In compliance with provisions contained in the Consolidated Law on Finance (Legislative Decree 58/1998), following the changes introduced by Law 262/2005, as well as in the regulatory measures issued by Consob, Intesa Sanpaolo has adopted specific Internal Dealing Regulations (currently available in Italian only), aimed at adapting internal regulations and procedures to the discipline of information requirements related to transactions involving shares issued by the issuer or other related financial instruments, carried out by relevant people or by people closely linked to these, to provide the necessary transparency and homogenous information to the market.
The Regulations identify the "relevant parties", defining their behaviour and disclosure requirements.
Relevant Parties For the purposes of the present Regulations and on the basis of the definitions indicated in Art. 152-sexies of Issuers' Regulation “Relevant parties” of Intesa Sanpaolo S.p.A. are:
Board Directors of Intesa Sanpaolo S.p.A., including those who sit on the Management Control Committee, and the Managing Director and CEO;
the Heads of the following Governance Areas: Chief Financial Officer, Chief Governance Officer, Chief Innovation Officer, Chief Lending Officer, Chief Operating Officer, Chief Risk Officer;
the Chief Compliance Officer;
the Heads of the Banca dei Territori Division, the Corporate and Investment Banking Division, the International Subsidiary Banks Division, the Private Banking Division, the Asset Management Division and the Insurance Division;
the Head of the Administration and Tax Department and the Manager responsible for preparing the Company’s financial reports;
the Head of Treasury;
the Head of Capital Light Bank.
On the basis of proposals formulated by the “Competent party”, the Managing Director and CEO of the Company identifies, even temporarily, in accordance with criteria set forth by the law, other Related parties, to which the provisions of Regulations apply.
The "Relevant parties" must communicate to the "Competent party", in the terms and according to the means provided for by Art. 4 of Reguations, the transactions for the purchase, sale, subscription or exchange, carried out – directly or indirectly – by themselves or by Closely-related parties.
Pursuant to Art.152-sexies of Issuers' Regulation "Parties closely-related to Relevant parties" are:
1. the spouse, if not legally separated, minor children, even of the spouse and, if living in the same house for at least a year, also parents, relatives and in-laws of the “Relevant parties”; 2. companies, juridical entities and trusts in which a “Relevant party” or one of the persons indicated in point 1 above is responsible, individually or jointly, for the management; 3. companies, controlled directly or indirectly by a “Relevant party” or by one of the persons indicated in point 1 above; 4. juridical entities whose economic interests are basically equivalent to those of a “Relevant party” or one of the persons indicated in point 1 above; 5. the trusts in which the “Relevant party” or one of the persons indicated in point 1 above is the beneficiary.
"Relevant parties" are forbidden from carrying out the transactions indicated above in the 30 days preceding the board meeting called to approve the financial statements and the half-yearly report and in the 15 days preceding the board meeting called to approve the interim statements.