Carraro S.p.A. INSIDER DEALING

Transcription

1 CODE OF CONDUCT on INSIDER DEALING Approved by resolution of the Board of Directors of 20 December 2002 Updated: 13 December 2016

2 CONTENTS 1. Introduction page 3 2. Purpose of the Code of Conduct page 3 3. Definition of Relevant Person and Person Closely Associated page 3 4. Person receiving, managing and disclosing information page 5 5. Significant Transactions and obligations of Relevant Persons page 6 6. Obligations of the Company page 9 7. Responsibilities and sanctions page Adoption of the Code and its publication page 10 ANNEXES: - Annex A Template 1: Notice to send to Relevant Persons. Template 2: Statement declaring that the Code has been read and accepted. Template 3: Appointment for the purposes of Disclosure to Consob pursuant to article 6.2 of the Code. - Annex B Privacy note - Annex C Template for notification and public disclosure of Significant Transactions (article 152-octies of the Issuer Regulation). 2

3 1. Introduction This Code of Conduct (hereinafter the Code ) regulates insider dealing for Carraro S.p.A. (the Company ), and has been written in compliance with article 19 of Regulation (EU) No 596/2014 of 16 April 2014 on market abuse ("Market Abuse Regulation" or MAR ), Commission Implementing Regulation (EU) 2016/523 of 10 March 2016, as well as, insofar as applicable, articles 114, paragraph 7 of Italian Legislative Decree no. 58 of 24 February 1998 ( TUF - Consolidated Finance Act ) and article 152-sexies and subsequent of the Regulation adopted by Consob with Resolution no of 14 May 1999 as amended (the Issuer Regulation ). Following the entry into force of MAR, the applicable regulatory framework in Italy will be amended accordingly; the Code may therefore be further amended. 2. Purpose of the Code of Conduct The Code is issued by the Board of Directors of the Company to regulate information flows about certain transactions on financial instruments issued by the Company, conducted by "Relevant Persons" and by "Persons Closely Associated" with them (as defined below), as well as the obligations of said persons and the Company concerning the disclosure of the aforesaid transactions to the market and to Consob. This Code does not relieve "Relevant Persons" of the obligation to comply with applicable laws or regulations, including for example, the provisions of article 180 and subsequent of Italian Legislative Degree no. 58/98 on insider trading and market manipulation (market rigging), and comply with the "Procedure for the internal management and disclosure of confidential information, with particular reference to inside information" approved by the Board of Directors of the Company on 13 December Definition of Relevant Person and Person Closely Associated 3.1 For the purposes of this Code, the term Relevant Persons, means: 3

4 I. the directors, regular auditors and general managers of the Company; II. senior managers who have regular access to inside information and power to take managerial decisions affecting the future developments and business prospects of the Company; III. members of boards of directors and of supervisory boards as well as persons with managerial functions in a company controlled directly or indirectly by the Company, if the book value of the investment in the aforesaid subsidiary accounts for more than 50% of the Company's assets as resulting from the last approved financial statements; IV. any person holding an investment, calculated pursuant to article 118 of Consob Ruling no of 14 May 1999, equal to at least 10% the share capital of the Company CARRARO S.p.A. comprising shares with voting rights, as well as any other entity that controls the Company CARRARO S.p.A. 3.2 For the purposes of this Code, the term Person Closely Associated with a Relevant Person means: I. the spouse (or a partner considered to be equivalent to a spouse) not legally separated, dependent children, even of the spouse and, if sharing the same household for at least one year, parents, relatives and relatives by marriage of relevant persons; II. III. legal persons, trusts or partnerships, in which the managerial responsibilities are discharged by a Relevant Person or by one of the persons indicated in point 3.2.I, acting alone or jointly; legal entities, controlled directly or indirectly by a relevant person or by one of the persons indicated in point 3.2 I; IV. companies of persons with economic interests that are substantially equivalent to those of a relevant person or of one of the persons indicated in point 3.2 I; V. trusts set up for the benefit of a relevant person or for one of the persons indicated in point 3.2 I. 4

