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25 January 2016

Women on corporate boards and company performance

Edited by People Management Competence Centre & Lab “The world is looking to Norway”, this is what an Italian newspapers announced in 2011 (La Repubblica, 2011). Indeed, Norway was the first country to introduce a law regulating gender balance on corporate boards. Ambitions about achieving gender balance in the upper echelons of Norwegian companies had existed for a long time. “However, any advances in increasing the number of women on corporate boards had little visible effects. In 1992, only 4 percent of the members of boards in corporations listed on the Oslo Stock Exchange were women, and in 2002 this figure had increased to only 6 percent despite efforts made” (Machold, Huse, Hansen, and Brogi, 2013 p. 1). This was the background for the Norwegian law on gender balance in corporate boards, and in 2008 about 40 percent of the board members in Norwegian publicly traded companies were women. The snowball starting in Norway is growing, and the effects seem to be accelerating, leading one country after another to follow the Norwegian example (Machold, Huse, Hansen, and Brogi, 2013). The most important lesson to be learnt from Norway is that even in a country where a gender-balance attention is well established, it was necessary to introduce a law in order to make significant increases in the number of women on boards. In Italy, the turning point came with the introduction of the Law 120/2011, the so called Golfo-Mosca Law (from the name of the promoters). The Law requires that boards (executives and non-executives) of publicly-listed companies and state-owned companies have at least 33% of female by 2015 and sets a target of 20% for the transition period. Four years after the law, the question we ask is this: does the increasing number of women on corporate boards improve organizational performance? According to several studies carried out by research institutes and consulting firms, most HR managers and HR professionals believe that having a good gender balance on boards conveys several key benefits to the organization, such as bringing different perspectives to decision-making, reflecting the wider diversity in society, etc. (see Figure 1). Fig. 1: CIPD Report 2015 Moreover, according to CEB SHL Talent Report 2013, the difference in the leadership potential of women and men is less than 1% in favour of women. This means that the pool of female potential leaders is not smaller as compared to the male pool. However, more than 60 percent of leadership positions are filled by men (Figure 2). Fig. 2: Leadership Potential – broken down by gender - Source: CEB - The 2012 Talent Report The effects of diversity (age, gender, cultural, ethnical)  on individual, group, and organisational performance have been widely investigated also in management literature and evidences are highly interesting. Some scholars solicited a reflection on potential negative effects of diversity in terms of conflict worsening, poor communication, and a reduction of group cohesion. On the other side, some scholars showed how diversity may increase creativity, innovation, decision making and, hence, performance. A recent study produced at St. Gallen University on a large sample of banks showed a positive and strong relation between gender diversity and perfomance, over 15 years. According to Reinert et al. (2015) women's contribution to firm's performance appears to be particularly valuable in times of crisis: they found that a 10% increase in the number of women in top management positions produced an increase on ROE greater than 3% per year, and this impact doubled in the years of severe crisis. There is another important study, published in 2012, which helps in understanding the rational of this positive relationship (Dezső & Ross, 2012). According to the results of this research carried out on 1,500 companies over a period of 15 years, the presence of female top managers increases the performance of (both top and middle) management, and by this means also firm's performance. Women, indeed, thanks to their different life experiences, contribute to management team with additional insights on some strategic issues, and in particular those on female business partners, customers, employees. More generally, heterogeneous groups benefit from different views, consider a wider set of possible solutions, debate the views of others with greater force, thus leading to higher quality decisions, especially when (as for decisions by top management teams) the task requires to analyze and process lots of information. It is true that diversity can also reduce social cohesion, engender conflicts, and reduced comfort within the group, but not necessarily this may result in a lower performance; on the contrary, it may generate better decisions, especially when they are "non-routine decisions", as in the case of Board ones. In those cases, benefits from gender diversity seem to outweigh its costs. Moreover, according to this study, the positive impact of women in the Top Management Team is not limited to the performance of the team but is extended to other levels of the organization. At some stages of career progression, in fact, mentoring relationships and other supportive relationships can be very important; since these social relations are strongly influenced by the similarity on certain social factors such as gender, the scarcity of women in top management can become a barrier to career opportunities for women. On the contrary, women in positions of senior management seem to be more sensitive than their men colleagues to growth of their employees, encouraging them to express their full potential. Therefore a woman should strongly believe that the presence of other women colleagues in senior management roles can increase her real career opportunities; this condition can positively affect motivation and commitment of women at all organizational levels. Finally, the results of this research show that the benefits of gender diversity in top management team are visible only in certain contexts, namely in those tasks that require creative solutions, such as in innovative processes based on the recombination of unique resources and competences. As a consequence the women presence on boards would be particularly important in those companies where innovation represents a key component of the strategy and, then, of managerial behaviours (Figure 3). Fig. 3 - Source : Dezső & Ross, 2012 According to these considerations, perhaps there isn’t a single answer to the question that we asked ourselves, as more and more evidences lead us to believe that the impact of diversity on performance depends on some contextual factors such as organizational culture and strategy, and HRM practices adopted (Figure 4). For example, the impact of diversity on performance will be positive when managers and their collaborators, are able to rely on the creativity and wealth of information; when they are coached, through cultural awareness and adequate HRM practices to deal with the complexity related to taking decisions or communicate in a very heterogeneous team. If this is true, then we have to accept – in a managerial perspective - the fact that gender diversity creates value if there are some contextual factors, that are able to take out its potential. And since diversity is a feature of the labor market and a social value, then companies have to gear up to create an inclusive organizational culture, and develop the skills needed to generate value from diversity. Figure 4: Diversity effects on performance Source: Kochan et al. 2003 Surely, having set percentages of women participation on Boards represents a key step, since it helps in creating an open and supportive culture, triggering a cascade effect that, over time, will ingender benefits on all organizational levels. Four years after the introduction of law on installments to women participation on Boards data shows that even in Italy, the effect has been high and the number of women on Boards has significantly increased (Fig. 5). However to generate a real impact, top management must ensure a visible commitment. Moreover, as it is true that "you can not manage what you do not measure," it is extremely important to adopt a more analytical approach on this issue and collect and analyze corporate data, monitor gender profile, and ensure greater transparency on these data. Finally, it is important to adopt policies to support gender diversity in the recruitment and selection process, in the design of career and in the adoption of work-life balance initiatives. Fig.5: Women on Corporate Boards (%) – Source: Credit Suisse, 2014 References Burke Eugene et al. "Big Data Insight e Analisi della forza lavoro globale", The SHL Talent Report, 2014. CIPD, "Gender diversity in the boardroom: Reach for the top", Survey Report, Feb. 2015. Dezsö, Cristian L., and David Gaddis Ross. "Does female representation in top management improve firm performance? A panel data investigation." Strategic Management Journal9 (2012): 1072-1089. Kochan, Thomas, et al. "The effects of diversity on business performance: Report of the diversity research network." Human Resource Management1 (2003): 3-21. Machold, Silke, et al., (eds). "Getting women on to corporate boards: A snowball starting in Norway". Edward Elgar Publishing, 2013. Reinert, Regina M. et al. "Does female management influence firm performance? Evidence from Luxembourg banks", Working Papers on Finance n. 2015/1, Swiss Institute of Banking and Finance (S/BF – HSG), Jan. 2015. 25 January 2016

