Anti-corruption system

Trenord rejects and prohibits corruption in all its forms. All staff — from top management to employees — are required to act with loyalty, fairness and transparency. This page explains how our Anti-Corruption System works, how it was built and how to report a violation.

Why We Built This System

Trenord adopted an Anti-Corruption System voluntarily, without any legal obligation. It is a self-regulation tool, part of a broader commitment to strengthening our governance and promoting a transparent business model.

The system is inspired by:

• Italian Law no. 190/2012 and ANAC guidelines
• The OECD Convention
• The ISO 37001 Standard

Under no circumstances may the belief of acting in the company's interest justify any act of corruption or any behaviour not in line with our Code of Ethics.

How the System Was Developed

The Anti-Corruption Project launched in early 2018. It involved Trenord's management in:

• Identifying the main corporate activities at risk of corruption
• Evaluating those risks
• Building a compliance system to monitor at-risk processes

On 25 July 2018, Trenord's board of directors formally approved the Anti-Corruption System. The system complements and optimises pre-existing internal controls, with a focus on the most sensitive areas from an anti-corruption perspective.

Training and Daily Commitments

Knowing the tools is the first step in fighting corruption. For this reason, Trenord has launched:

• Awareness-raising activities for all personnel
• Targeted training for specific professional roles

In their daily work, all Trenord staff are required to understand and apply the control mechanisms set out in the Anti-Corruption Policy. A dedicated internal unit supports all corporate structures in adopting the policy and spreading a culture of ethics and compliance.

Whistleblowing System

In 2023, in line with Italian Legislative Decree no. 24/2023 (implementing EU Directive 2019/1937), Trenord strengthened its Whistleblowing System by adding new reporting channels.

Who can report: legal representatives, directors, supervisory body members, managers, employees, collaborators, interns, suppliers, freelancers, consultants and shareholders.

What to report: any violation — or reasonable suspicion of a violation — of Trenord's Anti-Corruption Policy.

How to Submit a Report

• Web platform: trenordwhistleblowing.integrityline.com
• Free recorded voicemail: +39 (0)2 81480081 — enter code 9548 as the 4-digit Company Access Pin
• Direct meeting request: email comitatowhistleblowing@trenord.it with "whistleblowing" in the subject line
• Regular post: Trenord Srl, Piazzale Luigi Cadorna 14, 20123, Milan — for the attention of the Whistleblowing Committee (the report must be placed in two sealed envelopes inside a third sealed envelope marked "confidential")
• Model 231 channel: for communications to the Supervisory Body

Confidentiality and Protection

Trenord guarantees the confidentiality of the whistleblower's identity and all information contained in the report at every stage of the process.

Whistleblowers are protected against any direct or indirect retaliation, even if the report is ultimately unfounded, provided it was made in good faith. Any retaliatory act against a whistleblower may result in disciplinary proceedings against the perpetrator.