Procedure for the fulfilment of the obligations concerning Internal Dealing
This procedure (the “Procedure”) defines the regulations for the acquittal of the disclosure obligations inherent to transactions on the financial instruments of Mittel S.p.A. (the “Issuer” or the “Company”) or derivative instruments or other financial instruments linked to the same, carried out by MAR Relevant Parties or TUF Relevant Parties (as defined below), for the purpose of ensuring greater transparency towards the market and suitable prevention measures against market abuse and, in particular, against the abuse of Inside Information.

Definitions
Section I – DISCLOSURE OBLIGATIONS IN ACCORDANCE WITH THE MAR

Article 1 Relevant Persons
Article 2 Persons closely associated with MAR Relevant Persons
Article 3 MAR Relevant Transactions and deadlines for communication
Article 4 Threshold
Article 5 Black Out Period

Section II – DISCLOSURE OBLIGATIONS IN ACCORDANCE WITH THE TUF AND THE ISSUERS’ REGULATION
Article 6 TUF Relevant Persons and Persons closely associated with TUF Relevant Persons
Article 7 TUF Relevant Transactions and deadlines for communication
Article 8 Threshold and cases of exemption

Section III – DISCLOSURE OBLIGATIONS WHICH TUF RELEVANT PARTIES ARE RESPONSIBLE FOR IN THE EVENT THAT THE SAME ARE ALSO MAR RELEVANT PARTIES
Article 9. Regulations applicable to the TUF Relevant Parties which are subject to the notification obligations as per the MAR since they are MAR Relevant Parties

Section IV
PERSON IN CHARGE AND MARKET DISCLOSURE

Article 10 Person in Charge
Article 11 Method for making the communications to the Person in Charge
Article 12 Method for making the communications to the general public and Consob by the Person in Charge on behalf of the Company
Article 13 Communication of the Procedure to the MAR/TUF Relevant Parties
Article 14 Data processing
Article 15 Amendments and additions
Article 16 Information flows to the Supervisory Body
Article 17 Sanctions
Article 18 Final Provisions

Annexes:
– Annex A: List, by way of example but not limited to, of the MAR Relevant Transactions.
– Annex B: Transmission Letter template.
– Annex C: Acceptance Letter template.
– Annex D: MAR Notification Template.
– Annex D bis: TUF Notification Template.
– Annex E: Transactions which justify the authorisation to trade in the Black Out Period.