14 January 2016

The managerial perspective of the wellness industry

The 10th edition of the Executive Wellness Management course will start on January 21, 2016. It is a training project which aims to provide the skills and develop the conceptual tools to deal with the wellness services during their life cycle with an economic and managerial perspective. Potential participants are those who engage or intend to engage in management positions at health clubs, beauty centers, rehabilitation centers, medical spa, and fitness facilities of the same type placed in hotels, resorts, companies and healthcare organizations. To respond to the evolution of the industry, these figures require to: combine strong managerial skills in the areas of enterprise management (organization, strategy, administration and accounting), with industry-specific knowledge (technical aspects, market dynamics, characteristics of different sectors of wellness and related services, facilities, products) and with knowledge of "medical" aspects of wellness (prevention and maintenance of health status). act according to the logic of effectiveness and efficiency, to meet the growing demand of the market; manage in a unified way specialized but complementary segments, to satisfy an integrated demand (beauty, relaxation, fitness, healthcare); develop as a critical success factor, a gradual shift from a purely quantitative to a qualitative offer. The training model is based on maintaining a constant relationship between participants and the world of practice through a network of partnerships with excellent organizations and a faculty composed of outstanding personalities, professionals and academics. The course is held in Italian. DOWNLOAD BROCHURE For further information: tel. 06.85.222.302/314 email: sanita@luiss.it

