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Annalisa S.p.A. INTERNAL DEALING POLICY Arezzo (AR), July 5, 2018 (amended and supplemented on January 10, 2020) Annalisa S.p.A. Via Madame Curie n. 7, 52100 Arezzo (AR) Tax and VAT No.: 01163300518CONTENTS
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How to fill out internal dealing policy

01
Understand the purpose and scope of the internal dealing policy.
02
Determine the key individuals who will be involved in the process such as management, compliance officers, and legal advisors.
03
Establish the procedures for obtaining pre-clearance for trading in company securities.
04
Clearly outline the restrictions and prohibitions on trading based on insider information.
05
Implement reporting requirements for transactions in company securities.
06
Provide regular training and updates on the internal dealing policy to all relevant employees.
07
Monitor and enforce compliance with the policy through regular audits and reviews.

Who needs internal dealing policy?

01
All employees who have access to material non-public information about the company.
02
Management and executives who make decisions that could impact the company's stock price.
03
Board members and directors who have a fiduciary duty to act in the best interests of shareholders.
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Internal dealing policy is a set of rules and regulations that govern trading activities by individuals within a company.
Employees, directors, and other insiders who are involved in trading securities of the company are required to file internal dealing policy.
Internal dealing policy can be filled out by providing information about the individual's trading activities, including details of securities bought or sold, dates of transactions, and any relevant disclosures.
The purpose of internal dealing policy is to prevent insider trading and ensure transparency in trading activities within the company.
Information such as details of securities transactions, dates of transactions, and any disclosures related to the transactions must be reported on internal dealing policy.
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