5 3.3 Obligation for Relevant Persons to notify the Company and Closely Associated Persons. Each Relevant Person shall notify: - the Company, in writing, of the list of Closely Associated Persons, using the template in Annex A Template 2; - Closely Associated Persons, in writing, of their obligations in accordance with this Code and retain a copy of the notification. 4. Person receiving, managing and disclosing information 4.1 Reporting Officer. The Administration, Finance and Control Officer (CFO) is the officer ("Reporting Officer") appointed to receive, manage and disclose information on Significant Transactions - as defined below - notified by the persons indicated in sections 3.1 and 3.2 to the market (and in the case indicated in article 6.2). 4.2 Obligations of the Reporting Officer. The Reporting Officer, also through a person appointed from the Company's Legal Department, shall: a) Prepare and update a List of Relevant Persons and, as indicated by said persons, a List of Persons Closely Associated with them; b) Oversee information to be given to Relevant Persons concerning the disclosure obligations of this Code, through the notification as of Annex A Template 1 and Annex B; c) Obtain a written statement from Relevant Persons, based on the template in Annex A Template 2, in which they sign: a statement declaring they are aware their name has been included in the list of Relevant Persons; a statement declaring they are aware of and accept the contents of the Code; 5

6 an undertaking to notify Persons Closely Associated with them in writing of their obligations to notify Significant Transactions - as defined below - and to ensure that Persons Closely Associated do everything necessary to ensure that these obligations pursuant to article 1381 of the Italian Civil Code are strictly met; a statement identifying the Persons Closely Associated with them; d) Monitor the adoption of the Code and report to the Board of Directors on the advisability of updates and/or additions to the Code in order to bring it in line with applicable regulations as well as the most advanced national and international standards on conduct; e) Report to the Board of Statutory Auditors, the Board of Directors and the Supervisory Board on any infringements of the Code he identifies or becomes aware of in carrying out his duties; f) Meet his obligations as indicated in article 6 of the Code. 4.3 Exemption from liability. The Reporting Officer is not liable in any case for infringements of and/or delays in meeting the disclosure obligations of Relevant Persons and/or the Company vis-à-vis Consob and/or the market, if said infringements or delays result from a failure to disclose information or the incomplete, incorrect or delayed disclosure by Relevant Persons which infringes the provisions of this Code or established by law. 5. Significant Transactions and obligations of Relevant Persons 5.1 Scope of transactions. For the purposes of this Code, are taken into consideration those transaction which are conducted for any reason by Relevant Persons and Persons Closely Associated with them, concerning: a) shares issued by the Company; b) financial instruments connected to shares issued by the Company, meaning: 6

7 b.1) financial instruments that enable shares issued by the Company to be underwritten, purchased or sold; b.2) financial debt instruments convertible into shares issued by the Company or that may be exchanged with them; b.3) financial derivatives of shares issued by the Company referred to by Italian Legislative Decree no. 58 of 24 February 1998, article 1, paragraph 3; b.4) financial instruments equivalent to shares, representing these shares; b.5) the listed shares issued by subsidiaries of the listed issuer and related financial instruments as of letters b.1) to b.4); b.6) unlisted shares issued by subsidiaries of the Company, when the book value of the investment in the subsidiary accounts for more than 50% of the Company's assets, as resulting from the last approved financial statements, as well as related financial instruments as of letters b.1) to b.4). 5.2 Definition of Significant Transaction. Relevant Persons and Persons Closely Associated with them shall notify the Company: a) about transactions as of article 5.1 which, conducted during the year, reach the threshold of five thousand euros; and b) about transactions as of article 5.1 which, conducted in the same year and regardless of their value, take place after the threshold as of the previous point has been reached; (a) and b) are collectively referred to as Significant Transactions ). The threshold of five thousand euros is calculated by adding, without offsetting, all Significant Transactions conducted for each Relevant Person and the transactions conducted for Persons Closely Associated with them. 7