12 January 2016

Invest your talent in Italy – opportunity for prospective students

LUISS University, along with 21 other Italian universities is a partner of the Invest your talent in Italy program, which offers in its a.y. 2016/2017 edition a unique opportunity to students coming from Azerbaijan, Colombia, Egypt, Ethiopia, Ghana, Indonesia, Kazakhstan, Mexico, Turkey and Vietnam to literally invest their talent in Italy, developing their skills through a range of Master’s and Post-Graduate courses, entirely taught in English, in prestigious Italian Universities. The program aims at focusing both on the academic and the professional development of students, combining lectures with a practical on-the-job training in an Italian Company. Furthermore, students will have the chance to attend Italian Language courses and to participate to cultural activities offered by the University. Once selected, students will access to all the facilities envisaged by the program, such as scholarships, fee reductions and exemptions, welcome and support service from their arrival to the end of their academic career. The Invest your talent in Italy program is supported by the Italian Ministry of Foreign Affairs and International Cooperation, and the Italian Trade Agency - ICE, Uni – Italia, Unioncamere and Confindustria. To see the list of Master’s Degree courses and Post-Graduate programs offered by LUISS University and LUISS Business School included in the Program, please click here. APPLY NOW Application deadline: April 30, 2016 For further information, please write to welcomedesk@luiss.it.

08 January 2016

MBA Social Impact, a challenge to create a change.

The business world today has an undeniable social impact, that generates both risks and opportunities for companies. Finding business solutions that could foster shared values is a challenge for the new generation of managers whose responsibility goes beyond the economic activity to reach a social perspective. The main challenges that future managers will tackle are resilience and responsibilities, their goal is to make wealth into shared values. Together with no profit organizations and social enterprises, the Full-time MBA and Part-time MBA provide the Social Impact course: a series of activities, competitions, and exposure to real cases and contexts where students will face challenges to be solved using their creativity, and the skills acquired during the master. The Social Impact course is intended to provide students with cultural knowledge and social awareness that contributes to making  a bright, significant and sustainable change for society, mostly those who live difficult situations in different aspects. Through the collaboration of social entrepreneurs and NGOs, students will be involved  in competitions to develop knowledge, skills, and attitudes to engage, lead, and innovate in a global context, with advanced understanding of social issues key and the ability to create change. The aim of this course is to raise awareness among students about the two-fold role they play in society: by combining creativity and good will, students can generate both economic and social value. In the next days, the MBA students will face the first challenge in collaboration with Energia per i Diritti Umani (Energy for the Human Rights Association), a blind competition aiming at having a clear social impact. The results of the challenges will be directly applied to the real context by the organization involved. Results will be reported to the MBA students later in the year. The learning objectives of the challenges are forging the MBA students’ capability to take decisions in teams and under pressure, and making them experience the feeling that a future manager’s actions can be –and should be- linked to the most important social issues faced by our societies. Watch the gallery     8 January 2016

