The Board of Directors of Class Editori S.p.A., with a resolution dated September 28, 2023, updated the Code of Conduct for Internal Dealing (now referred to as the "Internal Dealing Procedure"), previously adopted by the Company on August 25, 2011.
The adoption of the Internal Dealing Procedure (the "Procedure") is instrumental in complying with the provisions of:

• Legislative Decree No. 58 of February 24, 1998 ("Consolidated Law on Financial Intermediation" also known as the "TUF"), as amended;
• Regulation adopted by CONSOB with Resolution No. 11971 of 1999, as amended ("Issuers' Regulation");
• EU Regulation 2014/596 on market abuse (Market Abuse Regulation "MAR"), as amended, and related implementing regulations.

The Procedure regulates the disclosure requirements for, and limits on, transactions involving the Financial Instruments of Class Editori S.p.A., carried out in any capacity by Relevant Persons and their respective Closely Associated Persons of the Company and its Relevant Subsidiaries (as defined in the Procedure).
In particular, all Transactions are subject to notification pursuant to the Procedure once the total amount set forth in Article 19, paragraph 8 of the MAR, or the different amount indicated from time to time by the Competent Authority pursuant to Article 19, paragraph 9 of the MAR, has been reached within a calendar year. In such cases, said amount and its subsequent adjustments are deemed directly applicable without the need for amendments to the Procedure. At the time of approval of the Procedure, the amount indicated in Article 19, paragraph 8 of the MAR was €5,000, but this amount was increased to €20,000 pursuant to Resolution no. 19925 adopted on March 22, 2017 by CONSOB.

More information about the Internal Dealing Procedure is available by downloading the document in Acrobat format.