8 For related financial derivatives, the amount is calculated with reference to the underlying shares. 5.3 Deadline for notifying the Company. In order for the Company to meets its disclosure obligations pursuant to the Issuer Regulation (and detailed in article 6 below of this Code), the Relevant Persons indicated in article 3.1, points I, II and III and Persons Closely Associated with them shall notify the Company of the Significant Transactions they have carried out by the second business day following the day when the Significant Transaction was conducted. The Relevant Persons indicated in article 3.1, point IV shall inform the Company of the Significant Transactions by the fifteenth trading day following the day of the Transaction. 5.4 Recipient and form of the disclosure. The disclosure shall be made in person to the Reporting Officer or by fax (fax no ) or ( address enrico_gomiero@carraro.com or to another address which is subsequently notified in writing by the Reporting Officer) using forms that conform or have an equivalent content to the Template for notification and disclosure" in Annex C (as indicated in article 7 of this Code). 5.5 Exceptions. Without prejudice to the obligation to notify Significant Transactions conducted by each Relevant Person and by each Person Closely Associated with them, the following are not notified: a) transactions of which the total amount does not reach the threshold of five thousand euros (as calculated pursuant to article 5.2) before the end of the year (31 December); b) transactions conducted between the Relevant person and Persons Closely Associated with them; c) transactions conducted by the Company with its own subsidiaries. 8

9 5.6 Blocking period. The Relevant Person may not conduct transactions on financial instruments on its own behalf or on behalf of third parties during the following periods: in the 30 (thirty) days prior to the date when the Board of Directors is convened to approve the draft Financial Statements and Interim Report of the Company - including the day when the meeting is held - that the Company is required to publish according to national law or regulations of Borsa Italiana S.p.A. in the 15 (fifteen) days prior to the date when the Board of Directors is convened to approve the results of the first and third quarter of each year of the Company, including the day when the meeting is held. The Board of Directors may, for contingent and exceptional reasons, put into effect prohibitions or limitations on transactions being conducted, in other specific periods of the year, by all or some of the Relevant Persons. 5.7 Disclosure to Consob. The Relevant Persons and Persons Closely Associated with them shall also notify Significant Transactions - personally or through the Company, according to the terms set out in paragraph 6.2 below to Consob, using a certified address 1. This disclosure shall be made using forms that are conforming or have an equivalent content to the "Template for notification and disclosure as of Annex C, before the end of the third business day following the date when the Significant Transaction was conducted. 6. Obligations of the Company 6.1 Disclosure to the market. The Company shall publish (with the procedures 1 Disclosure shall be sent to the address consob@pec.consob.it (if the sender is required to have a certified address) or by to the address protocollo@consob.it specifying Ufficio Informazione Mercati (Market Information Department) as the recipient and indicating MAR Internal Dealing in the subject line. 9

10 indicated in applicable regulations) information on Significant Transactions received from Relevant Persons, according to the forms and times established in articles 5.3 and 5.4, by the end of the third business day following the date when the Significant Transaction was conducted and at the same time send it to the authorised storage system. A copy of market disclosure will then be published on the Company's website (in the section on Corporate Governance). 6.2 Disclosure by the Company to Consob. The Company shall also send, within deadlines established by law (i.e. by the end of the third business day following the date of the Transaction), on behalf of Relevant Persons and Persons Closely Associated with them, notification to Consob as of article 5.6 provided that: - Significant Transactions have been notified to the Company according to the forms and times established by articles 5.3 and 5.4; and - the Company has received specific authorisation conforming to the module in Annex A Template Responsibilities and sanctions Failure to meet obligations and comply with the prohibitions in this Code shall, in the case of repeated, unjustified infringements: - by employees, result in the disciplinary sanctions of applicable laws and the collective bargaining agreement being taken; - by any other staff, result in the relationship of employment being terminated, also without notice; - by Directors and Auditors, result in the Board of Directors proposing, at a subsequent board meeting, that the defaulting Director or Auditor is removed from office. 8. Adoption of the Code, its publication and amendments 8.1 Adoption and publication of the Code. This Code is made known to 10

