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INTERNALDEALINGPROCEDURE Edition:25June,2015InternalDealingProcedureinforcesince24March2006asmodified bytheBoardofDirectorsofBeThink, SolveExecuteS.p.A.on1July,2014and25June,2015 1 Section INTRODUCTION

How to fill out internal dealing procedure

How to fill out internal dealing procedure:

1. Begin by familiarizing yourself with the purpose and requirements of the internal dealing procedure. Review any relevant laws, regulations, or company policies that govern internal dealings.
2. Determine the key components that need to be included in the procedure, such as the definition of internal dealing, the process for obtaining approval, the criteria for reporting and disclosing internal dealings, and any subsequent consequences or penalties for non-compliance.
3. Create a clear and concise document that outlines each component of the internal dealing procedure. Use plain language and avoid unnecessary jargon to ensure clarity and understanding.
4. Include step-by-step instructions on how to complete each requirement of the procedure. For example, if approval is required, specify what information or documentation needs to be provided, who should grant the approval, and any deadlines that must be followed.
5. Incorporate a mechanism for ongoing monitoring and review of internal dealings. This may include periodic assessments, audits, or reporting processes to ensure compliance and identify any potential issues.
6. Communicate the internal dealing procedure to all relevant stakeholders, including employees, executives, and any other individuals who may be involved in internal dealings. Provide training and resources to ensure that everyone understands their roles and responsibilities.
7. Regularly update the internal dealing procedure as needed to reflect any changes in laws, regulations, or company policies. Keep the procedure accessible and easily retrievable for reference and future use.

Who needs internal dealing procedure:

1. Publicly traded companies are typically required to have an internal dealing procedure in place to prevent insider trading and other illicit practices. This includes companies listed on stock exchanges or those subject to securities regulations.
2. Financial institutions, such as banks or investment firms, also need an internal dealing procedure to ensure compliance with financial regulations and prevent conflicts of interest.
3. Any organization that handles sensitive or confidential information, such as trade secrets or client data, may also benefit from having an internal dealing procedure to regulate access and prevent unauthorized disclosures.
4. Government agencies or departments that oversee public funds or manage public assets often have internal dealing procedures to maintain transparency and accountability in financial transactions.
5. Non-profit organizations or charities may adopt an internal dealing procedure to prevent misuse or misappropriation of funds and ensure proper governance and fiduciary responsibilities are upheld.

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What is internal dealing procedure?

Internal dealing procedure is a set of rules and regulations that govern how company insiders can buy or sell shares in the company.

Who is required to file internal dealing procedure?

Company insiders such as directors, officers, and certain employees are required to file internal dealing procedure.

How to fill out internal dealing procedure?

Internal dealing procedure can be filled out by disclosing relevant information about securities transactions, including the date, nature, and details of the transaction.

What is the purpose of internal dealing procedure?

The purpose of internal dealing procedure is to promote transparency and prevent insider trading by ensuring that company insiders disclose their securities transactions.

What information must be reported on internal dealing procedure?

Information such as the date of the transaction, description of the securities, number of securities, and price must be reported on internal dealing procedure.