Internal dealing

Transactions and persons subject to the current regulations on internal dealing

In compliance with the discipline introduced at European and Italian levels, the regulation of internal dealing concerns the public disclosure of transactions (“Transactions”) regarding the financial instruments issued by Enel, as well as derivatives or other financial instruments linked thereto, carried out by Persons with Managerial Responsibilities (“PMR”) and certain categories of persons closely associated to them, as well as by Relevant Shareholders (i.e. anyone holding an equity interest equal to at least 10% of Enel’s share capital) and certain categories of persons closely associated to them.

PMR refers to Directors and Regular Statutory Auditors of Enel and, currently, 5 senior executives of the Enel Group (as specified, together with the names of Directors and Regular Statutory Auditors, on the on the attached list) who have regular access to inside information relating, directly or indirectly, to Enel and have the power to take managerial decision affecting the future developments and business prospects of Enel.

Taking into account the significant innovations cast by the new market abuse laws introduced at the European level, in March 2017, Enel’s Board of Directors deemed it appropriate to approve a specific regulation on internal dealing, which was subsequently amended and supplemented in July 2017 and September 2019.

Threshold

Internal dealing transparency requirements do not apply in the event of Transactions whose total value does not reach the threshold of 20,000 euros within a calendar year. With respect to PMR and persons closely associated to them, once the threshold is reached, all the transactions carried out in the calendar year shall be disclosed, regardless of their amount.

Black-out Periods

PMR shall not conduct, on their own account or on account of a third party, directly or indirectly, Transactions during the thirty calendar days before the date scheduled for the announcement of the data concerning the draft financial statements of Enel, the consolidated financial statements, and the half-year financial report of the Enel Group (the so-called “Black-out Periods”).

Any exception from the restrictions to trade during Black-out Periods may be granted on a case-by-case basis due to the existence of exceptional circumstances and, in any case, under the condition that the PMR is able to demonstrate that the particular Transaction cannot be executed at a moment in time other than the Black-out Period.

Transactions carried out after April 1, 2006

In accordance with the recommendations of Consob, the following is the list Enel presented to the market regarding the transactions subject to internal-dealing regulations that were carried out after April 1, 2006 by PMR and Persons Closely Associated to them.