A series of procedures and provisions are in place with regard to the handling of company information, considered as components of the organisational, management and control model adopted.
In particular, the Board of Directors has approved a Procedure for the monitoring, internal reporting and public disclosure of sensitive information, aimed at:
- regulating the ways in which corporate documents and information concerning Mondadori and its subsidiaries are monitored, managed and circulated within the Company, especially with regard to sensitive information as per Art. 181 of the Consolidated Law on Finance (replacing Italian Legislative Decree no. 58/1998);
- regulating the ways in which sensitive information is disclosed to the public and to the supervisory bodies, in accordance with applicable laws and regulations, and in keeping with standards for the transparency, timeliness and non-selective nature of disclosures.
Register of Persons with access to sensitive information
The register of persons with access to sensitive information was established by the Board of Directors, effective 1 April 2006, in accordance with the provisions under Art. 115 bis of the Consolidated Law on Finance (replacing Italian Legislative Decree 58/1998).
The Operating provisions for management of the Register of persons with access to sensitive information, related to the procedure for management of sensitive information, highlight the criteria adopted by Mondadori in keeping the register and govern:
- the methods for identification, registration and future removal of persons who, due to their work, profession or duties performed on behalf of the company or its subsidiaries, have permanent or occasional access to sensitive information;
- the flows of information with regard to the corporate function in charge of keeping the register;
- the methods of reporting to registered parties with regard to the respective registration and relative changes/removals;
- the methods of managing and searching for data contained in the register.
The procedures on the handling of company information include the Internal Dealing Disclosure Procedure, adopted by the Board of Directors on 1 April 2006.
The procedure aims to:
- identify parties required to make the disclosures, regarding Mondadori shares or financial instruments connected to them, envisaged by Art. 114, paragraph 7 of the Consolidated Law on Finance (replacing Legislative Decree 58/1998);
- notify the relevant parties about said identification, the related obligations and the methods of carrying out the disclosures required by law;
- identify the person responsible for receiving, managing and disclosing the aforementioned disclosures to the market.