11 Relevant Persons or is expressly accepted by said and is published on the website in the section on Corporate Governance. 8.2 Amendments. Substantial amendments to this procedure are overseen by the Board of Directors of Carraro S.p.A. Instead, the Chairman, Deputy Chairman and Chief Executive Officer of Carraro S.p.A. may also make formal amendments, provided that the substance of the content does not change. 11

12 Allegato A / ANNEX A Template 1 Notification to send to Relevant Persons Dear Please note that your name has been included, as from the date of this notice, in the list of Relevant Persons pursuant to the of Carraro S.p.A. attached herein (the Code ). As regards operating aspects of being included in the list, please see the contents of the Code and regulations referred to in it. Please also note that insider trading and market manipulation are offences liable to criminal and administrative sanctions pursuant to applicable national regulations. Please confirm receipt of the Code, signing and sending the attached statement declaring you have read and accepted it. Best regards Campdoarsego, The Reporting Officer of Carraro S.p.A.

13 Allegato A / ANNEX A Template 2 Statement declaring that the Code has been read and accepted The undersigned Resident in In a capacity as - having acknowledged that he/she has been included in the list of "Relevant Persons" pursuant to article 3.1 of the of Carraro S.p.A. (hereinafter the Code ); - aware of the moral undertaking, as well as his/her legal obligations established by applicable laws and regulations (of which a copy has been provided) and by the Code; - having acknowledged the sanctions in the event of failure to meet obligations arising from the Code and from applicable laws and regulations that he/she declares he/she is aware of; - aware that Carraro S.p.A., is willing to undertake mandatory disclosure, in the name and on behalf of persons concerned, to the Supervisory Authorities and to the market, according to the limits and conditions established by the Code (articles 6.1 and 6.2), subject to compliance with the terms as of article 5.3 of the Code; HEREBY DECLARES - he/she has received a copy of the Code and has read and accepts it; - he/she will undertake to notify Persons Closely Associated with him/her of their obligations pursuant to applicable regulations and the Code and will keep a copy of said. In this regard, the following are Persons Closely Associated (as defined according to art. 3.2 of the Code): Name and surname/com pany name (*) Place and date of birth/company address(*) Tax code Type of connection

14 (*) For legal entities. - to undertake, with the utmost diligence, to strictly observe the provisions in this Code (and - pursuant to article 1381 of the Italian Civil Code - ensure that Persons Closely Associated strictly observe the disclosure obligations of applicable regulations and the Code) and forward notices to: CARRARO S.p.A. Direttore Amministrazione, Finanza e Controllo Via Olmo Campodarsego (PD) Fax enrico_gomiero@carraro.com (signature)

15 Allegato A / ANNEX A Template 3 Appointment for the purposes of disclosure to Consob The undersigned Resident in In a capacity as - having acknowledged that he/she has been included in the list of "Relevant Persons" pursuant to article 3.1 of the of Carraro S.p.A. (hereinafter the Code ); - aware that Carraro S.p.A., is willing to undertake mandatory disclosure, in the name and on behalf of persons concerned, to the Supervisory Authorities and to the market, according to the limits and conditions established by the Code (articles 6.1 and 6.2), subject to compliance with the terms as of article 5.3 of the Code; HEREBY DECLARES - that he/she appoints Carraro S.p.A. as of article 6.2 of the Code, to act on his/her behalf and on behalf of Persons Closely Associated with him/her and on the express authorisation of the latter, according to the conditions and terms of the Code, to disclose Significant Transactions conducted by him/her and by Persons Closely Associated with him/her to Consob ("Appointment"); - to undertake to notify Carraro S.p.A. of each Significant Transaction (as defined by article 5.2 of the Code), conducted by him/her or on his/her behalf and/or by Persons Closely Associated with him/her or on their behalf, by the second business day following the date when the transaction was conducted, by compiling and sending to the Reporting Officer, as defined by the Code, the template as of Annex A of the Code. - The appointment is valid from the date when this notice is received by Carraro until withdrawal by the undersigned or by Carraro, to be notified in writing at least 5 (five) business days before the date that withdrawal comes into effect. - Carraro may also consider this Appointment as terminated with immediate effect, without any need for notification, if the undersigned fails to comply with the conditions and procedures for sending the notification required as of the Code. (signature)

