Market Abuse procedure
On 5 September 2016, the Board of Directors of the Company, in full compliance with (EU) Regulation 596/2014 and related implementing regulations, approved the Market Abuse Procedure, which was subsequently updated in May 2017. The Market Abuse Procedure collected and coordinated, in a single document, the principles and rules intended to prevent market abuse.
On 13 December 2018, at the end of the process of verifying and updating the Market Abuse Procedure and taking into account the main topics of concern to the Company, the Board of Directors decided to break it down into three different procedures respectively dedicated to: (i) the public disclosure of inside information, (ii) management of the list of persons with access to inside information and, finally, (iii) implementation of the internal dealing obligations.
As a whole, the three procedures aim to:
• ensure adequate processing of price sensitive information relating to the company by those having access to it;
• regulate operations on shares and debt instruments issued by the company, as well as on derivatives or other related financial instruments conducted by specific individuals in senior management positions (so called, “internal dealing”);
• define operating procedures and scope of application of the ban imposed upon the individuals exercising administrative, surveillance or managerial functions in the company concerning transactions on shares, debt instruments and derivatives or other related financial instruments during pre-determined periods (so called “black out period”).
Procedure for the public disclosure of inside information
The Procedure for the public disclosure of inside information governs the management and processing of inside information as well as the procedures to be followed for the dissemination thereof, both inside and outside of the corporate context, in order to prevent the processing of inside information being carried out in an untimely and/or incomplete manner or it causing information asymmetries among the public.
The establishment, maintaining and updating of the List of persons with access to inside information are also governed with a specific Procedure.
Procedure for the fulfilment of internal dealing obligations
The Procedure for fulfilling the internal dealing obligations governs the disclosure on operations on the financial instruments of the company conducted by specific individuals in senior management positions (“relevant parties”).
In particular, it sets out the following:
• the criteria for identifying “relevant parties” and “relevant transactions” (above a certain threshold), to which the regulations in question apply;
• the disclosure obligations for “relevant parties,” “relevant shareholders,” “persons closely associated” with “relevant parties” and “relevant shareholders” and the company with respect to Consob and the public in relation to the “relevant transactions”;
• the regulations on the prohibition of carrying out “relevant transactions” in certain periods (“black-out periods”).
For more information see the specific section on internal dealing.
The three Procedures also apply to the other group companies, as part of the direction and coordination activities carried out by Italgas.
ultimo aggiornamento 01 July 2020 09:01 UTC