The ICC’s initiative consists in an Antitrust Compliance Toolkit. The elements in the ICC Antitrust Compliance Toolkit are not intended to represent a comprehensive or prescriptive list of what an antitrust compliance program must include, but seek to reflect what is commonly regarded as good practice in the field. Indeed, antitrust agencies themselves recognize that there can be no “one-size-fits-all” approach and that each compliance programme has to be designed to meet the specific antitrust risks faced by the company in question.

Intesa Sanpaolo’s initiative is threefold: the Antitrust Compliance Programme, the Antitrust collection (digital training products) and the internal communication tools (company magazine “Mosaico” and “Web TV” channel).