In order to avoid businesses from incurring administrative liability, Legislative Decree No. 231/2001 established an advanced organisational tool aimed at imprinting corporate activities in the direction of legal corporate sustainability. In this setting, “Model 231” now serves a clear corrective purpose. The administrative procedure serves as an undeniable forum for evaluating self-cleaning measures, which are founded on the idea of adversarial debate between the parties. This prompts a consideration on the discipline's approach for analysing the subjective conditions for participation in public tenders.