Market Abuse
The MSG Market Abuse is a necessary instrument to continually improve the definition of the process and resulting methods of implementation, in order to apply the recent legislative and regulatory provisions on market abuse, and, particularly, the obligations under EU Regulation no. 596/2014 (Market Abuse Regulation - MAR) and related implementation measures. Specifically, the MSG Market Abuse regulates the measures and procedures relating to both the internal management and external disclosure of Inside Information and Significant Information regarding the Company and its subsidiaries.
The MSG Market Abuse provides detailed operational instructions that will help Saipem to ensure, within its organisation and in its relations with third parties, that its conduct complies with European regulations, with due regard to specific features of the national institutional and operational framework.
The MSG Market Abuse, first issued on May 9, 2013, establishes the principles and rules that Saipem S.p.A. and the companies that it controls, directly and indirectly, in Italy and abroad, must adhere to for the management within Saipem and external communication of company documents and information regarding Saipem, with particular reference to Inside Information and Significant Information. To this end, the MSG Market Abuse also regulates the establishment, keeping and updating of Lists of persons with access to Inside Information and Significant Information, the identification of Relevant Parties and the means of notifying transactions executed, including through third parties, on shares issued by Saipem S.p.A. or on other financial instruments linked to these shares (“Internal Dealing”).
The MSG Market Abuse has been last updated by resolutions of the Board of Directors of Saipem S.p.A. on April 19, 2023 to reflect procedural and organizational updates.
pdf - 06-2023
Internal Dealing
For the purposes of Market Abuse procedures Relevant Parties are the members of the Board of Directors, the Board of Statutory Auditors, the Senior Managers with Strategic Responsibilities, the Significant Shareholders (*) and the Persons closely associated with Relevant Parties.
In accordance with Board of Directors’ resolution on December 13, 2022, the Board of Directors, at the proposal of the CEO, identifies the Senior Managers with Strategic Responsibilities among the persons reporting directly to the Chief Executive Officer or the General Manager who have the power and responsibility, directly or indirectly, for planning, directing and controlling the Group’s activities.
For such purpose, the Board of Directors on May 26, 2023, appointed as Senior Managers with Strategic Responsibilities, until otherwise resolved: the Chief Financial Officer, the Officer Responsible for Financial Reporting, the General Counsel, Contract Management, Company Affairs, Governance and Public Affairs, the Chief People, HSEQ and Sustainability, the Director Commercial, the Director Supply Chain, Digital and IT, the Director Asset Based Services, the Director Energy Carriers, the Director Sustainable Infrastructures, the Director Robotics and Industrialized Solutions, the Director Offshore Wind.
(*) anyone who directly or indirectly holds an interest, which, in accordance with Article 118 of the Issuers' Regulations, is at least ten percent (10%) of the Company's share capital with voting rights, as well as any other person who controls the Company.
Internal Dealing transactions
Below is a list of Internal Dealing Transactions since 2016
Related party | Position | Operation Date | Operation Type | Volume financial Instruments |
Mauro Piasere | Person discharging managerial responsibilities | 07/11/24 | S | 20.240 |
Paolo Calcagnini | Person discharging managerial responsibilities | 26/10/23 | P | 40.000 |
Alessandro Puliti | Chief Executive Officer | 26/10/23 | P | 24.000 |
Filippo Abbà | Person discharging managerial responsibilities | 26/10/23 | P | 35.000 |
Mauro Piasere | Person discharging managerial responsibilities | 08/09/23 | S | 20.000 |
Mauro Piasere | Person discharging managerial responsibilities | 01/09/23 | FA / S | 386 / 195 |
Simone Chini | Person discharging managerial responsibilities | 31/08/23 | P | 30.000 |
Mauro Piasere | Person discharging managerial responsibilities | 05/05/23 | P | 30.000 |
Simone Chini | Person discharging managerial responsibilities | 11/01/23 | P | 60.000 |
Paolo Calcagnini | Person discharging managerial responsibilities | 20/09/22 | P | 100.000 |
Marco Toninelli | Person discharging managerial responsibilities | 01/09/22 | FA / S | 890 / 496 |
Paolo Albini | Person discharging managerial responsibilities | 01/09/22 | FA / S | 316 / 213 |
Mauro Piasere | Person discharging managerial responsibilities | 01/09/22 | FA | 518 |
Alessandro Puliti | Person discharging managerial responsibilities | 27/07/22 | P | 140.000 |
CDP Industria S.p.A. | Relevant Shareholder | 19/07/22 | C | 253.176.710 |
ENI S.p.A. | Relevant Shareholder | 19/07/22 | C | 615.992.065 |
Marco Toninelli | Person discharging managerial responsibilities | 15/07/22 | C | 20.710 |
Paolo Albini | Person discharging managerial responsibilities | 27/05/22 | S | 2.521 |
