The contents of the project derive from the gap analysis of the current situation in comparison to the contents of the guidelines, and can be summarized into the following courses of action: ■ Integrate the compliance program, focusing the Code of Conduct more on the specific cases subject to the new ongoing procedures and submitting it for the approval of the Board of Directors of the company; ■ Place greater emphasis on, and offer further information about, the Compliance Program and the Code of Conduct, both inside and outside the Company with specific communication initiatives (e.g. its publication on the Group’s corporate website, adequate media visibility); ■ Further involve top management of the Company as “testimonials” who reiterate compliance with the program; ■ Carry out periodic checks on the implementation of the program itself, using methods yet to be defined; ■ Starting now, plan further training sessions, including those focused on the alleged offenses; Additional envisaged actions: definition of a structured method of assessing and identifying antitrust risks and adopting the related controls.