16 Allegato B / ANNEX B Privacy notice Pursuant to article 13 of Italian Legislative Decree no. 196/2003 Data Protection Act, Salini Impregilo S.p.A. (hereinafter the "Company"), with head offices in Via dei Missaglia, 97, Milano (Milan), in a capacity as data controller, is required to inform you of how your personal data will be used and your statutory rights. Your personal data that will be processed (e.g. data on personal information, tax data, information about financial instruments) will be used only for purposes connected with obligations established by law, regulations and EU regulations, and to meet any requirements of competent authorities. The disclosure of your personal data for the purposes indicated is mandatory in order to comply with obligations established by law, regulations, EU regulations and is also necessary as it is connected with and instrumental in establishing, continuing and correctly managing relations with the Company. Therefore, relations with the Company cannot go ahead if this data is not provided. As regards the purposes indicated, personal data will be processed using manual and automated means, suitable for guaranteeing security and confidentiality with logics that are strictly related to the purposes indicated. Please note that your personal data in relation to the purposes indicated herein may only be disclosed to banks and credit institutes, service companies, consultants, professionals and competent authorities in order to meet legal obligations. The data that you provide will be disclosed (through market disclosure and, for example, by including information, also in a summary form, in financial statements and interim and quarterly reports), within limits established by applicable laws. Moreover, data will be disclosed to office staff and third parties specifically appointed by the Data Controller, Data Processor and Persons in charge of the processing. Please also note that you may exercise your rights as of article 7 of Italian Legislative Decree no. 196/2003 such as, for example, the right to access your data, have it updated, rectified or supplemented, cancelled or object to the processing of your data on legitimate grounds, contacting the Legal and Corporate Affairs Department of the Company - Direzione Legale e Societario, Via dei Missaglia, 97, Milano (MI), where the Data Controller has its domicile.

