Internal Dealing

Transactions and persons subject to the internal dealing regulations2

The regulations regarding internal dealing are applicable to Poste Italiane for transactions involving the purchase, sale, subscription, and exchange of the Company's shares or related financial instruments carried out by "relevant persons". This category consists of shareholders who own at least 10% of the share capital of Poste Italiane, the Directors and the acting Statutory Auditors of Poste Italiane, as well as (as of today) additional 19 executives managers identified according to the regulations (included, together with the names of the Directors and the acting Statutory Auditors, on the attached list), given that they have regular access to privileged information and are entitled to take decisions that can affect Poste Italiane’s development and prospects.


Transactions and persons subject to the internal dealing regulations
Internal dealing transparency requirements do not apply to transactions – including those carried out by persons closely connected with the "relevant persons" – whose total value in one year is below 5,000 euro. Therefore, relevant persons shall notify transactions whose overall amount is equal or above 5,000 euro within year end.

Blocking periods
In issuing the provisions implementing the internal dealing regulations, the Board of Directors of Poste Italiane considered advisable to provide for the obligation for "relevant persons" (other than shareholders who own at least 10% of the share capital of Poste Italiane) to abstain from carrying out transactions subject to the internal-dealing regulations during four blocking periods before the approval of the financial statements, half-year financial statements and of the interim reports related to the first and third quarter by the same Board of Directors, indicated as follows:

  • in the month preceding the date scheduled for the approval of the proposed financial statements;
  • in the month preceding the date scheduled for the approval of the half-year financial statements;
  • in the fifteen days preceding the date scheduled for the approval of the interim report as of March 31;
  • in the fifteen days preceding the date scheduled for the approval of the interim report as of September 30.

This initiative of the Board of Directors was aimed to raise the Company's corporate governance standards above the regulations' standards preventing the "important persons" from carrying out transactions that the market might perceive as suspect, because they take place during periods of the year that are especially delicate for corporate information.

Transactions carried out as from the date of the listing of the Company’s shares
In accordance with Consob's recommendations, the list below includes transactions subject to the internal-dealing regulations communicated to the market by Poste Italiane and carried out as from the date of the listing of the Company’s shares (i.e. October 27, 2015) by the "relevant persons" and by the persons closely connected to them.

 

 - Transactions carried out by Shareholders who own stakes amounting to 10% or more of the capital of Poste Italiane S.p.A.

 - Transactions carried out by current Directors, Statutory Auditors and top Managers

 - Transactions carried out by ceased Directors, Statutory Auditors and top Managers

 - Shareholdings held by the relevant persons

 

2Article 114 of the Unified Financial Act and articles 152 sexies and152 octies of the Issuers Regulations.