The tool for identifying, preventing and controlling corruption risks is "Organisational Model the Board of Directors in 2003 and subsequently updated and approved in July 2017, with reference to the offences of inciting corruption between private subjects, corruption between private subjects, and unlawful intermediation and exploitation of labour – the crime of 'caporalato', that is illegal recruitment and employment at below the legal minimum wage – update to the market abuse regulations), which also refers, in application terms, to the Group's specific Anti-Corruption Policy1 adopted in December 2012.