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 Snam, internal dealing is governed by the Market Abuse Guide Line.
Any transactions that are considered “relevant” by the rules laid down by Consob, Italy’s markets authority, must be disclosed. At Snam, internal dealing imposes these requirements on:
- Chairman (Monica de Virgiliis)
- Chief executive officer (Stefano Venier)
- Directors (Massimo Bergami, Laura Cavatorta, Augusta Iannini, Piero Manzoni, Rita Rolli, Qinjing Shen, Alessandro Tonetti)
- Chairman of the board of statutory auditors (Stefano Gnocchi)
- Standing statutory auditors (Gianfranco Chinellato, Ines Gandini)
- Managers with strategic responsibilities: Chief Financial Officer e Chief International & Business Development Officer (Alessandra Pasini ), Chief Industrial Assets Officer (Massimo Derchi ), EVP Human Resources, Organization & PFM (Paola Boromei )
- Shareholders holding at least 10% of the Company's share capital (CDP RETI S.p.A.)
Shareholdings held by directors and Statutory Auditors
| Name | Post | Entity | Number of shares owned as of 31 December 2020 | Number of shares acquired in 2021 | Number of shares sold in 2021 | Number of shares owned as of 31 December 2021 |
|---|---|---|---|---|---|---|
| Marco Alverà | CEO | Snam | 403,879 | 667,010 (a) | 288,148(b) | 782,741 |
| Francesco Gori | Chief | Snam | 0 | 43 | 43 | 0 |
| Donata Paola Patrini (c) | Regular Auditor | Snam | 7,000 (c) | 0 | 7,000 (c) | 0 |
| 782,741 |
(a) Free allocation of Snam ordinary shares following the conclusion of the Vesting Period as provided for in the "2017 - 2019 Long-Term Share Incentive Plan" approved by the Shareholders' Meeting of 11 April 2017 The number represented also includes 83,964 of shares allocated as dividend equivalen.
(b) Shares sold on 30 July 2021, for purposes of meeting the tax liability associated with the share award.
(c) Shares owned by the spouse.
Shareholdings held by Snam managers with strategic responsibilities
| Snam managers with strategic responsibilities | Entity | Number of shares owned as of 31 December 2020 | Number of shares purchased in 2021 | Number of shares sold in 2021 | Number of shares owned as of 31 December 2021 |
|---|---|---|---|---|---|
| Managers with strategic responsibilities (a) | Snam | 117,741 | 302,704 (b) | 169,858 (c) | 250,587 |
27 April 2022 - 10:04 CEST