Internal dealing

Persons discharging managerial responsibilities (Relevant persons) in Intesa Sanpaolo (the Company), as well as Persons closely associated with them (Persons closely associated), shall:

• notify every transaction involving listed financial instruments issued by the Company or derivatives and other financial instruments linked to them and 
• comply with the restrictions to transactions 

pursuant to art. 19 of Regulation (EU) No. 596/2014 on market abuse (so-called MAR) and the delegated legislation (Regulations (EU) No. 2016/522 and No. 2016/523).
European legislation has integrated provisions of art.114 paragraph 7 of Legislative Decree No. 58/1998 (Consolidated Law on Finance).
Notifications and restrictions are referred to financial instruments issued by the Company and listed on a regulated market or traded on multilateral trading facilities (MTFs) or on other types of organized trading facilities (OTFs), to which the MAR applies.
Intesa Sanpaolo has adopted Group Regulations concerning the transactions carried out by Relevant persons pursuant to art. 19 of the Regulation (EU) No. 596/2014 ("Internal Dealing"). These rules also detail the notification procedures and the restrictions on the transactions. 

Relevant persons and Persons closely associated are directly responsible for the notifications under art. 19 of the Regulation (EU) No. 596/2014 and can instruct the Company to provide notifications on their behalf, according to the terms and conditions expressly agreed.
If there isn’t any agreement with the Company, Relevant persons and Persons closely associated shall personally notify each transaction to the Italian Market Authority (Consob) and to the Company, promptly and no later than 3 working days after the transaction’s date.

Furthermore, Relevant persons shall not carry out transactions on their own account or on behalf of third parties, directly or indirectly, on financial instruments issued by the Company on regulated markets, MTFs or OTFs in the 30 calendar days prior to the publication of the Company’s results for the period (so-called blocking period).