The activities required to create this program, which began in March ■ Interviews with senior staff previously identified by TIM; ■ Checking of documents contained on the personal computers of a specific number of managers previously selected in order to perform an objective collection of such documents; ■ Antitrust training (81 senior managers); ■ The writing and adopting of an Antitrust Code of Conduct; ■ The writing and adopting of an internal procedure aimed at implementing the compliance program in line with corporate procedures.