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This document outlines the procedure for fulfilling internal dealing obligations as stipulated by European and Italian regulations, including the identification of relevant persons and significant transactions that must be disclosed to regulatory bodies and the public. It includes definitions, responsibilities, and mechanisms for reporting significant transactions to ensure compliance with applicable market abuse regulations.

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Begin by gathering all necessary internal documents and forms related to the dealing procedure.

02

Identify the stakeholders involved in the internal dealing process.

03

Clearly outline the purpose of the dealing and the expected outcomes.

04

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Assign roles and responsibilities for each stakeholder in the process.

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Complete each section of the internal dealing form, providing accurate and detailed information.

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Submit the filled-out internal dealing form to the designated authority for approval.

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Follow up on the submitted procedure to ensure timely processing.

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Keep a copy of the submitted documents for future reference.

Who needs internal dealing procedure?

01

Employees involved in trades and transactions within the organization.

02

Management who oversees compliance and regulatory adherence.

03

Compliance officers responsible for monitoring internal dealings.

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HR departments for any employee with trading responsibilities.

05

Any party who is impacted by the outcomes of internal dealings.

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What is internal dealing procedure?

The internal dealing procedure is a set of guidelines and regulations that govern the reporting and management of transactions involving securities or other financial instruments by individuals within an organization, particularly those with access to confidential or material non-public information.

Who is required to file internal dealing procedure?

Individuals who are classified as insiders, including directors, officers, and employees who have access to non-public information about a company, are generally required to file internal dealing procedures.

How to fill out internal dealing procedure?

To fill out the internal dealing procedure, individuals must provide details such as their identity, the nature of the transaction, the securities involved, the date of the transaction, and any relevant amounts. Forms may vary by jurisdiction but usually require accurate and truthful disclosures.

What is the purpose of internal dealing procedure?

The purpose of the internal dealing procedure is to promote transparency and integrity in financial markets, to prevent insider trading, and to ensure that all market participants have access to the same information.

What information must be reported on internal dealing procedure?

Information that must be reported typically includes the insider's details, nature of the transaction, type of security, transaction date, number of shares traded, and the price at which the transaction occurred.

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