The Company has adopted an internal dealing procedure, which governs disclosure obligations and the restrictions on transactions involving financial instruments issued by the Company, or derivative instruments or other financial instruments linked to them, carried out by relevant persons or specific categories persons closely associated with them.

The Company also adopts a code of conduct for significant shareholders governing transactions involving financial instruments issued by ENAV, or derivative instruments or other financial instruments linked to them, carried out by significant shareholders (i.e., shareholders with at least 10% of the capital of ENAV) or persons closely associated with them.