FSTechnology SpA has adopted an Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 which establishes protocols, rules, tools and conduct that constitute a suitable system to identify and prevent the risks of committing the relevant crimes pursuant to Legislative Decree no. 231/2001 by its employees and all those who strive to achieve the Company's objectives, subject to management or supervision by the same.

The FSTechnology SpA Model 231, adopted in April 2020 following its business launch, is subject to progressive updates with respect to changes in the company's organisation and activities and to changes in case law, such as to mark new interpretative guidelines of the regulations provided for by the Model.

FSTechnology S.p.A. has adopted the new Anti-Corruption Management Model (AC Model) as a voluntary and integrated tool for the prevention of corruption-related phenomena in a broad sense.

The AC Model aims to prevent and counteract acts and behaviors, even those not constituting a criminal offense, that represent deviations from internal rules and procedures and may compromise the proper functioning and the overall interest of the Company (cases of mismanagement and malfunction).

The AC Model is an integral part of FSTechnology S.p.A.’s Internal Control and Risk Management System (SCIGR) and, together with the Organization, Management and Control Model pursuant to Legislative Decree 231/2001, constitutes a central element of the Company’s Unified Anti-Corruption Framework, serving as a self-regulation mechanism for the prevention of corruption-related phenomena.

The "Anti-Corruption Policy of the Ferrovie dello Stato Italiane Group", updated by the Board of Directors of FS SpA on 27 February 2024, standardizes and consolidates the principles and measures for preventing and combating corruption in a single framework for all companies of the FS Group. It communicates the principle zero tolerance for corruption to all stakeholders, on which the FS Group bases its business. The Policy establishes transversal control principles and behavioral standards for 14 risk areas, promotes training and awareness on the prevention of corruption, supports reporting and provides for the application of sanctions and contractual remedies, pursuing continuous improvement also through a periodic review.

FS Technology S.p.A. has implemented a process for receiving, analyzing, and handling reports (including anonymous ones) concerning FS Technology S.p.A. that are submitted by third parties or by members of the FS Italiane Group.

The process complies with the regulatory changes introduced by Legislative Decree no. 24 dated 10 March 2023 implementing Directive (EU) 2019/1937 of the European Parliament and Council of 23 October 2019 on the protection of whistleblowers who report breaches of European Union law and on provisions for protecting whistleblowers who report breaches of national laws (the “Whistleblowing Decree”).

FS Technology S.p.A. activated the following tools:

• A dedicated computer platform as the preferred tool for whistleblowing management, because it is best suited to guarantee confidentiality of the Reporter's identity, by electronic means, and adequate information security measures;
• A telephone line with an Interactive Voice Response, accessible at the dedicated FS Technology SpA telephone number +39 0682950716, which provides for: i) call recording with the reporter's express consent; ii) falsification of the Reporter's recorded voice in order to make it unrecognisable; iii) entry of the report within the above-mentioned IT platform for whistleblowing management.