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 SpA has voluntarily established and adopted its own Anti Bribery & Corruption management system (ABC system) to prevent corruption in the "broad" sense.

This framework aims to prevent acts and behaviour, even if they do not constitute a specific type of crime, which constitute cases of deviation from internal rules and procedures and may prejudice the good performance and general interest of the Company (cases of mismanagement and malfunctioning).

The ABC system is part of the FSTechnology SpA Internal Control and Risk Management System (SCIGR) and constitutes, together with the Organisation, Management and Control Model, a central element of the Company's Single Anti-Corruption Framework, as a unique self-regulatory tool to prevent corruption.

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 SpA has adopted a process for receiving, analysing and processing reports (also anonymously) concerning FS Technology SpA submitted by third parties or FS Italian Group personnel in order to contribute to the prevention of unlawful acts, irregularities or conduct in breach of the Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001, of the Anti-bribery & Corruption Management System, of the FS Group Code of Ethics, of laws or regulations.

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”).

FSTechnology 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 FSTechnology 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.