Internal dealing

World Duty Free Group has defined an internal dealing procedure that applies to transactions involving financial instruments made by Relevant Persons and Persons with close ties to them and is designed to discipline the disclosure obligations and modes of conduct to be adopted by Relevant Persons and World Duty Free Group to ensure maximum transparency of information for the market.

The Italian legal system has received the European regulation regarding market abuse through the approval of Act no. 62 of April 18, 2005; trading in financial instruments by relevant subjects is currently regulated by the applicable laws on financial brokerage (D.L. 58/1998, as amended) and by the Regulation on Issuers enacted by the Consob (the Italian stock markets regulator) under no. 11971/1999, as amended. The WDF procedure has been adopted pursuant to section 114, par. 7 of D.L. no. 58/1998 and section 152, paragraphs six to eight, of the Regulation on Issuers.

The rules of the procedure approved by WDF are therefore legally binding and must be adhered to by all relevant subjects and by the persons closely connected to them.

Internal Dealing Procedure

Attached are communications relating to transactions, published by the Company compliant to the rules on internal dealing.