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”), to regulate the information flows relevant to transactions
identified by Consob concerning the shares issued by the Company or other, connected financial
instruments (the so-called relevant transactions) and conducted, even by proxy, by the "relevant
persons" of the Company or persons "closely related" to the latter, as defined by Art. 152-
sexies of the Issuers’ Regulation.
“Significant individuals” of the Company are the members of the Board of Directors and the
Board of Auditors.
The
Internal Dealing Code has also indicated certain so-called “
Blocking periods” during which the relevant persons are expressly forbidden from carrying
out relevant transactions.
Such “
Blocking Periods” are:
• the 15 days preceding the approval by the Board of Directors of the draft Financial
Statements, the half-yearly report and the quarterly reports, up to the moment that the press
release concerning the resolutions adopted by the Board is disclosed to the market;
• any other periods in which the Board, or in case of urgency the Chairperson of the same and/or
the Managing Director, even separately, decide to ban or restrict the Relevant
Transactions.