These tools are the following: the Organizational and Management Model adopted in Italy, that allows for the administrative liability of companies for crimes committed by their senior executives or subordinates in the interest or to the benefit of the companies to be eliminated; the Internal Fraud policy aimed at discouraging and waylaying all types of fraudolent conduct as may be implemented by staff members to the detriment of the Group; and the soon to be issued Group Anti-money Laundering aimed at preventing the companies from becoming involved in money laundering.