Ethical code

Considering its history and vocation, the Ansaldo STS Group has always based its business development on the creation of safe, efficient, reliable and environmentally-friendly railway and urban rail transportation systems and solutions, placing its full focus on the people these systems and solutions serve, who live in very complicated contexts with increasingly complex lifestyles.

The code of ethics clarifies the commitments and responsibilities that should guide the company's business and activities, requiring compliance by anyone involved in any way with Ansaldo STS.

The code of ethics is available on the company's website11. It is a key element of the internal control system, and compliance with it enables Ansaldo STS and the group companies to prevent certain irregularities or illegal acts prohibited by the regulations of the various countries where Ansaldo STS operates, particularly Legislative decree no. 231/01 in Italy.

The code of ethics was formally adopted by the group companies by resolution of the respective boards of directors or equivalent management bodies. It was shared with all group personnel using the same methods as those applied by the parent Ansaldo STS.

In addition, a code of ethics control body was set up within each group company to promote the implementation of the code of ethics. A special information channel for the code of ethics was also created, and can be used to report any conduct that is inconsistent with the principles of the code of ethics by sending an email. The reports are sent and managed in accordance with a group procedure.

2014 events

In 2014, the code of ethics control body received reports of small violations of the code related to Ansaldo STS Australia as follows: a) improper use of the company credit card; b) incorrect application of the redundancy policy; c) alleged bullying and harassment. Two of these issues have been settled and the third is under negotiation. None of them highlighted the need to revise the code of ethics.

In 2014, Ansaldo STS Australia's code of ethics control body was asked to interpret the application of the code in relation to third parties' offers of gifts to employees.

Training on the code of ethics

Ansaldo STS relentlessly promotes and fosters awareness of the code of ethics and the related protocols and updates, as well as knowledge of the areas of activities in the various functions with responsibilities, hierarchical relationships, duties and training. It informs employees on the code of ethics and the related protocols first by distributing specific documentation to all employees and workers collaborating with the company in any way, and requires, when the material is delivered, that they sign a statement certifying that they have read the documentation received.

In addition, company personnel can, at any time, ask supervisors for guidance and clarifications on the content of the code of ethics, protocols and duties assigned to them. When new employees are hired and/or contracted, Ansaldo STS immediately gives them the information necessary for adequate knowledge of the code of ethics and protocols, with particular respect to those that concern them specifically.