Internal Dealing

Internal dealing refers to transparency requirements for operations relating to Shares or Debt Instruments issued by listed companies, as well as derivatives or other relating financial instruments carried out by representatives of the Companies themselves, Relevant Shareholders and by persons closely connected to them. At Industrie De Nora SpA these issues are governed by the internal dealing procedure approved by the Board of Directors on 18 February 2022. Any transactions that are considered “relevant” by the rules laid down by Consob, Italy’s markets authority, must be disclosed.

At Industrie De Nora , internal dealing imposes these requirements on:

• the members of the Board of Directors and the members of the Board of Statutory Auditors of the Company;
• the managers that have valid access to inside information directly or indirectly concerning the Company and who have the power to make management decisions that could affect the future development and prospects of the Company;
• anyone who has a shareholding, calculated in accordance with article 114, paragraph 7 of the Consolidated Finance Act and article 118 of the Issuers Regulation, of at least 10% of the share capital of the Company, represented by Shares with voting rights, and any other party who controls the Company.