Market abuse

In order to ensure the utmost fairness in the management of privileged information and transparency in the communication outwardly, Atlantia adopts specific procedures that meet the standards laid down by European and national legislation as well as the recommendations of the Corporate Governance Code 

In accordance with the Regulation (EU) no. 596/2014 ("MAR"), and in light of the applicable national regulatory framework, Atlantia has adopted the following procedures on Market Abuse:
  • Procedure for Market Announcements;
  • Code of Conduct for Internal Dealing.

Procedure for Market Announcements 

The Procedure for Market Announcements ("Procedure" ) regulates the internal management and disclosure to the market of inside information concerning Atlantia and its subsidiaries (if it constitutes inside information for Atlantia itself). 
It defines principles, behavioural obligations, roles and responsibilities on the matter, entrusting the management of inside information to the Chairman and the Chief Executive Officer who ensure correct and punctual disclosure to the market and timely communication to the competent authorities for market control, if needed. 
The Procedure also contains rules on keeping and updating the List of persons having access to Inside Information (Insider Register), which is managed by the General Counsel Department. 
The Procedure was last updated on 4 August 2021 in order to incorporate changes in the Company's organisational structure.

Code of Conduct for Internal Dealing

The Internal Dealing Code governs the disclosure obligations imposed on "Relevant Persons" and "Persons closely associated with them" vis-à-vis Atlantia and the market, in respect of transactions (including the purchase, sale, subscription or exchange of shares) carried out by the latter in relation to shares (and the financial instruments linked to them), as well as bonds, within the limits and terms set out in the Code.

In addition, pursuant to the Internal Dealing Code, Relevant Persons and Persons closely associated with them are subject to a blackout period - during the 30 days preceding the communication to the market of the Board of Directors' approval of the draft financial statements and the half-yearly report - during this period, they are prohibited from carrying out transactions in the Company's shares (and related financial instruments) and bonds . The time limit is reduced to 10 calendar days prior to the disclosure to the market of the possible approval - on a voluntary basis - by the Board of Directors of selected pre-closing data relating to the previous financial year and additional periodic information relating to the first and third quarter of the financial year. 

The Code of Conduct for Internal Dealing was last updated in March 2021 to incorporate the change in the MAR regulation, effective from January 2021, with respect to the deadlines for the issuer to notify the market of transactions carried out by relevant persons and notified to the Company.

Internal Dealing Announcement

2021