The Banca Ifis regulation on internal dealing is compliant with the relevant EU legislation (EU Regulation no. 596/2014, so-called Market Abuse Regulation) and aims to ensure maximum disclosure transparency towards the market. The “Policy on transactions carried out by Key Personnel and People Closely Associated with them on shares, debt securities and related financial instruments issued by Banca Ifis” (Internal Dealing Policy) was reviewed in February 2020. This policy governs:

• The obligations related to the identification of Key Personnel and “People closely associated with them”;
• The management of information relating to transactions beyond the minimum amount threshold on shares, debt securities or related instruments issued by Banca Ifis, carried out, directly or indirectly, by a Key Personnel Member or by a “Closely Associated Person” and subject to notification obligations;
• The management of “closure periods“, time intervals within which Key Personnel must refrain from carrying out transactions on shares and other debt securities issued by Banca Ifis, as well as on financial instruments connected to them.

The list of key personnel reads as follows:

• The members of the Board of Directors;
• The members of the Board of Statutory Auditors;
• The General Manager;
• The “strategic” executives:
  • Head of Central Finance Department;
  • Head of Central Affairs Department;
  • Head of Central NPL Management;
  • Head of the Central Capital Markets Department;
  • Head of Central Operations Department;
  • Head of Industrial Plan Governance, Planning and Management Control;
  • Chief Risk Officer;
  • Head of Internal Audit;
  • Head of Compliance;
  • General Manager of Ifis Npl Servicing;
  • Head of Legal and Corporate Affairs;
  • Head of Investor Relations and Corporate Development;
  • Head of Communication, Marketing and External Relations;
• Any person who holds a shareholding calculated pursuant to Article 118 of the Issuers’ Regulation, equal to at least 10% of the share capital of Banca Ifis, represented by shares with voting rights or any person who controls the Bank;
• The other subjects identified as such, even for limited periods of time, with a specific resolution of the Board of Directors of Banca Ifis.

The policy on internal dealing also applies to “persons closely associated” with Key Personnel.