Internal Dealing

Olidata adopted a procedure disciplining operations involving financial instruments issued by Olidata S.p.A. on the part of relevant persons and persons closely related to them (internal dealing). This procedure establishes disclosure obligations and lines of conduct that must be observed by relevant persons and Olidata S.p.A. to ensure maximum transparency in the eyes of the market.

Following assimilation by Italian law of EU Market Abuse legislation (law 62/2005), internal dealing is now disciplined by the consolidated financial intermediation acts (decree law 58/1998 and subsequent amendments), the Listed Companies Regulations promulgated by Consob (resolution 11971/1999 and subsequent amendments) to enforce said consolidated acts and by the recommendations provided in Consob Communication DEM/6027054, 28th March 2006. Olidata’s internal dealing procedure was adopted pursuant to art. 114, clause 7, decree law 58/1998 and art. 152 sexies – 152 octies of the Listed Companies Regulation.The rules in Olidata’s procedure therefore have the force of law and relevant persons and persons closely related to them are strictly bound to abide by them.