Governance

INTERNAL DEALING

The Company has adopted internal Rules of Procedure for the management of confidential and relevant information, as well as for the management and public disclosure of privileged information, with the aim of respecting the confidentiality requirements provided for in legal provisions, monitor access to, and circulation of, information that is or could become privileged information, and ensure public disclosure of such information according to the criteria of transparency, timeliness and non-selectivity, in accordance with relevant laws and regulations in force.

The Company has also adopted a Procedure for keeping and updating an Insider Register – i.e. the register of persons who, on account of their occupational or professional activity, or functions performed on behalf of the Company, have access on a permanent or occasional basis to insider information on the Company - and to the Relevant Information Register (RIL Register) – i.e. the register of persons who, on account of their occupational or professional activity or functions performed on behalf of the Company, have access to items of information that may, in the near future or at a later stage, become privileged information.