22 December 2015

Project Risk Management: a cultural approach

(By Paolo Cecchini, PMP, PMI-RMP, PMO Leader, Project Management Specialist, Risk Manager) 24/11/2015 Business Continuity & Crisis Management "Find your project's risks before they find you" Introduction Waking up and preparing your coffee this morning you took a risk. Going at work by car, by bike or on foot you took a risk. If you decided to put your money on a bank account or use it to invest in stocks you took a risk. If you decided to spend your weekend gambling, you took a risk. Risk is always present in every activity, especially when decision is required. Embracing the correct risk management strategy is definitely useful in everyday life, but becomes fundamental in project management where, to guarantee project success, it is necessary to implement a transition from reactive risk management to proactive, predictive risk management. History Risk as such is very well known since ancient times, but its structured management started after the big changes in numbering systems, the understanding of statistical principles behind probability and the increase in popularity of gambling and betting. But it was only during the Renaissance that a "scientific" management of statistical concepts applied to gambling started to appear. Although the Arabic numbering system, featuring digits worldwide used nowadays, has been introduced in Europe in between 1000 and 1200 A.C., making possible calculations beyond simple sums and subtractions, we had to wait the Renaissance for the digits 0-9 to completely replace the roman numerals. Actually the first probabilistic study on gambling (cards, dices, betting) dates back to Renaissance, from Girolamo Cardano, an italian mathematician, philosopher and doctor. A well-structured analysis of risk management started after the second world war, evolving towards the current structure after 1955 and improving from 1970 up to now both in financial and operational environment. A risk management culture The foundation of an effective risk management is the existence in the organization (all levels) of the related culture. The message spread by this culture is that risk management is part of everyday life for all the members of the organization. In other words the goal of the risk culture is to create a well-defined environment where both managers and professionals are always looking for risks and related responses in order to use previous experience for effective decision making. There are several obstacles moving against risk culture creation, first of all the risk management costs. Among them: very short timeframes; lack of confidence in risk management processes; fear of negative interpretation of risk identification process. Almost always the common root cause of the issues listed above is the lack of understanding, by top level management, of the benefits that an effective risk management policy could bring to the company. This is also the reason why it is difficult to get well dimensioned resources for risk management; in case of limited resources availability risk management activities are the first to be canceled (almost always). It is then vital for the project manager or the risk manager the creation of a project environment where all the main stakeholders are completely aware of the importance and effectiveness of proper risk management. There are several actions that can be implemented to reach this goal. Among them: get consensus and support from top level management; enroll an expert risk management professional; provide specific risk management education; put in place a well performing risk management communication policy; use the right risk management tools; create a risk management knowledge base and use it for future projects. Risk definition and description From the project point of view the most common definition of risk is the one adopted by the Project Management Institute: "Project risk is an uncertain event or condition that, if it occurs, has a positive or negative effect on one or more project objectives such as scope, schedule, cost, or quality" It is important to underline the fact, almost always ignored at least in our Mediterranean culture, that with the word "risk" we can refer to positive (opportunities) or negative (threats) events. It is therefore important, during the risk identification phase, to identify both threats and opportunities and to handle them in the proper way. In a well structured risk management process, every identified risk is defined using a risk metalanguage including at least the following: cause event effect Beside the risk definition with the metalanguage, the two most important parameters to define a risk (positive or negative) are the probability of the event and the impact on one or more project objectives. As we'll see later on when talking about quantitative risk analysis, it is common habit to assign a symbolic value to the risk multiplying its probability by its impact. Risk Management process Effective risk management must be supported by a rigorous and well defined process. Main goal of risk management is to minimize threats probability and impact and to maximize opportunities probability and impact. The Project Management Institute defines for project risk management a structure composed by six separate processes: Plan Risk Management Identify Risks Perform Qualitative Risk Analysis Perform Quantitative Risk Analysis Plan Risk Responses Control Risks As a general guideline every process is characterized by a well defined list of input data (Inputs), a set of tools and techniques to process input data and a well defined list of output data (Outputs) composed by the results of process computation that can be Inputs to other risk management processes at the same time. The entire set of risk management processes is repeated during the whole project life cycle as performing activities to deliver project outcomes can generate new risks. Project risk originates from the uncertainty naturally included in all projects; two risk macro categories can be defined: known risks: the ones that have been previously identified, analyzed and provided with response actions in order to mitigate their probability and impact (or to enhance them in the case of opportunities); unknown risks: the ones that can't be identified (unpredictable) and therefore can't be proactively managed but you can only react if and when they occur. It is also worthwhile to define a few concepts that enhance risk definition and characterization inside organizations and among stakeholders: risk attitude: the level of risk that organizations or stakeholders are willing to accept and how they approach it; risk appetite: degree of uncertainty an entity is willing to take on in anticipation of a reward (PMBoK 5th Edition); risk tolerance: the degree, amount or volume of risk that an organization or individual will withstand (PMBoK 5th Edition); risk threshold: measures along the level of uncertainty or the level of impact at which a stakeholder may have a specific interest. Below that risk threshold the organization will accept the risk, above that risk threshold the organization will not tolerate the risk (PMBoK 5th Edition). As already said before, effectiveness of risk management process is guaranteed only if the entire organization shows complete acknowledgment and acceptance for this activity. Plan Risk Management This process defines how risk management activities will be performed; it also ensures that resources involved in risk management are well balanced with relevance of the project for the organization. A well-defined and detailed planning of risk management activities will result in a huge increase of success probability. At the end of the process a Risk Management Plan document will be released. Identify Risks This process drives the identification of risks that could have an impact on one or more project objectives, depicting all risks characteristics. Tasks included in this process will supposedly allow the project team to know in advance events that could affect project objectives, making possible the implementation of a proactive management. The result of the process is the first draft of the risk register, a document containing all relevant information on identified risk that will be progressively updated with results from subsequent risk management processes. Perform Qualitative Risk Analysis This process, by mean of qualitative analysis of probability and impact of all identified risks, provides a prioritized list of them with the aim to reduce the project uncertainty level and to focus the team on high priority risks. Using qualitative analysis techniques mainly based on high level estimation of probability and impact (not numerical evaluation but with definitions like high-medium-low) the process provides as output an update of the risk register with new relevant information. Perform Quantitative Risk Analysis This process, by means of numerical and statistical techniques, allows the in depth evaluation of the overall project risk. Moreover it provides an important evaluation tool for decision makers. Tools and techniques used for this kind of analysis are quite complex and therefore expensive; that's the reason why even if obtained results allow predicting the future of the project (in terms of profitability) with a very high confidence factor, they are used only for high priority risks. Plan Risk Responses This process, using results from previous analysis, defines and plans a set of risk response actions aimed to decrease probability and/or impact of negative risks (threats) and to increase probability and/or impact of positive risks (opportunities). It is very important to clarify that despite the name "response actions", these actions are not performed when the risk happens, but before the risk can happen in order to modify risk probability and/or impact for the benefit of the project. Risk responses are defined according to the different risk response strategies: negative risks (threats): Avoid: avoidance is simply avoiding the risk; can be accomplished in many different ways and generally happens early in the project when any change will result in fewer impacts; Transfer: transference is a response strategy where risk and its ownership is transferred to a third party; the risk doesn’t disappear (it is just moved). Transference nearly always involves payment of a risk premium to the third party being in charge to handle the risk; Mitigate: Mitigation is a strategy aimed to reduce the probability and/or impact of an identified risk; mitigation is done before the risk happens, cost and time for mitigation has to be lower than cost and time involved repairing the damage caused by the risk. The risk may still happen but hopefully impact will be very low; Accept: Acceptance is a strategy that simply accepts the risk because no other action is feasible; passive acceptance requires no action, the project team deals with the risks as they happen. Active acceptance involves developing a contingency plan should the risk occur. positive risks (opportunities): Exploit: This strategy may be selected for opportunities where the organization wishes to ensure that the opportunity is realized; it tries to eliminate the uncertainty associated with the opportunity ensuring it will happen; Enhance: This strategy is used to increase the probability and/or positive impacts of an opportunity; it tries to identify and maximize key drivers of these impacts as this may increase the probability for the opportunity to happen; Share: this strategy involves allocating some ownership of the opportunity to a third party best able to pursue the opportunity itself; Accept: this strategy accepts the opportunity in order to gain advantage from it but without actively pursuing it. Control Risks This process takes care of previously defined response plans implementation, identified risks tracking and monitoring, residual and secondary risks monitoring, new risks identification and risk management efficiency evaluation. This process also ensures that the risk management process is performed iteratively during the entire project life cycle. Project Risk Management in Ericsson Project management culture is so strongly embedded in our company that we have defined our own project management methodology (hugely based on Project Management Institute guidelines), globally adopted. As a consequence the project risk management has a very high relevance in our business process, also due to the fact that all our solutions are delivered as projects and therefore their success is fundamental for company health. Inside our project management methodology the risk management process has a very high priority, so high that specific actions have been put in place to optimize and enhance it. Actions span from dedicated training to existing process audit to existing tools verification to new tools adoption analysis. Great emphasis is put on risk management process introduction since the very early stages of offer negotiation with the customer, with the aim to increase risk identification effectiveness and enhance response plan development in order to get better project results, with benefits for the customer and the provider as well. Conclusions What has been described above is just a scratch on the surface of a complex and fascinating discipline highly relevant for any kind of task. In the needs of shortness I haven't analyzed for instance stakeholder communication issues that dealing with risks have very high priority and are quite complex. I hope this short introduction triggered your interest for this discipline and conveyed the message that we have access to more sophisticated tools to increase predictability than the crystal ball. Business Continuity & Crisis Management

