Internal Dealing

In terms of procedures relating to the prevention of the illicit “Market Abuse” activity, the Company has adopted a Code of Conduct relating to internal dealing. This aims, in particular, to regulate the notification and communication of information in accordance with laws and regulations, relating to the transactions concerning financial issued by Rai Way, or other financial instruments linked to them, carried out by “relevant individuals” (so called “insiders”) or by subjects closely associated with them.

The Internal Dealing Code regulates duties of information and modalities of conduct that must be observed and respected in order to ensure total informational transparency on the market relating to financial operations carried by:

• members of the Board of Directors;
• members of the Board of Statutory Auditors;
• managers qualified as managers with strategic responsibility.
  

The Code also applies to persons/entities “closely associated” with relevant individuals, such as close family members or controlled companies.