Internal dealing is regulated by Consob, Italy’s market regulator. Telecom Italia has voluntarily supplemented Consob’s rules by obligating employees to refrain from buying and selling shares during certain periods of the year (so-called blackout periods).
Transparency regarding transactions involving Company shares or related financial instruments undertaken directly by employees or through a third party closely connected with them (internal dealing), is governed by the Consob Regulation on Issuers (Art. 152-sexies et seq.).
Telecom Italia has also introduced on a voluntary basis the principle of refraining from undertaking such transactions in specific periods of the year (so-called blackout periods).
Pursuant to the law, the directors and statutory auditors of the issuing company, as well as “persons undertaking functions of directorship, auditing and top management in a listed issuing company and the managers who have regular access to confidential information and have the power to take management decisions that may affect the future evolution and prospects of the listed issuing company” are required to make disclosures to the market regarding the transactions involving Company shares or financial instruments connected to the same when these have a value of more than €5,000 on an annual basis.
The Telecom Italia Self-Regulatory Code also provides for blackout periods from the day following the closing of each accounting period (March 31, June 30, September 30, December 31) up to the first disclosure of the economic and financial data for the period, either definitive or projected.
These blackout periods may be extended or suspended by the Board of Directors on extraordinary occasions.