Transactions and persons subject to the current regulations on internal dealing
In compliance with the discipline introduced at European and Italian level, the regulation of internal dealing concerns the public disclosure of transactions (“Transactions”) regarding the financial instruments issued by Enel, as well as derivatives or other financial instruments linked thereto, carried out by Persons Discharging Managerial Responsibilities (“PDMR”) and certain categories of persons closely associated to them, as well as by Relevant Shareholders (i.e. anyone holding an equity interest equal to at least 10% of the share capital of Enel) and certain categories of persons closely associated to them.
PDMR means Directors and Regular Statutory Auditors of Enel and, currently, 11 senior executives of Enel Group (as specified, together with the names of Directors and Regular Statutory Auditors, on the on the attached list) who have regular access to inside information relating, directly or indirectly, to Enel and have power to take managerial decision affecting the future developments and business prospects of Enel.
In March 2017 Enel’s Board of Directors, taking into account the significant innovations cast by the new market abuse discipline introduced at European level, deemed it appropriate to approve a specific “Regulation on internal dealing", subsequently amended and supplemented in July 2017 and in September 2019.
Internal dealing transparency requirements do not apply in the event of Transactions whose total value does not reach, within a calendar year, the threshold of Euro 20,000. With respect to PDMR and persons closely associated to them, once the threshold is reached, all the transactions carried out in the calendar year shall be disclosed, regardless of their amount.
PDMR shall not conduct, on their own account or for the account of a third party, directly or indirectly, Transactions during the thirty calendar days before the date scheduled for the announcement of the data concerning the project of financial statements of Enel, the consolidated financial statements and the half-year financial report of Enel Group (so called “Black-out Periods”).
Any exception from the restrictions to trade during Black-out Periods may be granted on a case-by-case basis due to the existence of exceptional circumstances and, in any case, under the condition that the PDMR is able to demonstrate that the particular Transaction cannot be executed at another moment in time than during the Black-out Period.
Transactions carried out as from April 1, 2006
In accordance with the recommendations of Consob, listed below are the transactions subject to the internal-dealing regulations, which have been communicated to the market by Enel and carried out as from April 1, 2006 by PDMR and Persons Closely Associated with them.