On 5 May 2014, the Board also approved the Internal Dealing procedures (aimed at clarifying the disclosure requirements to CONSOB and to the public) related to transactions involving financial instruments issued by the Company or its subsidiaries and ‘‘relevant entities’’. 


With the entry into force of Regulation (EU) no. 596/2014 of 16 April 2014 ("Market Abuse Regulation" or "MAR"), the Company has updated the Procedure in accordance with the provisions of art. 19 of the abovementioned MAR, by the Delegated Regulation (EU) 2016/522 of 17 December 2015 (the "EU Delegation Regulation"), its implementing provisions and, more generally, regulations, including the regulatory level in force on Communication of transactions carried out by relevant persons and persons closely related to them, as described in the procedure.


A mandatory abstention is imposed on the ‘‘relevant persons’’. These entities may not carry out transactions subject to the Internal Dealing regulations during the blackout periods, lasting 30 days, before the approval of the draft financial statements, the interim financial report, each interim management and business plan, by the Board of Directors. The dates of these meetings are reported in the financial calendar published on the website of the Company. 

This prohibition does not apply to the purchase of shares made in the exercise of rights granted under stock option and stock grant plans, subject to the obligation not to proceed with their sale during the periods indicated.