ANTI-CORRUPTION SYSTEM

LOYALTY, FAIRNESS AND TRANSPARENCY

The top management, the management and all the employees of Trenord are firmly committed to carrying out all activities within their competence with loyalty, fairness, transparency and honesty, and with respect for legality. That is why Trenord rejects and prohibits corruption without exception.

With the aim of continuing the process of strengthening and continuously improving its governance system, Trenord has implemented the Anti-Corruption System, without any legal constraints, as an instrument of self-regulation as part of a virtuous path that the Company is dedicated to pursuing.

THE PROJECT

The Anti-Corruption Project, launched in early 2018, saw the involvement of Trenord's management in the process of identifying and assessing the main business activities in which the risk of corruption could occur, and in the preparation of a compliance system to oversee the processes at risk. The Project aimed at completing and optimising the control system already existing within the Company, focusing on the most important aspects from an anti-corruption perspective and in compliance with the Company's Code of Ethics.

It is with this in mind that the Company's Board of Directors, at its meeting of 25 July 2018, approved the Trenord Anti-Corruption System, inspired by national requirements and the guidelines set out in Act No. 190/2012 and the ANAC Guidelines, as well as best practices and international standards, such as the OECD Convention and the ISO 37001 Standard.

This Anti-Corruption System allows the Company to rely on effective measures to prevent corruption, while promoting an increasingly transparent business model, to the benefit of Trenord's reputation and performance.

For Trenord, in no case may the conviction of acting in favour or to the advantage of the Company justify, not even in part, any attempt or corruptive act or any illegal behaviour or behaviour that is not in line with the Company's Code of Ethics.

ADOPTION AND IMPLEMENTATION

The first element for the development of an effective strategy to combat corruption is represented by the maturation of an in-depth knowledge of prevention tools: in this sense, an activity to raise awareness among Trenord personnel and a training activity dedicated to the various professional figures has been initiated.

Trenord's staff is required to be strongly committed and constantly attentive to understanding and implementing those control mechanisms that the Anti-Bribery Policy and the related Regulatory Instruments of the Trenord Anti-Bribery System provide for in the conduct of daily business activities.

In order to ensure the effectiveness of the Anti-Corruption System, a dedicated organisational unit has been set up, whose task is to ensure effective support to the company structures in the adoption of the Policy, and in spreading the culture of ethics and compliance.

SIGNALS

If Trenord Personnel become aware (or have reasonable suspicion of the existence) of conduct that may, even in the slightest, constitute a violation of Trenord's Anti-Bribery and Corruption Policy, they must report this situation in accordance with the company's procedures for reporting violations and irregularities. In this sense, Trenord provides the possibility to report episodes of non-compliance through an online guided path that assists the reporter. This tool complements other traditional reporting methods such as email and regular mail.

For third parties, it should be noted that dedicated channels of communication to the Trenord Supervisory Committee are established, consisting of:

email address: odv231@trenord.it

post office box: c.a. Organismo di Vigilanza di Trenord - Piazzale Luigi Cadorna, 14 - 20123 Milano

Trenord guarantees the utmost confidentiality of the reports submitted in accordance with its own company procedures, and also ensures protection from any form of threat or retaliation to all those who have submitted such reports.