Market Abuse/Internal Dealing

Fincantieri’s Board of Directors since 2014 has adopted (i) a procedure for the management and disclosure to the market of corporate information and for the management of the relevant lists and (ii) an internal dealing procedure, which represent the regulatory framework that regulates the behaviors and the processes of Fincantieri, as a listed company, on market abuse.

The above procedures were subsequently updated to incorporate the innovations introduced by Regulation (EU) No. 596/2014 of the European Parliament and of the Council of 16 April 2014 (Market Abuse Regulation or MAR) and its implementing regulations, as well as by national laws, also taking into account the guidelines issued on the subject by the European Securities and Markets Authority (ESMA) and by Consob and the recommendations of the Corporate Governance Code.

The "Procedure for the management and disclosure to the market of corporate information and for the management of the relevant lists", lastly updated by the Board of Directors on October 20, 2023, defines the principles, the obligations of conduct, the roles and responsibilities inhering the proper internal management and external disclosure by Fincantieri of corporate information concerning the Company itself and its subsidiaries, with particular reference to relevant information (i.e. information that may subsequently become inside information) and inside information and it contains the provisions relating to keeping and updating the lists of people having access to relevant and inside information.

The rules and principles contained in the abovementioned procedure are aimed at ensuring compliance with the laws and regulations in force on market abuse and at ensuring the utmost discretion and confidentiality of company information in order to prevent the disclosure of information concerning Fincantieri and its subsidiaries from being made selectively, i.e. from being issued in advance to certain persons - such as shareholders, journalists or analysts - or being issued without notice, incomplete or inadequate.

The “Internal Dealing Procedure” is intended to clarify the disclosure obligations towards Consob and the public related to transactions carried out by “Relevant Persons” involving Fincantieri shares or other related financial instruments.
 
The procedure requires the disclosure of transactions carried out by “Relevant Persons” (“Relevant Subjects” and “Persons Closely Associated” with them) involving the purchase, sale, subscription, or exchange of shares and debt securities issued by Fincantieri, or derivatives or other financial instruments linked to them, exceeding a total amount of EUR 20,000 in any given year.
 
The procedure also stipulates that “Relevant Persons” are prohibited from carrying out transactions during the thirty calendar days preceding the announcement of an interim financial report or year-end financial report made public by the Company (the so-called “Blocking Period”). The dates of such meetings are listed in the corporate events calendar published on the Company’s website.