Internal Dealing

Our internal dealing regulations govern disclosure obligations for people who hold key positions at the bank in relation to transactions involving debt instruments issued by Mediobanca International and derivative financial instruments or other financial instruments linked to them.

The disclosure obligation arises because the settlement of transactions involving the company’s financial instruments by persons holding key positions can be particularly significant information for the market.

The procedure requires these individuals, referred to as "Relevant Persons", to promptly report the transactions carried out to Group Corporate Affairs unit, which then informs the Authority and the public, in the manner and within the time periods required.

INDIVIDUALS SUBJECT TO THE RULES
The internal dealing rules apply to the following relevant persons:

  • the Members of the Board of Directors;
  • Members of senior management;
  • the Heads of the Control Functions (Compliance, Internal Audit and Risk Management).

The rules also apply to persons or entities defined as “Closely Related to Relevant Persons”:

  1. Spouse or partner equivalent to spouse as defined by Luxembourg law, depending children as defined by national law and relatives who have shared the same household for at least one year as the date of the transaction;
  2. entities, companies and trusts:
    • in which a Relevant Person, or one of the persons referred to in point 1 above, holds management responsibilities;
    •  controlled directly or indirectly by a Relevant Person or one of the persons referred to in point 1 above;
    • whose economic interests of which are substantially equivalent to those of a Relevant Person or one of the persons referred to in point 1 above.

TRANSACTIONS SUBJECT TO THE RULES
The rules apply to transactions such as acquisitions, disposals, subscriptions or swaps involving Mediobanca International debt securities or financial instruments linked to them. They do not apply to transactions whose aggregate amount is below the threshold of 5,000 Euro in the course of the year or a higher amount, if any, set by the relevant Authority.

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