FS SpA – Piazza della Croce Rossa 1 – 00161 Roma);
  • By email, to the addresses: comitatoetico@fsitaliane.it; segnalazioni.231@fsitaliane.it;
  • Verbally, by means of a declaration issued by the whistleblower at a specific hearing to the FS SpA Ethics Committee/Supervisory Body, being recorded in the minutes and signed by the whistleblower.

FS SpA ensures the confidentiality of the whistleblower’s identity, prohibits any form of retaliation or discrimination against anyone who has submitted a report as well as third parties connected to the whistleblower, having adopted measures aimed at protecting the rights of the subjects reported.

To ensure no retaliation against the whistleblower, a system for monitoring the whistleblower’s work situation has been activated for FS SpA staff, with a duration of two years from the date of reporting.

The subjects in any way involved in managing the reports are to maintain – within the limits established by law – confidentiality regarding the existence and content of the report and the activities carried out in this regard, in addition to guaranteeing the confidentiality of the whistleblower’s identity along with that of the reported subjects and any other subjects involved, in accordance with current legislative provisions.

For reports in which the whistleblower provides their personal details, they shall be informed of the receipt and handling of the report, as well as the outcome of the investigations conducted.

The reported subject will then be informed about the content of the report, of which they can obtain a copy (without any evidence of the name of the reporting party), and regarding the results of the investigations carried out.

In both cases, certain precautions have been adopted in the interest of excluding any prejudice to the objectives and interests involved. For example, the whistleblower may not be notified regarding the results of the investigation if the rights of the reported person could be unduly compromised. Similarly, informing the whistleblower could be delayed or omitted in order to prevent any risk of compromising the investigations to be carried out and, in any case, when notification could even indirectly lead to the identity of the reporting person being discovered.

Reports are submitted to the FS SpA Ethics Committee and/or Supervisory Board.

The FS SpA Supervisory Body manages the reports relating to violations or attempted circumvention of FS SpA’s Model 231 or violation of the Code of Ethics that have or could have relevance pursuant to Legislative Decree no. 231/2001.

If the reporting, following the outcome of a preliminary investigation, proves to be merely circumstantial, preliminary activities are carried out, with the support of the Audit Department, to ascertain whether or not the reported facts are well-founded.

Any reports concerning Subsidiaries are then sent to the competent bodies of the company (Ethics Committee/Supervisory Body) for the relative investigations.

As part of the reporting management process, personal data is processed in compliance with current legislation on the matter (EU Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018). 


FAQ: Management of Whistleblowing Reports

As follows a short guide to submit a report and the enlisted communication channels.