Internal dealing

Within the procedures for the management and transmission of information relating to the Company, on March 24, 2006 the Board of Directors adopted the Code of Conduct for Internal Dealing matters (“Internal Dealing Code”), and on 28 July 2017 updated it.

The Code is meant to regulate the information flows relevant to transactions on shares issued by the Company or other connected financial instruments and conducted, even by proxy, by people responsible for management, control or direction, and people “closely associated” with them (as defined by Article 19 of Regulation (EU) No 596/2014). Moreover, are also included the transactions carried out by people with a share of at least 10% of the share capital or

 entities controlling the Company, called “Relevant Persons”, as well as by people closely associated with them (pursuant to Article 152-sexies of Consob Regulation No. 11971/1999).

In accordance with art. 19 of Regulation (EU) No. 596/2014, the Internal Dealing Code has also indicated a so-called “Blocking periods”, namely a closure period of 30 calendar days prior to the date set for the announcement of a financial reporting, during which the people responsible for management, control or direction are expressly forbidden to carry out transactions on their own account or on the account of third parties, directly or indirectly, relating to shares or debt instruments, or derivatives or related financial instruments.

Internal Dealing Notice

This section includes all the notices relevant to the transactions subjected to the Internal Dealing rules and carried pursuant ex art. 19 of Regulation (EU) No. 596/2014 by people responsible for management, control or direction, and people closely associated with them. Moreover, are also included the transactions carried out by people with a share of at least 10% of the share capital or entities controlling the Company, called “Relevant Persons”, as well as by people closely associated with them (pursuant to Article 152-sexies of Consob Regulation No. 11971/1999).

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