CODE OF ETHICS

Of COIPA Italia S.p.A & Group Ventura

Introduction

This Code of Ethics establishes the principles of conduct and guidelines to be followed by all employees, executives, collaborators, suppliers, and partners of [Company Name] (hereinafter “the Company”). Our commitment is to provide safe, reliable, and sustainable railway services, in compliance with the highest ethical and legal standards.

1. INTEGRITY AND HONESTY

All members of the Company are required to behave with integrity, honesty, and transparency in all professional activities. Every decision, action, and interaction must be guided by fairness and loyalty, both toward colleagues, clients, suppliers, and regulatory authorities.

• Obligation of Transparency: Every transaction and decision must be documented correctly and transparently.
• Absence of Corruption and Conflicts of Interest: Employees must not accept or offer bribes, gifts, or undue advantages that could compromise the integrity of their work. Conflicts of interest must be avoided in all professional activities.

2. SAFETY AND QUALITY

The safety of passengers, employees, and assets is our top priority. Every action and decision must aim to guarantee the highest level of safety and quality in our railway services.

• Operational Safety: Employees must strictly follow all safety regulations and operating procedures. Any risks must be promptly reported to prevent accidents.
• Control and Maintenance: It is essential that all vehicles, infrastructure, and systems are kept in perfect condition. Regular maintenance must be performed with the utmost attention.

3. ENVIRONMENTAL RESPONSIBILITY AND SUSTAINABILITY

The Company is committed to reducing the environmental impact of its operations. Every activity must comply with environmental regulations, adopting sustainable technologies and practices.

• Minimizing Environmental Impact: We promote the use of ecological and renewable technologies to reduce greenhouse gas emissions and pollution.
• Recycling and Waste Management: Employees must follow responsible waste management practices, promoting recycling and reducing waste.

4. HUMAN RESOURCES AND DIVERSITY

The Company promotes an inclusive, fair, and respectful work environment. Every employee must be treated with dignity, respect, and impartiality.

• Non-Discrimination: The Company does not tolerate any form of discrimination, including but not limited to race, gender, age, religion, sexual orientation, or disability.
• Training and Development: We offer continuous training opportunities to allow our employees to grow professionally and acquire new skills.
• Safety and Well-being: We ensure a safe and healthy work environment, free from harassment and abuse of any kind.

5. LEGAL COMPLIANCE AND REGULATORY COMPLIANCE

All employees must comply with local, national, and international laws and regulations regarding railway transport, safety, environment, and labor law.

• Compliance with Laws: All activities must be conducted in full compliance with applicable laws. Employees are required to act in accordance with all regulations, including those related to railway safety and data protection.
• Anti-Corruption and Anti-Fraud Policies: The Company adopts a zero-tolerance policy toward corruption and fraudulent practices. Employees must avoid any activity that could damage the Company’s reputation.

6. RELATIONSHIPS WITH CLIENTS AND SUPPLIERS

The Company is committed to maintaining transparent, fair, and respectful relationships with clients, suppliers, and all external stakeholders.

• Service Reliability and Quality: We provide high-quality railway services, adhering to schedules and offering a safe and pleasant travel experience.
• Transparency in Contracts and Transactions: All contracts with suppliers and clients must be written clearly and fairly, without hidden or deceptive clauses.
• Ethics in Supplier Relations: We select our suppliers based on criteria of quality, ethics, and sustainability.

7. DATA PROTECTION AND PRIVACY

The protection of personal and sensitive information of clients, employees, and partners is of fundamental importance to the Company.

• Respect for Privacy: All personal data must be handled with the utmost confidentiality and in compliance with privacy laws.
• Data Security: Employees must follow strict cybersecurity protocols to protect company and client information.

8. REPORTING ILLEGAL ACTIVITIES AND WHISTLEBLOWER PROTECTION

The Company encourages reporting illegal activities or unethical behavior. It is our responsibility to ensure that whistleblowers are protected from retaliation or discrimination.

• Reporting Channels: The Company provides secure and confidential channels for reporting. Every report will be treated with the utmost seriousness and investigated promptly.
• Protection from Retaliation: We guarantee that employees who report misconduct or irregularities in good faith will not face any form of retaliation.

Conclusion

This Code of Ethics reflects our values and our commitment to operate responsibly, safely, and ethically. Every employee and collaborator is required to respect these principles, contributing to our goal of being a leader in the railway industry with a positive impact on society and the environment.