17 ALLEGATO C / ANNEX C Modello di notifica e di comunicazione al pubblico delle operazioni effettuate da persone che esercitano funzioni di amministrazione, di controllo o di direzione e da Persone a loro Strettamente Legate (ai sensi dell articolo 152-octies Regolamento Emittenti e del Regolamento di esecuzione (UE) 2016/523) Template for notification and public disclosure of transactions by persons discharging managerial responsibilities and persons closely associated with them (pursuant to article 152-octies of the Issuer Regulation and Commission Implementing Regulation (EU) 2016/523) 1 Dati relativi alla persona che esercita funzioni di amministrazione, di controllo o di direzione/alla Persona Strettamente Legata Details of the person discharging managerial responsibilities/person closely associated a) Nome Name Per le persone fisiche: For natural persons: Name: First name: Cognome: Last name: 2 Motivo della notifica Reason for the notification a) Posizione / Qualifica Position / Status b) Notifica iniziale / Modifica Initial notification / Amendment Per le persone che esercitano funzioni di amministrazione, di controllo o di direzione: indicare la posizione (ad esempio, amministratore delegato, direttore finanziario) occupata all'interno dell'emittente, del partecipante al mercato delle quote di emissione, della piattaforma d'asta, del commissario d'asta, del sorvegliante d'asta For persons discharging managerial responsibilities: the position occupied within the issuer, emission allowances market participant/auction platform/auctioneer/auction monitor should be indicated, e.g. CEO, CFO. Pozione: Position: Indicare se si tratta di una notifica iniziale o della modifica di una precedente notifica. In caso di modifica, spiegare l'errore che viene corretto con la presente notifica Indication that this is an initial notification or an amendment to prior notifications. In case of amendment, explain the error that this notification is amending. 3 Dati relativi all'emittente, al partecipante al mercato delle quote di emissioni, alla piattaforma d'asta, al commissario d'asta o al sorvegliante d'asta Details of the issuer, emission allowance market participant, auction platform, auctioneer or auction monitor a) Nome Name Nome completo dell'entità: Full name of the entity: CARRARO b) LEI Codice identificativo del soggetto giuridico, conforme al codice LEI di cui alla norma ISO Legal Entity Identifier code in accordance with ISO LEI code F3EC59FFEC Dati relativi all'operazione: sezione da ripetere per i) ciascun tipo di strumento; ii) ciascun tipo di operazione; iii) ciascuna data; e iv) ciascun luogo in cui le operazioni sono state effettuate Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted Operazione Transaction a) Descrizione dello strumento finanziario, Tipo di strumento Codice di identificazione Description of the financial instrument, Type of instrument Identification code Indicare la natura dello strumento: un'azione, uno strumento di debito, un derivato o uno strumento finanziario legato a un'azione o a uno strumento di debito; una quota di emissione, un prodotto oggetto d'asta sulla base di quote di emissione o un derivato su quote di emissione. Indication as to the nature of the instrument: a share, a debt instrument, a derivative or a financial instrument linked to a share or a debt instrument; an emission allowance, an auction product based on an emission allowance or a derivative relating to an emission allowance. Codice di identificazione dello strumento come definito nel regolamento delegato della Commissione che integra il regolamento (UE) n. 600/2014 del Parlamento europeo e del Consiglio per quanto riguarda le norme tecniche di regolamentazione sulla segnalazione delle operazioni alle autorità competenti adottato a norma dell'articolo 26 del regolamento (UE) n. 600/2014. Instrument identification code as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities adopted under Article 26 of Regulation (EU) No 600/2014. ISIN:

