Internal Dealing

Internal Dealing

This section provides access to the disclosures concerning transactions carried out by Relevant Persons and disseminated to the market by Lottomatica in accordance with the applicable internal dealing regulations, with respect to transactions relating to shares issued by Lottomatica or other financial instruments linked thereto, executed, whether directly or through intermediaries, by the Company’s Relevant Persons and their Persons Closely Associated.

Relevant Persons and Persons Closely Associated

The following are defined as “Relevant Persons”:

1. the members of the Board of Directors;
2. the standing members of the Board of Statutory Auditors of the Company; and
3. senior executives (alti dirigenti) who, although not serving as directors or statutory auditors of Lottomatica, have regular access to inside information directly or indirectly concerning the Company and have the power to take managerial decisions affecting the future developments and business prospects of the Company. These individuals are identified as the Executives with Strategic Responsibilities (Dirigenti con Responsabilità Strategiche) of the Company.

The following are defined as “Persons Closely Associated”:

a) the spouse (coniuge) of a Relevant Person or a partner considered to be equivalent to a spouse in accordance with national law, a dependent child (figlio a carico) of a Relevant Person in accordance with national law, a relative who has shared the same household for at least one year on the date of the Transaction concerned;

b) legal persons, trusts or partnerships, the managerial responsibilities of which are discharged by a Relevant Person or by one of the persons referred to in letter a) of this paragraph ;

c) legal persons, trusts or partnerships, directly or indirectly controlled by a Relevant  Person or by one of the persons referred to in letter a) above of this paragraph;

d) legal persons, trusts or partnerships, whose economic interests are substantially equivalent to those of a Relevant Person or one of the persons referred to in letter a) above of this paragraph;

e) legal persons, trusts or partnerships, established to benefit a Relevant Person or one of the persons referred to in letter a) above of this paragraph;

f)  the additional persons, whether natural or legal persons, as may be identified by the legislation applicable from time to time.

g) any additional persons identified as such by the Board of Directors by amending this procedure.

Relevant Transactions

Transactions falling within the scope of internal dealing obligations include those (as listed in the Procedure adopted by the Company) carried out in relation to shares issued by Lottomatica or financial instruments linked thereto, which exceed the threshold of significance established by the Company in compliance with applicable European and national regulations.

Closed periods

The Relevant Persons may not carry out Transactions on their behalf or on behalf of third parties, directly or indirectly, in the 30 (thirty) calendar days before the date scheduled for the approval of the draft annual financial statements, the consolidated financial statements, the half-yearly report and, where the Company decides to proceed with the relevant approval, the interim management report as at 31 March and the interim management report as at 30 September (“Closed Periods”). It is understood that the period of 30 (thirty) calendar days shall commence from the date of the meeting of the Board of Directors established for the approval of the accounting data according to the Company’s financial calendar, or otherwise fixed, and the Closed Period shall end only after the press release regarding the approval of the said accounting data has been released to the public.

Internal Dealing Procedure

For further information, reference is made to the specific Internal Dealing Procedure adopted by Lottomatica in compliance with the applicable provisions in force, which is made available herein.