Internal dealing

Internal dealing procedures govern the ways in which the market is informed of financial transactions carried out by those who cover certain roles within the issuing company.

Current regulations

Regulations on internal dealing have been updated by the Market Abuse Regulation (MAR), effective as of 3 July 2016, and later integrated by Consob resolution n. 19925, effective as of 14 July 2017 and intended to implement the MAR.

The people in question

The regulations have identified:

1. as individuals concerned, all members of the Board of Directors, Standing auditors and any top manager of the company who has regular access to privileged information and holds the power to take managerial decisions, as well as all individuals closely tied to the above, the latter being defined as follows:
   1. a spouse or equivalent partner as defined by national laws, dependent children as defined by national laws, a relative that has shared the same residence for at least 1 year as of the date of the transaction in question;
   2. a legal entity, trust or partnership whose managerial responsibilities are covered by a person who carries out administrative, supervisory or managerial tasks, or by a person falling under the above section i), or again either directly or indirectly controlled by such a person, if the entity was founded for their own benefit or if its economic interests are fundamentally in line with those of the person involved;
2. all those holding a share amounting to at least 10% of the Company's share capital (Significant Shareholders), as well as any other person controlling the Company.

Disclosure requirements

Based on the regulations:

• the persons in question, not included among the Significant Shareholders, are required to communicate to the issuer all transactions involving shares and related financial tools, carried out by themselves and by people with close ties, within two working days from the date of the transaction; the listed issuer is required to communicate to Consob, according to the foreseen modalities, all information received by said persons in question, within 3 working days from the date of the transactions;
• Significant Shareholders, i.e. those holding a share that amounts to at least 10% of the Company's share capital, are required to communicate to the latter any transactions involving shares and related financial tools within the end of the fifth day of the month following the one in which said transactions were carried out; the listed issuer is required to communicate to Consob, according to the foreseen modalities, any information received from such persons within the end of the open market day following the one in which they received the information and, in any case, within the end of the fifteenth day following the one in which the transactions were carried out.

Page update on 12 October 2020