Internal dealing and market abuse

In the context of the procedures relating to the Market Abuse Regulations (Regulation (EU) No. 596/2014 of the European Parliament and of the Council of the European Union of 16 April 2014 on market abuse – Market Abuse Regulation), the procedure for the fulfilment of internal dealing obligations governs disclosure obligations relating to transactions on Italgas’ financial instruments carried out by Relevant Persons (hereinafter, also the “Procedure”), in order to ensure greater transparency towards the market and adequate preventive measures against market abuse and, in particular, against insider trading.

The regulations in fact required Relevant Persons, as identified by the Procedure itself, to promptly notify the market and Consob of any transaction on the Company’s financial instruments considered relevant under Consob regulations and the Procedure.

Relevant Persons shall mean Relevant Parties together with Persons Closely Associated with Relevant Parties.
For the purposes of the procedure, the following are considered as Relevant Parties: (i) MAR Relevant Parties and (ii) Relevant Shareholders.

Relevant Shareholders are those who hold a stakean equity investment, calculated pursuant to Article 118 of the Issuers’ Regulation, amounting to at least 10% of the company’s share capital, represented by voting shares, as well as any other subject that controls the company.

The following are considered as Persons Closely Associated with Relevant Parties: (i) persons closely associated with MAR Relevant Parties and (ii) persons closely associated with Relevant Shareholders.

For more information on the types of relevant transactions, see the specific paragraphs of the Procedure.
The list of internal dealing disclosures made since 2016 is set out below.

A= Purchase

B= Other – Free allocation of Italgas S.p.A. ordinary shares following the accrual of rights assigned pursuant to the “2018-2020 Co-Investment Plan” approved by the Shareholders’ Meeting of 19 April 2018.

C= Sale of Italgas S.p.A. ordinary shares allocated free of charge pursuant to the “2018-2020 Co-Investment Plan” approved by the Shareholders’ Meeting of 19 April 2018, to cover tax charges (“sell to cover”) related to this allocation in accordance with the Plan.

D= Sale of ordinary shares in Italgas S.p.A.

E= Other – Free allocation of Italgas S.p.A. ordinary shares following the accrual of rights assigned pursuant to the “2021-2023 Co-Investment Plan” approved by the Shareholders’ Meeting of 20 April 2021.

F= Sale of Italgas S.p.A. ordinary shares allocated free of charge pursuant to the “2021-2023 Co-Investment Plan” approved by the Shareholders’ Meeting of 20 April 2021, to cover tax charges (“sell to cover”) related to this allocation in accordance with the Plan.

(*) Free assignment of Italgas S.p.A. ordinary shares following the accrual of rights allocated pursuant to the “2018-2020 Co-Investment Plan” approved by the Shareholders’ Meeting of 19 April 2018. For theExecutives with strategic responsibilities  61.867 shares were sold as ordinary shares to cover the tax charges (“sell to cover”) associated with the assignment in accordance with the Plan; while 21.045 shares were sold as ordinary Italgas shares.

(**) Free assignment of Italgas S.p.A. ordinary shares following the accrual of rights allocated pursuant to the “2018-2020 Co-Investment Plan” approved by the Shareholders’ Meeting of 19 April 2018. For the Executives with strategic responsibilitie 27,159 shares were sold as ordinary shares to cover the tax charges (“sell to cover”) associated with this assignment in accordance with the Plan; while 63,539 shares were sold as ordinary Italgas shares.

^{1 of which 12,000 in person and 2,000 by the spouse}

(Situation at 31 December 2022)

(*) Free assignment of Italgas S.p.A. ordinary shares following the accrual of rights allocated pursuant to the “2018-2020 Co-Investment Plan” approved by the Shareholders’ Meeting of 19 April 2018.