Internal dealing

CIR has adopted Consob regulations on Internal Dealing, implementing a specific Code of Conduct aimed at regulating transactions carried out by relevant persons on financial instruments issued by the company.

The Code of Conduct, approved by CIR’s Board of Directors, establishes:

• methods of communication and transparency of transactions subject to mandatory public notification;
• rules of conduct to be followed, including during blackout periods (prohibition of transactions before the release of financial results);
• sanctions in case of non-compliance, also based on applicable legal provisions.

The Code defines insiders or relevant persons as individuals who, due to their role, have access to inside information and are therefore required to comply with the obligations under Internal Dealing.
In particular, relevant persons include:

• the members of CIR’s Board of Directors;
• the standing members of CIR’s Board of Statutory Auditors;
• the General Manager and the Officer in charge of preparing the company’s accounting documents.

The purpose of the Code is to ensure transparency and fairness in dealings with the market, preventing behaviors that may create information asymmetries or undermine investor confidence.