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Internal dealing
HT governance_internal dealing

Internal dealing

Our Internal dealing code to ensure transparency.

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.

Blocking 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.

For the purposes of insider trading rules, the following people are considered to be insiders (relevant persons):

  • members of administrative bodies (directors): Antonio Cangeri, Gian Maria Mossa, Azzurra Caltagirone, Lorenzo Caprio, Roberta Cocco, Alfredo Maria De Falco, Ilaria Romagnoli, Cristina Rustignoli e Vittorio Emanuele Terzi.
  • members of oversight bodies (statutory auditors): Natale Freddi, Mario Francesco Anaclerio, Flavia Minutillo.
  • those carrying out key managerial roles in the company (such as general managers or anyone carrying out an analogous role) and those managers with regular access to privileged information or who can influence the company's performance: Gian Maria Mossa, Andrea Ragaini and Marco Bernardi
  • the external auditors
  • members of administrative or oversight bodies and persons carrying out key managerial roles at Banca Generali's directly or indirectly owned subsidiaries if the book value of the stake held in the subsidiary represents more than 50% of Banca Generali's assets.
  • anyone else owning at least 10% of the company's share capital.

List of individual holdings

NameCompany shares heldShares held end at end-2006Shares purchaseShares soldShares held as of today
Mossa Gian Maria Banca Generali 0 20,000 0 20,000
Bernardi Marco Banca Generali 0 2,382 0 2,382
Ragaini Andrea Banca Generali 0 6,152 0 6,152
Terzi V. Emanuele Banca Generali 0 0 0 0
Caltagirone Azzurra Banca Generali 0 0 0 0
Lapucci Massimo Banca Generali 0 1,000 0 1,000
Rustignoli Cristina Banca Generali 0 1,728 0 1,728
Our internal risk control system to ensure transparency.