On 13 November 2019 the Board of Directors introduced new Operating provisions regarding sensitive information, which replaced the procedure in place since 28 July 2016. The procedure places the responsibility for handling inside information with the Chief Executive Officer, who may enlist, as applicable, the services of the Central Finance, Procurement and Information Systems (Corporate and Legal Affairs Department, M&A and Investor Relations functions), the Communications and Media Relations Department and any other functions involved in relation to the contents and type of information.
The Procedure aims to:
- regulate the ways in which corporate documents and information concerning Arnoldo Mondadori Editore S.p.A. are monitored, managed and circulated within the Company, especially with regard to inside information as per Article 7 of Regulation (EU) No. 596/2014;
- regulate the ways in which inside information is disclosed to the market and the public, in accordance with applicable laws and regulations pertaining to inside information;
- regulate and maintain the Register of persons with access to inside information.
The procedures on the handling of company information include the Internal Dealing Disclosure Procedure, adopted by the Board of Directors on 8 February 2018.
- identifies the Managers required to make notifications under internal dealing regulations;
- duly informs the relevant persons of their status, the related obligations and the procedures and deadlines for making required notifications;
- identifies within the Corporate and Legal Affairs Department the designated officer for receiving, managing and disclosing to the market the notifications made by Managers.
The Corporate and Legal Affairs Department also carries out the systematic filing of notifications received and disclosed under disclosure requirements and keeps and updates the Insider List.