Organisations now adhere to principles of honesty, openness and transparency in all its operational and organisational activities. There are times however when some information held by the organisation has to be regarded as confidential to the organisation. In such circumstances all Employees are required to maintain strict confidentiality regarding such information. As much information is nowadays held on computer systems, this policy is written in terms of the confidentiality of information using a computer. Its principles apply to all information.
The purpose of these Rules is to govern the procedures for communication to external recipients of documents and information regarding the Company and Group, particularly in regard to price sensitive information (i.e. information that can significantly influence the price of financial instruments).
The text of these rules is set forth as follows:
It is hereby announced and ordered that communication to external recipients of documents and information regarding the Company and Group, particularly in regard to price sensitive information, is regulated by the following internal procedure:
1. press releases regarding periodic information (financial statements, half-year report, quarterly report, etc.) and those regarding extraordinary transactions (mergers, acquisitions, capital increases, etc.) are approved by the Board of Directors and disseminated in compliance with the rules and regulations issued by the Supervisory Bodies;
2. in the other cases, public disclosures are managed, either jointly or severally and separately, by the Chairman or the Vice Chairman; they are also responsible for assessing the significance of the facts subject to disclosure. It is agreed that – except in urgent cases, such as the need to reply promptly to eventual requests by supervisory bodies – the Vice Chairman will be required to agree in advance on the content of these disclosures with the Chairman;
3. management of relations with institutional investors, financial analysts, and market operators is primarily the responsibility of the Chairman, who may rely on the support of the Investor Relations manager, while the Vice Chairman may collaborate with the Chairman in performing these activities whenever he deems fit;
4. the Directors, Statutory Auditors, Investor Relations manager, and all employees in general are required to maintain the confidentiality of price sensitive documents and information acquired in the course of performing their duties (if they have not already been published in the prescribed forms) and comply with the procedure envisaged for external communication of these documents and information;
5. it is absolutely forbidden for anyone to grant interviews to the press or make statements in general that contain information about significant facts that can be classified as price sensitive and that were not included in previously published press releases or documents.