Ethics, compliance and integrity

  

Model 231

Organizational Management and Control Model

The Organization, Management and Control Model pursuant to Legislative Decree. n. 231/2001 consists of a series of rules, protocols, tools and conduct, functional to providing the Company with an effective and adequate organisational, management and control system suitable for identifying and preventing the risks of commission of relevant crimes pursuant to Legislative Decree. n. 231/2001 by people of the organization or functionally linked to the organization in the interest or advantage of the Company itself.​
The adoption and effective implementation of Model 231 is the essential condition for exemption from the administrative liability of the entity pursuant to Legislative Decree. 231/2001. The Model has been progressively updated in light of the organizational and regulatory changes that have affected the Company over the years, with a view to continuous improvement.

Anti-corruption

The Anti-Corruption Policy of the FS Group is an expression of the zero tolerance for corruption principle on which the FS Group bases its business, in the belief that acting according to legality and integrity, in addition to being a legal obligation and a moral duty, reflects on the achievement of the objectives and reputation of the individual companies and the Group and represents an essential foundation for guaranteeing their reliability and credibility with a view to pursuing sustainable success.​

Code of Ethics

The FS Logistix companies are inspired by the principles of responsibility, transparency and integrity. To this end, the FS Logistix companies have adopted the Code of Ethics of the Ferrovie dello Stato Italiane Group, as a founding element of their Organization, Management and Control Model pursuant to Legislative Decree. n. 231/2001.​

The Code of Ethics represents the common basis of the fundamental values ​​and standards of conduct of the Ferrovie dello Stato Italiane Group and the compass that must guide the behavior of all the people within the Group (corporate bodies, management, employees) and of all those who, directly or indirectly, permanently or temporarily, establish relations and relationships with the Group companies.

Whistleblowing

FS Logistix SpA and its subsidiaries have adopted - in compliance with current legislation - a process for managing reports, even anonymously, capable of contributing to the prevention and combating of illegal behavior or behavior contrary to the Organisation, Management and Control Model pursuant to Legislative Decree. n. 231/2001, the Anti Bribery & Corruption management system and the Code of Ethics of the FS Group. The channels indicated must be understood as privileged compared to the external one established and managed by ANAC.

Below are the references for managing reports relating to each company.

 

FS Logistix 

The reporting management process is an integral part of the Model pursuant to Legislative Decree. n. 231/2001 of FS Logistix SpA. For the sending and management of reports, FS Logistix SpA has implemented, in implementation of law no. 179/2017 (so-called whistleblowing law), a dedicated IT platform.

Below are further channels dedicated to reporting:

  • ordinary mail, addressed to Mil SpA, Technical Secretariat of the Ethics and Reporting Committee and/or HR Department of MIL SpA with headquarters in Viale dello Scalo San Lorenzo, 16, 00185 Rome or Supervisory Body c/o Audit Department of MIL Spa with headquarters in Viale dello Scalo San Lorenzo, 16, 00185 Rome;

  • email, addressed to  comitatoetico@mercitalialogistics.it  therefore  organismodivigilanza@mercitalialogistics.it; 

  • verbally, through a statement issued by the Reporter, in a specific hearing set within a reasonable time, to the Ethics and Whistleblowing Committee or to the Supervisory Body of MIL SpA, recorded in the minutes and signed by the Reporter.

 
Mercitalia Intermodal  

The reporting management process is an integral part of the Model pursuant to Legislative Decree. n. 231/2001 of Mercitalia Intermodal SpA.
For the sending and management of reports, Mercitalia Intermodal SpA has implemented, in implementation of law no. 179/2017 (so-called whistleblowing law), a dedicated platform .

Below are further channels dedicated to reporting:

  • verbally, through a statement issued by the Reporter, in a specific hearing set within a reasonable time, to the Supervisory Body or to the Ethics Committee of Mercitalia Intermodal S.p.A., recorded in the minutes and signed by the Reporter.

 

Mercitalia Shunting & Terminal 


The reporting management process is an integral part of the Model pursuant to Legislative Decree. n. 231/2001 of Mercitalia Shunting & Terminal Srl.
For the sending and management of reports, Mercitalia Shunting & Terminal Srl has implemented, in implementation of law no. 179/2017 (so-called whistleblowing law), a dedicated platform.

Below are further channels dedicated to reporting:

  • ordinary mail, addressed to the Supervisory Body or Ethics Committee c/o Mercitalia Shunting & Terminal Srl with headquarters in via Angelo Scarsellini, 119, Torre B, 17th floor, 16149 Genoa;

  • verbally, through a statement issued by the Reporter, in a specific hearing set within a reasonable time, to the Supervisory Body or to the Ethics Committee of Mercitalia Shunting & Terminal Srl, recorded in the minutes and signed by the Reporter.

 
Mercitalia Rail 


The reporting management process is an integral part of the Model pursuant to Legislative Decree. n. 231/2001 of Mercitalia Rail Srl.
For the sending and management of reports, Mercitalia Rail Srl has implemented, in implementation of law no. 179/2017 (so-called whistleblowing law), a dedicated platform. 

Below are further channels dedicated to reporting:

  • ordinary mail, addressed to the Supervisory Body or Ethics Committee c/o Mercitalia Rail Srl with headquarters in Piazza della Croce Rossa 1, 00161 Rome;

  • verbally, through a statement issued by the Reporter, in a specific hearing set within a reasonable time, to the Supervisory Body or to the Ethics Committee of Mercitalia Rail Srl, recorded in the minutes and signed by the Reporter.

 

Bluferries 

The reporting management process is an integral part of the Model pursuant to Legislative Decree. n. 231/2001 of Bluferries Srl.
For sending and managing reports, Bluferries Srl has implemented, in implementation of law no. 179/2017 (so-called whistleblowing law), a dedicated platform.

Below are further channels dedicated to reporting:

  • ordinary mail, addressed to the Supervisory Body or Ethics Committee c/o Bluferries Srl with headquarters in via Calabria n.1 98122 Messina (ME) Italy;

  • verbally, through a statement issued by the Reporter, in a specific hearing set within a reasonable time, to the Supervisory Body or to the Ethics Committee of Bluferries Srl, recorded in the minutes and signed by the Reporter.

 

Terminal AlpTransit S.r.l. 

The reporting management process is an integral part of the Model pursuant to Legislative Decree. n. 231/2001 of Terminal AlpTransit Srl.
For sending and managing Terminal AlpTransit Srl reports, the channels are as follows:

  • ordinary mail, addressed to the Supervisory Body or Ethics Committee c/o Terminal AlpTransit Srl with headquarters in Via Anton Checov n. 50/2, 20151 Milan;

  • verbally, through a statement issued by the Reporter, in a specific hearing set within a reasonable time, to the Supervisory Body or to the Ethics Committee of Terminal AlpTransit Srl, recorded in the minutes and signed by the Reporter.

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