Whistleblowing Management Guidelines

Italo S.p.A. protects the values established in its Code of Ethics, mainly regarding correct internal and external relationships, transparency towards all parties concerned and responsibility towards the community.

The Company pays particular attention to complying with laws, rules and regulations and considers this commitment as the main condition for belonging to the Company.

In this context, Italo makes available to all those who - in any way - have relations with the Company, all the necessary channels to report on potential violations regarding the Organisation, Management and Control Model ex Legislative Decree 231/01, laws, rules and regulations.  

A “Report” is defined as any news regarding suspicious behaviours or alleged illegal conduct and/or attitudes that may cause damages and/or detriment to Italo and its reputation, especially for what concerns:

• alleged breaches, requests or incentives to breach external laws and regulations provisions, the Company Code of Ethics and Organisation, Management and Control Model ex Legislative Decree 231/01 and/or Internal procedures;
• alleged findings, irregularities, conduct, acts or omissions that harm the public interest and/or the integrity of the public administration and/or private entities;
• significant unlawful behaviours pursuant to Legislative Decree 231/01.

Reports shall be submitted in good faith, fully aware that Italo shall guarantee confidentiality on Whistleblowers’ identity and the content of the report, as well as protect the informant from any retaliation and/or discriminatory act for reasons connected - directly or indirectly - to the Report.

Italo’s “Whistleblowing Management Guidelines” define the process of receiving, analysing and processing Reports and establish a Whistleblowing Committee to oversee the whole process. The Committee is composed by the Head of Internal Audit & Risk Management, the Head of Human Resources & Organization and the Head of Legal Affairs & Compliance. In order to favour the sending of Reports, Italo has implemented a dedicated IT platform (https://whistleblowing.italospa.it/) to guarantee confidentiality and to protect the identity of the Whistleblower and the Reported person by means of secure protocols and ad-hoc cryptography tools.

It is also possible to submit a Report by sending a letter to the Company headquarters: Italo Via Casilina 1 - 00182 Rome, to the attention of the Whistleblowing Committee in the person of the Head of Internal Audit and Risk Management Function.

Moreover, oral Reports are accepted only if submitted through a direct meeting with the Whistleblowing Committee or one of its members.

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