In 231/2001 and the SEA Model was structured as follows: ■ refresher sessions on the Decree, Organization and Management Model, anti-corruption measures and whistleblowing for Executives on January 18 and 29, 2019; ■ training on the Decree, Organization and Management Model, anti-corruption measures and whistleblowing by two Directors of the Supervisory Board for two newly-appointed SEA Executives; ■ information/training brochures for all employees (excluding Executives) on Model 231/2001, anti-corruption measures and whistleblowing, distributed via the company intranet with a “read and sign” notification.