The program in question – which was conceived as an instrument to be adopted by all the Italian companies of the Group – consists of a “general part” (which describes, among other things, the content of legislative decree n. the objectives of the program and how it works, the duties of the internal control body responsible for supervising the functioning and observance of the program and for seeing that it is kept up to date, the flows of information, and the related penalty regime) and separate “special parts” concerning the different kinds of crimes provided for by legislative decree n. 231/2001, which the program aims to prevent.