The procedure regarding Internal Dealing governs the methods for notifying the market of financial transactions carried out by persons holding specific offices in the issuer company.

Current regulations
Starting from 2006, the regulations on Internal Dealing entered into force, governed by article 114 of the Consolidated Finance Act and articles 152-sexies, 152-septies and 152-octies of the Regulation implementing Legislative Decree no. 58 of 24 February 1998, concerning the regulation of issuers(adopted by Consob by resolution 11971 of 14 May 1999) and subsequent amendments.

Disclosure obligations
Based on the regulations:

• relevant persons are required to notify CONSOB and the issuer of transaction involving shares and linked financial instruments concluded directly and by persons closely associated with them no later than five trading days after the execution date;
• listed issuers must publicly disclose the information received from the relevant person, according to the methods envisaged, no later than the end of the trading day following that of its receipt.

Relevant persons
The regulations identify the following as relevant persons: the members of the Board of Directors, Standing Auditors and shareholders that hold an equity investment of at least 10% of the share capital, as well as the persons closely associated with relevant persons, who are intended as:

1. spouses, unless legally separated, dependent children, including those of the spouse and, if they have cohabitated for at least one year, parents, relatives and kin of the relevant persons
2. legal persons, partnerships and trusts in which a relevant person or one of the persons referred to in subparagraph (i) is solely or jointly responsible for management
3. legal persons controlled directly or indirectly by a relevant person or one of the persons referred to in subparagraph (i)
4. partnerships whose economic interests are substantially equivalent to those of a relevant person or one of the persons indicated in subparagraph (i)
5. trusts set up in favour of a relevant person or one of the persons referred to in subparagraph (i)

Page updated 22 August 2011