Internal Dealing

Olidata has adopted an internal dealing procedure concerning transactions in financial instruments issued by Olidata S.p.A. made by Relevant Persons and Persons closely related to them. The purpose of the procedure is to regulate the disclosure requirements and behavioral procedures that must be observed and complied with by Relevant Persons and Olidata S.p.A. in order to ensure maximum disclosure transparency to the market.

Following the transposition into Italian law of EU regulations on Market Abuse (Law 62/2005), the matter is now governed by the Consolidated Law on Financial Intermediation (Legislative Decree No. 58/1998, as amended; hereinafter, the “TUF”), the Issuers’ Regulations issued by Consob (Resolution 11971/1999, as amended) in application of the TUF, and the recommendations and clarifications contained in Consob Communication No. DEM/6027054 of March 28, 2006. The Procedure is adopted pursuant to Article 114 paragraph 7 of the TUF and Articles 152 sexies – 152 octies of the Issuers’ Regulations. Therefore, the rules contained therein have the character of binding and mandatory provisions to be complied with by Relevant Persons and Persons closely related to them.