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Italferr S.p.A. has adopted a process for managing reports, also in anonymous form, capable of contributing to the prevention of illicit acts, irregularities or conduct put in place in violation of the Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001, of the Anti Bribery & Corruption management system, of the FS Italiane Group's Code of Ethics, of internal and/or external regulations (e.g. on corruption, antitrust, etc.) or in any case likely to cause damage or harm to the FS Italiane Group, even if only in terms of image or reputation.

The report management process is an integral part of Italferr S.p.A.'s Model of Organisation, Management and Control pursuant to Legislative Decree No. 231/2001 in implementation of Law No. 179/2017 (so-called ‘Whistleblowing law’).

THE WHISTLEBLOWING PLATFORM

In implementation of Law No. 179/2017 (so-called 'Whistleblowing law'), Italferr has equipped itself with an IT platform that allows reports to be sent anonymously even. The platform constitutes a preferred tool for sending and managing reports, as it is better suited to protect the confidentiality of the reporter's identity and ensure adequate information security measures.

THROUGH THE PLATFORM THE WHISTLEBLOWER CAN:

Submit a report

Change or update a previously sent report

Consult the status of a report you have sent in

Receive feedback on verification outcomes where the reporter has provided his or her identity.

THE PLATFORM ALLOWS THE COMPANY TO:

Separate the identifying data of the reporter from the content of the report by providing for the adoption of codes replacing the identifying data so that the report can be processed anonymously

Keep the contents of the report confidential throughout the entire report handling phase, allowing access only to authorised individuals

Adopt secure protocols for data transport over the network as well as the use of encryption tools for the content of the report and any attached documentation

Interact with the reporter, ensuring his or her anonymity.

ALTERNATIVELY, REPORTS CAN BE SUBMITTED VERBALLY, BY MEANS OF A STATEMENT MADE BY THE REPORTER AT A SPECIAL HEARING, TO ITALFERR'S ETHICS COMMITTEE/SUPERVISORY BODY, RECORDED IN THE MINUTES AND SIGNED BY THE REPORTER, OR THROUGH THE FOLLOWING CHANNELS:

ORDINARY MAIL

Italferr SpA / Segreteria Comitato Etico o Segreteria Organismo di Vigilanza, via Vito Giuseppe Galati, 71 - 00155 Roma