Italian compliance programmes in groups of companies

Legislative Decree 231/01 introduced corporate criminal liability into the Italian legal system: companies are exempted from the liability if they set up and implement a suitable compliance programme (called ‘Model 231’). Recent statements in the sphere of jurisprudence have drawn attention to these compliance programmes in groups of companies, although the legislation does not cover them. By means of empirical evidence this paper investigates the organisational set-ups adopted by companies within groups and the measures drawn up to implement a compliance programme. Special attention is paid to elements of differentiation that make the compliance programme ‘specific’ to each company and therefore more likely to prevent criminal offences.