Market abuse compliance
Snam ensures proper processing of price-sensitive information in order to protect all investors and avoid that subjects may make use of information not in the public domain to make speculative transactions on the markets
Snam’s Board of Directors approved the market abuse procedure. This compliance effort combines and co-ordinates the market abuse rules and principles that Snam and its related parties must adhere to, in order to:
a) ensure adequate processing of price sensitive information relating to the Company by those having access to it;
b) regulate operations on Shares and debt instruments issued by the Company, as well as on derivatives or other related financial instruments conducted by specific individuals in senior management positions (so called, “internal dealing”); and,
c) define operating procedures and scope of application of the ban imposed upon the Company and individuals exercising administrative, surveillance or managerial functions in the Company concerning transactions on Shares and debt instruments issued by the Company, as well as on derivatives or other related financial instruments during pre-determined periods (“black out period”).
Annex A -“Relevant Regulations”
Annex B -“List of Financial Instruments”
Annex C -“Decision to delay the disclosure of Inside Information”
Annex 9 -“Disclose Procedure pursuant to Implementing Regulation (EU) 523/2016”
Annex 10 -“Exemption from Black-Out period prohibitions”
The Market Abuse Procedure has been adopted by Snam's subsidiaries.
The company's foreign subsidiaries may adopt the procedure so long as it is adapted to respect local laws.
Market abuse procedure is articulataed as follows
Access to privileged information
The first part of the Procedure sets forth the rules for the management and processing of Privileged Information, as well as the procedures to be followed for communicating said information both within and outside of the Company, in order to prevent Privileged Information from being processed at the wrong time and/or in an incomplete manner, or to prevent said processing from resulting in information asymmetry. In the same section the Procedure sets forth the rules governing the management of the Register of Informed Persons.
Rules governing internal dealing and black out period
The second part sets forth the rules for the disclosure of transactions carried out by persons who hold a senior position within the Company (i.e. the Significant Persons). In particular:
- the methods for identifying the "Significiant Transactions" (transactions over a threshold) carried out by said significant persons and by closely related persons involving the shares or associated Ffnancial Instruments;
- the disclosure requirements of Significant Persons, the Person Closely Associated to the Significant Persons and of the Company vis-à-vis Consob and the public in relation to Significant Transactions;
- the ban on Significant Persons and closely related persons carrying out Significant Transactions during certain periods ("black-out periods").
Besides this part sets out rules to define when Snam is banned from issuing and/or performing transactions on its listed financial instruments.
30 August 2016 - 12:02 CEST