MODEL 231

On 27 September 2012, Trenord approved the Organisational, Management and Control Model pursuant to Legislative Decree No. 231/01 (i.e. Model 231), aimed at preventing the administrative liability of the Company in relation to certain crimes committed or attempted in the interest or to the advantage of the Company by directors or employees. The Company's liability is excluded if it has adopted and effectively implemented, prior to the commission of offences, an organisation, management and control model suitable for the prevention of crime, and has set up a body responsible for supervising the functioning of and compliance with the model.

Trenord's Model 231, which is constantly updated, consists of a General Section aimed at illustrating the function and principles of the model, as well as its general contents, and a Special Section aimed at indicating sensitive activities, the related principles of conduct and the specific control measures responsible for preventing or mitigating offences.

The following form an integral part of Trenord's Model 231:

The Code of Ethics
The risk self assessment aimed at identifying sensitive activities
All the provisions, internal measures, acts or company operating procedures that constitute the instruments for implementing the Model

Trenord updated its Model 231 in 2014, 2017, 2019, 2020 and 2023.

The current Model 231 was updated by resolution of the Trenord Board of Directors on 20 february 2023.

Per the resolution of 4 March 2019, the Trenord Board of Directors of Trenord also appointed the Supervisory Committee, a three-member collegiate structure, with autonomous powers of initiative and control, which has been entrusted with the task of supervising the functioning, effectiveness and compliance with Model 231.

Dedicated channels of communication to the Trenord Supervisory Committee are established, consisting of: