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This document outlines the internal dealing procedures for Luxottica Group S.p.A., detailing the obligations, definitions, relevant parties, and information obligations regarding transactions made
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How to fill out Internal Dealing Procedure

01
Step 1: Obtain the Internal Dealing Procedure form from your compliance department.
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Step 2: Read the instructions and guidelines provided on the form carefully.
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Step 3: Fill in your personal information, including your name, position, and contact details.
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Step 4: Provide details of the transaction, including the date, type of securities involved, and the value of the transaction.
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Step 5: Indicate whether the transaction is for personal account or on behalf of another party.
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Step 6: Ensure that you disclose any potential conflicts of interest.
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Step 7: Review the completed form for accuracy and completeness.
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Step 8: Submit the form to the compliance officer for review and approval.

Who needs Internal Dealing Procedure?

01
Employees who have access to sensitive or non-public information within an organization.
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Members of the board of directors and executive management.
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Individuals involved in trading or transactions related to the company's securities.
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Any personnel required to adhere to regulations regarding insider trading.
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The Internal Dealing Procedure refers to the set of rules and regulations that govern the buying, selling, and reporting of stock or securities by individuals who have access to material non-public information about a company.
Individuals who are considered insiders, such as company directors, executives, and employees with access to confidential information, are required to file Internal Dealing Procedure reports.
To fill out the Internal Dealing Procedure, individuals must provide details regarding their transactions, including the date of the transaction, the type of security, the number of shares bought or sold, and their relationship to the company.
The purpose of the Internal Dealing Procedure is to enhance transparency and prevent insider trading by ensuring that all transactions by insiders are reported and monitored.
Information required to be reported includes the insider's name, position, the details of the transaction (date, type of transaction, quantity of securities), and the price at which the transaction occurred.
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