The governance system

Processing of corporate information

For the distribution and storage of regulated information, Reno De Medici S.p.A. uses the SDIR platform named "eMarket SDIR" and the authorized storage system named eMarket Storage (www.emarketstorage.com) managed by Spafid Connect. S.p.A. with headquarters in Milan. The services are authorized by Consob (resolution No. 19879 for the storage system eMarket Storage and resolution No. 19878 for the distribution system eMarket SDIR).

As regards the processing of corporate information, a series of procedures and regulations are in force, incorporated as components of the Organisation, Management and Control Model adopted by the Board of Directors pursuant to Legislative Decree no. 231/2001.

Insider Dealing processing code

The procedure aims to:

  • regulate, according to confidentiality criteria, the methods of monitoring, management and internal circulation of corporate documents and information concerning Reno De Medici S.p.A.  and its subsidiaries, in particular regarding Relevant and Insider Dealing;
  • regulate the methods of communication to the public of Insider Dealing, according to criteria of transparency, timeliness and non-selectivity in accordance with the applicable regulatory provisions, both national and European in origin;
  • regulate the methods concerning the correct upkeep and constant update of the lists of people who have access to Relevant and Insider Dealing (“Insider List” and “Relevant Information List” o “RIL”).

The procedure also contains the provisions to the subsidiaries – required by Art. 114 of Legislative Decree no. 58/1998 – on information flows to Reno De Medici S.p.A., set in place to enable it to provide adequate and timely information to the market on events and circumstances that qualify as Insider Dealing and can be attributed to the operating environment of the subsidiaries.