The Banca Ifis regulation on internal dealing is compliant with the relevant EU legislation (EU Regulation no. 596/2014, so-called Market Abuse Regulation) and aims to ensure maximum disclosure transparency towards the market.

On the other hand, the “Policy on transactions carried out by Relevant Persons and Closely Related People in shares, debt securities and related financial instruments issued by Banca Ifis” (the “Internal Dealing Policy”) was updated in April 2021.

This policy governs:

• The obligations related to the identification of Key Personnel and “People closely associated with them”;
• The management of information relating to transactions beyond the minimum amount threshold on shares, debt securities or related instruments issued by Banca Ifis, carried out, directly or indirectly, by a Key Personnel Member or by a “Closely Associated Person” and subject to notification obligations;
• The management of “closure periods“, time intervals within which Key Personnel must refrain from carrying out transactions on shares and other debt securities issued by Banca Ifis, as well as on financial instruments connected to them.

The list of key personnel reads as follows:

• The members of the Board of Directors;
• The members of the Board of Statutory Auditors;
• Key management personnel, who are currently:
  • Co-General Manager Chief Operating Officer
  • Co-General Manager Chief Commercial Officer
  • Head of the Communication, Marketing, Public Affairs & Sustainability Department
  • Chief of Staff and Chairman’s Communication 
  • Chief Financial Officer
  • Manager charged with preparing the Company’s financial reports
  • Chief Lending Officer
  • Head of the Npl Department
  • Head of Internal Audit
  • Head of Compliance
  • Chief Risk Officer
  • Head of Anti-Money Laundering
  • Head of the Human Resources Department
  • General Counsel
  • Head of the Investor Relations & Corporate Development Department
  • CEO of Ifis NPL Servicing S.p.A. 
  • General Manager of Ifis NPL Servicing S.p.A.
  • CEO of Banca Credifarma S.p.A.
• Any person who holds a shareholding calculated pursuant to Article 118 of the Issuers’ Regulation, equal to at least 10% of the share capital of Banca Ifis, represented by shares with voting rights or any person who controls the Bank;
• The other subjects identified as such, even for limited periods of time, with a specific resolution of the Board of Directors of Banca Ifis.

The policy on internal dealing also applies to “persons closely associated” with Key Personnel.