Ferrotramviaria S.p.A. follows the aim of basing every process of its business managing on the values of efficiency, propriety and integrity. Therefore, Ferrotramviaria S.p.A. established to adapt its managing and supervision governance model to the regulations of the Legislative Decree n° 231/2001. In particular, this choice aims:

• to guarantee the Company’s integrity, strengthening the internal control system;

• to improve the efficacy and directness in business managing; To make sure of fulfilment of Decree’s obligations;

• to make aware every person who works with Ferrotramviaria S.p.A. of its directness and propriety values.

In fact, for the first time in our national legal order, the Legislative Decree n° 231/2001 introduced the concept of “administrative responsibility” of an associative authority (company, authority with juridical personality, association of businesses, organization), for crimes committed or attempted by:a natural person occupying a top management position (representative, administration, direction of the authority or anyone who has managing and control functions); an employee, in order to advantage the same authority.

The administrative responsibility of a company is independent from the legal responsibility of the natural person who has committed the crime, and they join together. It’s allowed a specific form of relieve from that kind of responsibility if the company proves to have efficiently adopted and applied some models of governance and management, apt to prevent crimes with a certain knowledge.

An additional element is the foundation of an internal board with the task of supervising on functioning and observance of such models and, moreover, on their upgrading (Supervisory Board).Warnings and notices upon the correct functioning of the governance model can be sent to the following e-mail address, whose addressees are the members of Ferrotramviaria S.p.A.’s Supervisory Board: odv@ferrovienordbarese.it The main constitutive elements of the governance model are represented by the following documents:

GENERAL PART
ETHICAL CODE