The AGCM’s initiative consists of a detailed and updated presentation of its experience in the field of compliance programmes as well as its 2018 Guidelines on antitrust compliance. The possibility of considering compliance programmes as a mitigating factor in the determination of the level of sanction was introduced by the 2014 sanctions guidelines of the AGCM. In October 2018, the AGCM adopted its Guidelines on antitrust compliance to provide undertakings with guidance on how to structure an effective antitrust compliance programme and its treatment in the context of the investigation. According to this Guidelines, the adoption and effective implementation of a specific compliance programme can lead to a reward in the form of a reduction of fines of up to 15%.