The regulation of insider trading underwent a radical change as of 1 April 2006, when European Union rules on market abuse were adopted in Italy and Consob, the stock-market regulator, approved a new set of regulations.
Once its shares were publicly traded, Banca Generali adopted a procedure governing significant transactions involving Banca Generali shares (or related financial instruments) worth at least 20,000.00 euros during a calendar year and carried out by people holding key positions in the company or by their close relatives.
The code defines as insiders (relevant persons) all directors and statutory auditors of the bank, anyone with managerial responsibility within the company, the external auditors and anyone closely associated with these people.
It classifies significant transactions as the purchase, sale, subscription, exchange or barter of Banca Generali stock or related securities.
The following are excluded from the definition of significant transactions:
those worth no more than 20,000.00 euros per calendar year
those with no monetary value (gifts, legacies, free stock grants, subscription rights) as well as the exercising of rights deriving from stock-option plans (although any subsequent sale falls within the scope of these rules)
those carried out between an insider and someone closely associated with them
those carried out by the company and its subsidiaries
Black out periods
Relevant persons are forbidden from carrying out transactions regarding Banca Generali stock or related securities in the following periods:
during the 30 days preceding Banca Generali board meetings called to approve annual or semi-annual financial results
during the 15 days preceding Banca Generali board meetings called to approve quarterly financial results (as of 31 March and 30 September)
The board can also decide to impose further periods during which insiders are forbidden or limited in their transactions.