21 December 2015

“Delta ti – In real time”, the exhibition organised by the students of LUISS Master of Art.

The students of the fifth edition of the LUISS Master of Art, under the guidance of Achille Bonito Oliva, presented, as a curatorial collective, the exhibit “Delta ti – In tempo reale” (Delta ti -  In real time), at the Carlo Bilotti Museum. The choice of the title, Delta ti, derives from the physics formula that expresses the concept of time laps and means to synthesize the contemporary condition in which reality rapidly chances and everything is concentrated in a single moment, a suspended moment, in real time. A path punctuated by the 18 art works of contemporary artists coming from different backgrounds, generations and poetics: sculpture, photography, video, fixtures, performances and audio interventions shape the aesthetic research and critic between art and life. The artists that took part to the exhibit, with their works or performances, are: Elisabetta Benassi, Mircea Cantor , Gianni Politi, Claire Fontaine, Giorgio Andreotta Calò, Fabio Mauri, Emiliano Maggi, HH Lim, Cesare Pietroiusti, Rà Di Martino, Franco Vaccari, Matteo Nasini, Ileana Florescu , Leonardo Petrucci, Andrea Lanini, Baldo Diodato, Piero Golia , Pablo Mesa Capella. The exhibit will be open to the public from December 17, 2015 to January 17, 2016. Contacts: progettomostra@luiss.it lma@luiss.it Info Exhibition: Carlo Bilotti Museum – Aranciera di Villa Borghese Viale Fiorello La Guardia, 00197 - Rome (Italy) Tel. (+39) 060608 Free entrance Orari: Tuesday – Friday 10.00 – 16.00; Saturday and Sunday 10.00 – 19.00; 24 e 31 December  10.00 – 14.00; 25 December, 31 January. Closed on Monday.

14 December 2015

Closed the First Successfull Edition of the Course on how to Improve and Explout the Sport Facilities - LUISS Business School and CONI

On the last November, 23, 24 and 25 the first edition of the Course "Stadiums and sports facilities: the new frontiers of real estate" hold by LUISS Business School together with CONI. The attenders were all the stakeholders involved: football clubs, sport associations, real estate asset management companies, investment companies, law firms, entrepreneurs and professionals. The sports sector suffers a gap due to the lack of facilities compliant with security and sustainability. The law 147/2013 tries to enhance the sports facilities with economic sustainability. In this changing scenario, the Course was the opportunity to learn new skills and to discuss the most relevant issues. In considerazione del grande successo dell’iniziativa e dell’alto livello delle competenze coinvolte, LUISS Business School e CONI sono già al lavoro per realizzare la nuova edizione in programma nel 2016. L’obiettivo degli organizzatori è che questa iniziativa possa divenire il punto di riferimento per tutti coloro che intendano approcciare con competenza e professionalità questo importante e sempre più rilevante opportunità di business. Becasue of the successs, LUISS Business School and CONI have already started to work at the second edition to be scheduled in 2016. The mission is to become a benchmark for all those who wish to approach with competence and professionalism this important business opportunities.

14 December 2015

The compliance: reflections to go beyond appearance

Alessandro Addotti - MACOM LUISS Business School Co-Director - Partner at Law Firm Addotti&Associates The definition of compliance requires a systematic approach with regard to the organizational way. Compliance must be pervasive in every business environment. The “worst case scenario” as source of costs of not-compliance can be a useful guideline about the advantages of compliance. Compliance consists of rules and applicable laws. However, the definition limits the full organizational commitment which is what compliance means. It isn’t necessary to tick the box in order to define compliance, since it should be a part of the mission and the values of a company, and a potential source of competitive advantage, not simply a budget item. The previous inputs define the arena where compliance operates: in particular, in the Italian legislation, L. 231, AML, corporate governance (mainly in regulated sectors) and safety in the workplace are all rules related to compliance. Compliance also means tax or antitrust issues, as well as the standard of business conduct. Last but not least, the ownership of compliance: it is not enough for a job profile to assure a real best practice in compliance. It should be concrete, operational and measurable. An organizational chart or a system of delegated powers are good practices, but they are not enough. Compliance efforts should aim at integrated compliance (the role of EHS Officer vs Compliance Officer or the relationship between Legal and Compliance) with KPIs in order to measure its performance. With this regard, the relationship between compliance and internal audit is essential: a culture of compliance requires the awareness and the knowledge of the main topics and issues above mentioned. Finally, with regard to the cost of compliance, the most relevant benchmark could be the cost of the not-applied compliance. Although the advantages of compliance are hard to measure, the failure to comply would easily be measured in legal terms.

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