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INTERNAL DEALING PROCEDURE For World Duty Free S.p.A. (approved by the Board of Directors on 20 September 2013) Table of Contents Foreword Art. 1 Relevant Persons and Persons closely connected to
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How to fill out internal dealing procedure for:

01
Start by familiarizing yourself with your company's internal dealing policy and procedure. This may include reviewing any written documents, attending training sessions, or speaking with colleagues who are knowledgeable about the process.
02
Ensure you understand the requirements and obligations outlined in the internal dealing procedure. This may include restrictions on trading certain securities, disclosure requirements, and pre-clearance procedures.
03
Determine if you are considered an "insider" according to the internal dealing procedure. Insiders typically include directors, officers, and employees who have access to material non-public information about the company.
04
If you are an insider, familiarize yourself with the specific rules and regulations that apply to insider trading in your jurisdiction. This may include legal restrictions, reporting requirements, and penalties for non-compliance.
05
Keep track of your trades and investments to ensure compliance with the internal dealing procedure. This may involve maintaining a trading log, obtaining pre-clearance for certain transactions, or reporting any changes in your holdings.
06
Regularly review and update your knowledge of the internal dealing procedure as it may change over time. Stay informed about any updates or amendments to the policy and seek clarification if you have any doubts or questions.
07
Lastly, always act ethically and responsibly when conducting any transactions or engaging in activities that fall under the scope of the internal dealing procedure. This includes avoiding any potential conflicts of interest and adhering to the highest standards of integrity.

Who needs internal dealing procedure for:

01
Companies that are publicly traded or listed on a stock exchange typically require employees, directors, and officers to follow an internal dealing procedure. This ensures compliance with insider trading laws and regulations.
02
Employees who have access to material non-public information about the company, regardless of their position or job role, may also be required to adhere to the internal dealing procedure. This helps prevent misuse of sensitive information for personal gain.
03
Directors and officers of the company, who often possess decision-making authority and access to confidential information, are expected to follow the internal dealing procedure to maintain transparency and uphold their fiduciary duties.
In summary, anyone who works for a publicly traded company, has access to material non-public information, or holds a position of authority within the organization may be required to fill out and follow the internal dealing procedure. It is crucial to understand and comply with these guidelines to ensure the integrity and transparency of financial markets.
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Internal dealing procedure is for ensuring that individuals within an organization comply with regulations regarding trading their own company's securities.
Certain individuals within an organization, such as directors and executives, are required to file internal dealing procedure.
Internal dealing procedure can be filled out by providing information on transactions involving the company's securities, such as date of transaction and amount.
The purpose of internal dealing procedure is to prevent insider trading and ensure transparency in trading activities within the organization.
Information such as details of transactions, parties involved, and any relevant disclosures must be reported on internal dealing procedure.
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