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This document outlines the regulations and procedures regarding insider trading, handling privileged information, and the obligations of internal dealing persons within Gruppo Editoriale L'Espresso
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How to fill out Code of Conduct for Internal Dealing

01
Obtain the Code of Conduct template for Internal Dealing from your organization's compliance department.
02
Read the document thoroughly to understand its purpose and requirements.
03
Fill in your personal details, including your name, position, and department at the top of the document.
04
Review the organization's policies related to internal dealings and ensure you are familiar with them.
05
Answer any specific questions or sections in the document about your internal dealings.
06
Provide examples of past internal dealings if required, ensuring confidentiality and compliance with privacy policies.
07
Sign and date the document to validate your agreement to the Code of Conduct.
08
Submit the completed document to the designated compliance officer or department.

Who needs Code of Conduct for Internal Dealing?

01
All employees who are involved in decision-making processes that could influence or impact the organization, including management and staff in finance, legal, or operations.
02
Executives and board members who have access to confidential information and may engage in internal dealings.
03
Any employee who trades or recommends trading in the organization’s securities based on non-public information.
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The Code of Conduct for Internal Dealing is a set of guidelines aimed at ensuring that individuals who have access to non-public, price-sensitive information about a company do not misuse that information while trading in the company's securities.
Individuals with access to confidential information, such as directors, executives, employees, and any associated persons of a company, are typically required to adhere to and file reports under the Code of Conduct for Internal Dealing.
To fill out the Code of Conduct for Internal Dealing, individuals need to provide information regarding any securities transactions, detailing the nature of the transaction, the date it occurred, the number of securities involved, and any relevant relationship to the company.
The purpose of the Code of Conduct for Internal Dealing is to promote transparency and integrity in the trading of securities, mitigate the risk of insider trading, and ensure compliance with applicable laws and regulations.
The information that must be reported includes details of the transaction, such as the securities bought or sold, the transaction date, the amount involved, the price at which the transaction was conducted, and the identity of the person reporting.
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