Internal Dealing

In terms of procedures relating to the prevention of the illicit “Market Abuse” activity, the company has employed 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 financial operations of Rai Way, or other financial tools related to it, carried out by “relevant individuals” (or “insiders”) and by those closely associated with it.

The Internal Dealing Code regulates IT obligations and conducts that must be observed and respected in order to ensure total informational transparency on the market relating to financial operations carried out by individuals with access to sensitive information on the company.

The Internal Dealing Code applies to:

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

The Code applies also to all those “closely associated” with relevant individuals, whether through marriage and/or family.

Regulatory obligations relating to internal dealing can also be applied to shareholders who possess a share equal to at least 10% of the social capital of the company, as well as every other individual who owns the company and those closely associated with them.