It is strictly forbidden for the relevant persons and persons closely associated with relevant persons to perform purchase, sale, subscription or swaps transactions involving the shares of Unione di Banche Italiane and financial instruments associated with them, performed by themselves or by persons closely associated with them in the 20 days prior to meetings of the Management Board convened to approve the draft annual, half year and quarterly financial reports.

The prohibition does not apply to the exercise of rights granted under stock option plans nor to the exercise of option rights and the sale at the same time of the shares resulting from exercising those rights.

Exceptions to that prohibition may be granted by the Management Board if reasonable grounds exist.

The Management Board also has the power to forbid or limit the performance of transactions in the financial instruments involving the shares of Unione di Banche Italiane by relevant persons and persons closely associated with them in other periods of the year.