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This document outlines the updated Internal Dealing Procedure for LU-VE S.p.A., aimed at identifying Relevant Persons and Significant Transactions that need to be disclosed in compliance with EU market abuse regulations and Italian law.
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How to fill out internal dealing procedure

01
Begin with the proper heading: 'Internal Dealing Procedure'.
02
Include the date of the procedure's implementation.
03
Define the purpose of the internal dealing procedure.
04
List the parties involved in the internal dealings.
05
Outline the process for initiating an internal deal, including required documentation.
06
Specify the approval steps needed for the internal dealings.
07
Detail the confidentiality requirements related to internal dealings.
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Provide instructions for documenting the internal dealing process.
09
Outline the review process post-deal completion.
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Include contact information for queries regarding the procedure.

Who needs internal dealing procedure?

01
Employees involved in financial transactions.
02
Legal and compliance teams to ensure adherence to regulations.
03
Management for oversight and approval of internal dealings.
04
Internal auditors for monitoring and reviewing transactions.
05
Human resources for training and awareness activities.
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The internal dealing procedure refers to the set of guidelines and processes that govern the buying or selling of securities by insiders of a company to ensure transparency and compliance with legal regulations.
Persons deemed insiders, such as company executives, directors, and other key employees who have access to unpublished price-sensitive information about the company, are typically required to file the internal dealing procedure.
To fill out the internal dealing procedure, insiders must complete the required forms detailing their transactions, including the type of security, number of shares involved, transaction date, and any other relevant details mandated by regulatory bodies.
The purpose of the internal dealing procedure is to prevent insider trading, promote market integrity, and ensure that all investors have equal access to material information.
The information that must be reported includes the insider's name, position, type of transaction, number of shares bought or sold, transaction date, and any other specific details required by the regulatory authority.
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