Paolo Albini | Person discharging managerial responsibilities | 28/04/22 | S | 7.045 |
Massimiliano Branchi | Person discharging managerial responsibilities | 21/04/22 | S | 10.000 |
Maurizio Coratella | Person discharging managerial responsibilities | 31/12/21 | FA | 17.241 |
Stefano Porcari | Person discharging managerial responsibilities | 31/12/21 | FA / FA | 27.300 / 18.457 |
Marco Toninelli | Person discharging managerial responsibilities | 01/09/21 | FA | 44.326 |
Luigi Siri | Person discharging managerial responsibilities | 01/09/21 | FA / S | 25.037 / 10.953 |
Marco Satta | Person discharging managerial responsibilities | 01/09/21 | FA / S | 25.037 / 25.037 |
Stefano Porcari | Person discharging managerial responsibilities | 01/09/21 | FA / S | 55.369 / 55.369 |
Maurizio Coratella | Person discharging managerial responsibilities | 01/09/21 | FA / S | 51.721 / 22.605 |
Mario Colombo | Person discharging managerial responsibilities | 01/09/21 | FA / S | 32.232 / 32.232 |
Silvia Abrate | Person discharging managerial responsibilities | 01/09/21 | FA / S | 12.543 / 5.498 |
Dario Gallinari | Person discharging managerial responsibilities | 03/06/21 | S | 33.572 |
Francesco Racheli | Chief Operating Officer Xsight Division/Director Digital and Innovation | 31/05/21 | FA | 25.275 |
Stefano Cao | Chief Executive Officer | 28/04/21 | S | 102.853 |
Mauro Piasere | Person discharging managerial responsibilities | 24/11/20 | S | 20.000 |
Capfin S.p.A. | Person closely associated with relevant person | 18/11/20 | S | 61.000 |
Davide Ruvolo | Director Strategy | 10/11/20 | S | 19.426 |
Capfin S.p.A. | Person closely associated with relevant person | 29/10/20 | P | 36.000 |
Silvia Abrate | Person discharging managerial responsibilities | 01/09/20 | FA | 19.500 |
Stefano Cao | Chief Executive Officer | 01/09/20 | FA | 298.125 |
Mario Colombo | Person discharging managerial responsibilities | 01/09/20 | FA / S | 49.425 / 49.425 |
Gaetano Colucci | Person discharging managerial responsibilities | 01/09/20 | FA / S | 36.375 / 16.949 |
Dario Gallinari | Person discharging managerial responsibilities | 01/09/20 | FA | 84.000 |
Mauro Piasere | Person discharging managerial responsibilities | 01/09/20 | FA | 36.900 |
Stefano Porcari | Person discharging managerial responsibilities | 01/09/20 | FA / S | 81.900 / 81.900 |
Francesco Racheli | Person discharging managerial responsibilities | 01/09/20 | FA / S | 75.825 / 35.306 |
Davide Ruvolo | Person discharging managerial responsibilities | 01/09/20 | FA / S | 36.375 / 16.949 |
Marco Satta | Person discharging managerial responsibilities | 01/09/20 | FA / S | 36.375 / 16.949 |
Luigi Siri | Person discharging managerial responsibilities | 01/09/20 | FA | 36.375 |
Marco Toninelli | Person discharging managerial responsibilities | 01/09/20 | FA | 63.450 |
Stefano Cao | Chief Executive Officer | 03/08/20 | P | 110.000 |
Capfin S.p.A. | Person closely associated with relevant person | 29/07/20 | P | 25.000 |
Claudia Macchi | Person closely associated with relevant person | 05/06/20 | S | 10.000 |
Claudia Macchi | Person closely associated with relevant person | 10/07/20 | A / S | 12.000 / 12.000 |
Stefano Cao | Chief Executive Officer | 13/03/20 | P | 100.000 |
Claudia Macchi | Person closely associated with relevant person | 13/03/20 | P | 10.000 |
Paul Schapira | Board member | 18/05/20 | P | 200.000 euro |
Giulio Ettore Bozzini | Person discharging managerial responsibilities | 12/10/18 | FA | 47.470 |
Mauro Piasere | Person discharging managerial responsibilities | 26/11/18 | P | 5.000 |
Federico Ferro-Luzzi | Board member | 22/09/18 | S | 40.500 |
Federico Ferro-Luzzi | Board member | 29-02-2018 | P | 40.500 |
Paolo Andrea Colombo | President | 26/02/18 | P | 290.000 |
Stefano Cao | Chief Executive Officer | 26/02/18 | P | 290.000 |
Dodge & Cox | Relevant Shareholder | 11/02/18 | P | 639.213.542 |
Dodge & Cox | Relevant Shareholder | 09/02/18 | S | 4.475.000 |
Fabio Pallavicini | Person discharging managerial responsibilities | 08/02/18 | C | 242.000 |
Egidio Palliotto | Person discharging managerial responsibilities | 05/02/18 | C | 55.000 |
Antonio Careddu | Person discharging managerial responsibilities | 05/02/18 | C | 18.700 |
Dodge & Cox | Relevant Shareholder | 05/02/18 | S | 6.125.407 |
Dodge & Cox | Relevant Shareholder | 04/02/18 | S | 7.392.002 |
Fondo Strategico Italiano S.p.A. | Relevant Shareholder | 03/02/18 | C | 1.213.880.008 |
Dodge & Cox | Relevant Shareholder | 03/02/18 | S | 6.943.000 |
Dodge & Cox | Relevant Shareholder | 02/02/18 | S | 3.517.750 |
Andrea Forzan | Person discharging managerial responsibilities | 01/02/18 | C | 25.300 |
Dodge & Cox | Relevant Shareholder | 01/02/18 | S | 3.458.875 |
Dodge & Cox | Relevant Shareholder | 29/01/18 | S | 3.880.000 |
Eni S.p.A. | Relevant Shareholder | 28/01/18 | S | 2.953.432.746 |
Dodge & Cox | Relevant Shareholder | 28/01/18 | S | 7.046.267 |
Eni S.p.A. | Relevant Shareholder | 22/01/18 | C | 55.176.364 |
Dodge & Cox | Relevant Shareholder | 15/01/18 | S | 35.601 |
Legend
C = capital increase subscription
FA = free assignment of ordinary shares of Saipem S.p.A.
FA / S = free assignment and sell to cover taxes.
P = purchase
S = sale