Internal Dealing

Our code of conduct regarding internal dealing matters, that includes the procedures aiming at ensuring transparency towards the market.

Since April 2004, Terna adopted a code of conduct regarding internal dealing, to guarantee transparency toward the market for its significant transactions based on the acquisition, sale, subscription and exchange of Terna’s shares, or of financial tools linked to them that are carried out, either directly or indirectly, by persons holding relevant decision-making powers within the company and that have access to price sensitive information (“relevant persons”).
 

Subsequently to the entrance into effect of the new internal dealing regulations introduced by Law No. 62 dated April 18, 2005 (“EU Law 2004” that integrated the provisions of art . 114 of the Consolidated Financial Text) and by the relative implementing regulations (Articles 152 sexies to 152 octies and Attachment 6 of Consob Regulation No. 11971/1999 so-called Issuer’s Regulation), Terna adopted a specific internal Procedure for identifying Terna’s “relevant persons” and for managing, handling and announcing to the market information regarding financial transactions carried out by such persons.
 

As part of this procedure, recently updated on March 19, 2010, Terna deemed it appropriate to maintain for the “relevant persons” identified, the obligation to refrain from conducting, either directly or indirectly, transactions that are subject to internal dealing regulations during two blocking periods identified at the time of approval of the draft financial statements and of the half- year report on the part of Terna’s Board of Directors.
 

This page includes the Internal Procedure for identifying Terna’s “relevant persons” and for managing, handling and announcing to the market the information regarding financial transactions carried out by such persons, adopted in compliance with article No. 152 octies, paragraph 8, of Consob Regulation dated May 14, 1999 No. 11971 (Issuers’ Regulation), updated in 2010. This section also includes information published in compliance with art. 152-octies of Consob Resolution No. 11971/1999.
 

Terna’s information to the market as of April 1, 2006 is also published, regarding transactions subject to the internal dealing regulations carried out by Terna’s “relevant persons” and by persons strictly linked to them.
 

Internal Dealing Communication

Date	Relevant Person	Relation with Terna
17/01/2012	Romano Minozzi	Director
29/12/2011	Romano Minozzi	Director
29/12/2011	Romano Minozzi	Director
22/12/2011	Romano Minozzi	Director
22/12/2011	Romano Minozzi	Director
21/12/2011	Romano Minozzi	Director
21/12/2011	Romano Minozzi	Director
19/12/2011	Romano Minozzi	Director
19/12/2011	Romano Minozzi	Director
25/11/2011	Romano Minozzi	Director
25/11/2011	Romano Minozzi	Director
19/09/2011	Romano Minozzi	Director
24/08/2011	Luigi Roth	Chairman of Board of Directors
22/08/2011	Romano Minozzi	Director
18/04/2011	Flavio Cattaneo	Chief Executive Officer
02/28/2011	Luciano Di Bacco	Manager charged with preparing a company’s financial reports
02/28/2011	Fabio Todeschini	Finance, Control, Interntional and M&A Director
02/28/2011	Gianni Vittorio Armani	Italian Operations Director
02/28/2011	Flavio Cattaneo	Chief Executive Officer
12/17/2010	Salvatore Machì	Director
14/10/2010	Luigi Roth	Chairman of Board of Directors
05/05/2010	Luigi Roth	Chairman of Board of Directors
04/20/2010	Salvatore Machì	Director
06/12/2009	Fabio Todeschini	Finance and Control Director and Business Development and International Activities Director
01/07/2009	Flavio Cattaneo	Chief Executive Officer
12/22/2008	Salvatore Machì	Director
12/12/2008	Adriana Palmigiano	Head Of Planing and Control
12/01/2008	Flavio Cattaneo	Chief Executive Officer
10/09/2008	Luigi De Francisci	Regulatory Affairs Director
10/07/2008	Luciano Di Bacco	Administration Department Director
09/22/2008	Francesco Del Pizzo	Dispatching and Conduction Director
10/11/2007	Salvatore Machì	Director
07/31/2007	Luca d'Agnese	Italy Operations Director
06/01/2007	Francesco Del Pizzo	Dispatching and Conduction Director