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Internal Dealing Procedure
The Internal Dealing Procedure adopted by UniCredit S.p.A. prescribes reporting duties and restrictions relating to certain transactions in UniCredit shares and/or debt instruments, as well as other financial instruments, linked to "Relevant Persons" of UniCredit and persons closely associated with them.
The Procedure implements the relevant regulatory requirements set out in article 19 of the Regulation (EU) no. 596/2014 ("Market Abuse Regulation") applicable to persons discharging managerial responsibilities.
Notifications and blackout periods
The procedure provides two relevant duties on subjects classified as Relevant Persons of UniCredit S.p.A.:
- to notify CONSOB of transactions on listed UniCredit shares and debt instruments (as well as derivatives and financial instruments linked thereto) executed by them and/or by persons closely associated with them; and
- to refrain from executing the above transactions in certain periods ("Blackout Periods"): Relevant Persons are prohibited from entering into transactions in UniCredit listed shares and/or debt instruments (as well as derivatives and financial instruments linked thereto) during a period of 30 calendar days before the announcement of annual financial statements, half-year financial reports, and the quarterly financial reports. In addition, the Board of Directors can decide other periods when transactions by Relevant Persons are banned or restricted.