2021 Sustainability Report
| ABC SYSTEM The FS Italiane Group conducts its business in compliance with the principles of integrity, ethics and zero tolerance for corruption. The Group has adopted a Code of Ethics and 231 Model, issued specific guidelines for the prevention of corruption between private parties within the FS Italiane Group and joined the United Nations’ Global Compact, the tenth principle of which is to “work against corruption in all its forms”, demonstrating its commitment to operating in accordance with these principles. To further support this commitment, since 2017, the Parent has voluntarily used a self-regulatory tool to prevent corruption. Called the unified anti-corruption framework, this tool is based on two management and control models:
94
UNIFIED ANTI-CORRUPTION FRAMEWORK
Guidelines on the anti-corruption policies
MOG 231
ABC system
Legislative decree no. 231/01 crimes
Corruption in general
* the 231 Model, for suspected corruption within the scope of Legislative decree no. 231/2001 (including between private parties, undue soliciting to give or promise benefits and misconduct, embezzlement, abuse of office, influence peddling);
* the anti-bribery & corruption management system (“ABC system”), set up to implement the Anti-corruption policy guidelines which also form an integral part of the framework and contain directions for the creation of an effective anti-corruption system at FS Italiane SpA.
