Giuseppe Bulgarini d’Elci and Roberta Cristaldi wrote the article “Doveri più stretti se l’azienda è pubblica” (Stricter duties if the company is state-owned) published in the Italian business newspaper il Sole24Ore. Giuseppe and Roberta analyzed decision no. 3136/15 of the Court of Cassation which affirms that in a scenario featuring the governmental nature of the function pursued by the enterprise, the personal conduct of an employee is measured against stricter criteria for the purposes of termination.