Internal Dealing

SAES Getters S.p.A. adopted a Code of Conduct for Internal Dealing identifying Persons obliged to carry out the disclosures pursuant to article 114, subsection 7, TUF and  the person appointed to receive, manage and disclose to the market information pursuant to article 114, subsection 7, TUF. The Code of Conduct specifies the disclosure obligations the Significant Persons (as defined in the Code of Conduct) and the Company are required to observe. Such procedure, as from April 1, 2006, amends and replace the previous Code of Conduct for Internal Dealing approved by the Board of Directors on December 19, 2002, as updated on February 14, 2003, following the entry into force of the Consolidated Finance Act (Legislative Decree 58/1998 and subsequent amendments), the Consob Regulations for Issuers (Resolution 11971/1999 and subsequent amendments) - as amended because of the  implementation in the Italian legislation of the European regulation related to Market Abuse (L. 62/2005) - and recommendations and clarifications included in the Consob Resolution 6027054 of March 28, 2006.

You can view the Internal Dealing Code of Conduct - in PDF format - updated on August 28,2008 and on February 23, 2012 and on July 29,2016 by clicking the following link:

• Internal Dealing Code of Conduct

You can view the Internal Dealing Filings - in PDF format - dated as from January 1, 2017 by clicking the following links:

• January 4, 2017

• September 19, 2017

• December 21, 2018 - S.G.G. Holding S.p.A.

• January 7, 2019

• August 13, 2020 - S.G.G. Holding S.p.A.

• May 18, 2023