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Translation from the Italian which remains the definitive version LUXOTTICA GROUP S.P.A. INTERNAL DEALING PROCEDURE 1. INTRODUCTION This procedure is intended to: (i) define the obligations set out
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How to fill out internal dealing procedure

How to fill out internal dealing procedure
01
Step 1: Familiarize yourself with the company's internal dealing policy and guidelines.
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Step 2: Gather all relevant information and documents regarding the transaction or dealing that needs to be reported.
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Step 3: Complete the internal dealing form provided by the company.
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Step 4: Provide accurate and detailed information about the nature of the transaction, parties involved, and any potential conflicts of interest.
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Step 5: Attach any supporting documents, such as contracts or agreements, as required by the internal dealing procedure.
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Step 6: Submit the filled-out form and supporting documents to the designated department or individual responsible for internal dealing reporting.
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Step 7: Follow up on any additional requirements or clarifications requested by the internal dealing compliance team.
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Step 8: Maintain records of all internal dealing transactions for future reference or audits.
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Step 9: Periodically review and update the internal dealing procedure to ensure compliance with regulatory changes or internal policy updates.
Who needs internal dealing procedure?
01
Companies listed on stock exchanges
02
Financial institutions
03
Employees and officers with access to non-public information
04
Companies with significant shareholders or directors
05
Companies regulated by securities laws
06
Companies with a Code of Conduct or ethical guidelines
07
Organizations with complex financial transactions
08
Companies operating in industries with high potential for conflicts of interest
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What is internal dealing procedure?
Internal dealing procedure is a set of rules and regulations that govern the buying and selling of securities by individuals within a company.
Who is required to file internal dealing procedure?
Employees and insiders who have access to confidential information and are involved in trading securities are required to file internal dealing procedure.
How to fill out internal dealing procedure?
Employees must disclose their transactions in securities, including the type of security, the date of the transaction, and the amount of the transaction.
What is the purpose of internal dealing procedure?
The purpose of internal dealing procedure is to prevent insider trading and ensure transparency in securities transactions within a company.
What information must be reported on internal dealing procedure?
Information such as the type of security, the date of the transaction, the amount of the transaction, and any additional information required by the company.
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