18 b) Natura dell'operazione Nature of the transaction Descrizione del tipo di operazione utilizzando, se necessario, i tipi di operazioni stabiliti dall'articolo 10 del regolamento delegato (UE) 2016/522(1) della Commissione adottato a norma dell'articolo 19, paragrafo 14, del regolamento (UE) n. 596/2014 oppure uno degli esempi specifici di cui all'articolo 19, paragrafo 7, del regolamento (UE) n. 596/2014. Description of the transaction type using, where applicable, the type of transaction identified in Article 10 of the Commission Delegated Regulation (EU) 2016/522(1) adopted under Article 19(14) of Regulation (EU) No 596/2014 or a specific example set out in Article 19(7) of Regulation (EU) No 596/2014. A norma dell'articolo 19, paragrafo 6, lettera e), del regolamento (UE)n. 596/2014, indicare se l'operazione è legata all'utilizzo di programmi di opzioni su azioni Pursuant to Article 19(6)(e) of Regulation (EU) No 596/2014, it shall be indicated whether the transaction is linked to the exercise of a share option programme. c) Prezzo/i e Volume/i Price(s) and volume(s) Prezzo/i Price(s) Volume/i Volume (s) Se più operazioni della stessa natura (acquisto, vendita, assunzione e concessione in prestito ecc.) sullo stesso strumento finanziario o sulla stessa quota di emissione vengono effettuate nello stesso giorno e nello stesso luogo, indicare in questo campo i prezzi e i volumi di dette operazioni, su due colonne come illustrato sopra, inserendo tutte le righe necessarie. Utilizzare gli standard relativi ai dati per il prezzo e la quantità, comprese, se necessario, la valuta del prezzo e la valuta della quantità, secondo la definizione dal regolamento delegato della Commissione che integra il regolamento (UE) n. 600/2014 del Parlamento europeo e del Consiglio per quanto riguarda le norme tecniche di regolamentazione sulla segnalazione delle operazioni alle autorità competenti adottato a norma dell'articolo 26 del regolamento (UE) n. 600/2014. Where more than one transaction of the same nature (purchases, sales, lendings, borrows, ) on the same financial instrument or emission allowance are executed on the same day and on the same place of transaction, prices and volumes of these transactions shall be reported in this field, in a two columns form as presented above, inserting as many lines as needed. Using the data standards for price and quantity, including where applicable the price currency and the quantity currency, as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities adopted under Article 26 of Regulation (EU) No 600/2014. d) Informazioni aggregate Volume aggregato Prezzo Aggregated information Aggregated volume Price I volumi delle operazioni multiple sono aggregati quando tali operazioni: si riferiscono allo stesso strumento finanziario o alla stessa quota di emissione; sono della stessa natura; sono effettuate lo stesso giorno e sono effettuate nello stesso luogo. The volumes of multiple transactions are aggregated when these transactions: relate to the same financial instrument or emission allowance; are of the same nature; are executed on the same day; and are executed on the same place of transaction. Volume aggregato: Utilizzare gli standard relativi ai dati per la quantità, compresa, se necessaria, la valuta della quantità, secondo la definizione del regolamento delegato della Commissione che integra il regolamento (UE) n. 600/2014 del Parlamento europeo e del Consiglio per quanto riguarda le norme tecniche di regolamentazione sulla segnalazione delle operazioni alle autorità competenti adottato a norma dell'articolo 26 del regolamento (UE) n. 600/2014 Using the data standard for quantity, including where applicable the quantity currency, as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities adopted under Article 26 of Regulation (EU) No 600/2014 Informazioni sui prezzi: nel caso di un'unica operazione, il prezzo della singola operazione; nel caso in cui i volumi di operazioni multiple siano aggregati: il prezzo medio ponderato delle operazioni aggregate. Price information: In case of a single transaction, the price of the single transaction; In case the volumes of multiple transactions are aggregated: the weighted average price of the aggregated transactions. Prezzo: Utilizzare gli standard relativi ai dati per la quantità, compresa, se necessaria, la valuta della quantità, secondo la definizione del regolamento delegato della Commissione che integra il regolamento (UE) n. 600/2014 del Parlamento europeo e del Consiglio per quanto riguarda le norme tecniche di regolamentazione sulla segnalazione delle operazioni alle autorità competenti adottato a norma dell'articolo 26 del regolamento (UE) n. 600/2014. Using the data standard for price, including where applicable the price currency, as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities adopted under Article 26 of Regulation (EU) No 600/2014. e) Data dell'operazione Date Data del giorno di esecuzione From: To: of the transaction dell'operazione notificata. Date of the particular day of execution of the notified transaction. Utilizzare il formato ISO 8601: AAAA-MM-GG; ora UTC. Using the ISO 8601 date format: YYYY-MM-DD; UTC time.

19 f) Luogo dell'operazione Place of trading Nome e codice di identificazione della sede di negoziazione ai sensi della MiFID, BORSA ITALIANA S.P.A. - XMIL dell'internalizzatore sistematico o della piattaforma di negoziazione organizzata al di fuori dell'unione in cui l'operazione è stata effettuata come definiti dal regolamento delegato della Commissione che integra il regolamento (UE) n. 600/2014 del Parlamento europeo e del Consiglio per quanto riguarda le norme tecniche di regolamentazione sulla segnalazione delle operazioni alle autorità competenti adottata a norma dell'articolo 26 del regolamento (UE) n. 600/2014. Name and code to identify the MiFID trading venue, the systematic internaliser or the organised trading platform outside of the Union where the transaction was executed as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities adopted under Article 26 of Regulation (EU) No 600/2014