The policy of silent periods is one of the elements of a broader discipline concerning the treatment of corporate information.
Without prejudice to the provisions of applicable law concerning the protection of particular categories of information, the use of information in Telecom Italia must observe the general principles regarding the efficient exploitation and safeguarding of a company’s resources, which can be expressed as the rule of the “need to know”.
To this end there shall be procedures for the classification and handling of information from the point of view of its confidentiality. The Board of Directors shall also adopt a procedure for the handling and disclosure to the public of privileged information that the Company’s subsidiaries shall also comply with.
Relevant persons for the purposes of the law on insider dealing and persons closely related to them shall refrain from carrying out transactions involving shares of the Company (and of the parent company, if any) and financial instruments linked to them from the day following the close of each accounting period until the first disclosure of the final or preliminary economic and financial data for the period.
As an exceptional measure, the Board of Directors may establish additional blackout periods during which the obligation to refrain from insider dealing referred to above shall apply or suspend such obligation.
The Board of Directors shall identify the managers of the Group who shall be subject to particular disclosure obligations vis-à-vis the public.