Whether (a) the relevant illegal activity is listed in the
Legislative Decree no. 231/2001 (the “Decree”) as
predicate offense, (b) DAO is incorporated as one of the
entities to which the Decree applies, and (c) the offenses
are committed by DAO’s associates in its interest or to its
benefit and it has not adopted and effectively
implemented compliance programs suitable to prevent
the commission of such offense, then the DAO could be
held responsible for the sole ground of commission of
such offenses.
