Market Profiles

RBC IS operates an omnibus account structure in this market under RBC investor Services Trust and segregated account structure under IS Bank S.A.

For further information or support around accessing this market, please contact your RBC IS representative.

BORSA ITALIANA S.p.A. 
The stockholders of Borsa Italiana S.p.A. include the main Italian banks as well as domestic and international institutional investors.

The company is responsible for the organisation and management of the Italian stock exchange, in particular to:

• oversee transaction activities
• define the rules and procedures for admission and listing on the market for issuing companies
• define the rules and procedures for admission intermediaries supervise listed companies disclosure

The markets and Borsa Italiana S.p.A. are supervised by Bank of Italy and CONSOB, who is responsible for the overall supervision of both regulated and unregulated markets. Borsa Italiana SpA pursues the development of regulated markets through the maximisation of liquidity, transparency and competitiveness. Market participants are domestic and international members, operating in Italy and from abroad through remote membership. Borsa Italiana is part of the London Stock Exchange Group.

The following shows the markets that are currently under the responsibility of Borsa Italiana SpA.

Equities: 
MTA is the main screen-based equities market it also included in two segments:

• STAR("Segmento Titoli con Alti Requisiti"): high standard mid-cap segment dedicated to companies with a market capitalization lower than 1 billion Euros, complying with specific requirements in terms of liquidity, transparency and corporate governance
• ETFplus– ETFplus is the regulated electronic market of Borsa Italiana fully dedicated to the trading of
  • ETFs (Exchange traded funds)
  • Structured ETFs
  • ETCs (Exchange traded commodities)

i.e. of the instruments that replicate the performance of indices (equity, fixed income and commodities) or single commodities.


At the end of 2014, Borsa Italiana launched the Open-end Collective Investment Undertakings (CIUs) segment on is ETF plus. 

Derivatives:
IDEM - The Italian Derivatives Electronic Market is the derivatives market for futures and options on indexes and single stocks. It started in futures on the MIB 30 index (FIB 30), with other option contracts on the MIB 30 index and future and option contracts on stocks progressively introduced afterwards.

IDEX - IDEX (Italian Derivatives Energy Exchange) is the segment of the Italian Derivatives Markets (IDEM) dedicated to trading of derivatives based on commodities and related indices.

Euronext Clearing, the Italian CCP, previously called Cassa di Compensazione & Garanzia (CC&G) is the central counterparty for all contracts executed on IDEX. Futures on electrical power delivered in Italy are negotiated on IDEX.

AGREX (Agriculture EXchange). new segment of IDEM market went live at the end of January in 2013

Listed derivatives futures contracts on durum wheat are traded in this new segment.

Euronext Clearing acts as Central Counterpart and has implemented new specific clearing procedures and risk management methodology to support the new product, particularly during the delivery phase (i.e. physical settlement, unless differently agreed between the parties).

The main features of the new future on durum wheat traded on AGREX are as follows:

• Maturity periods: March, May, September and December
• Number of contracts tradable: 5 maturities
• Size: 50 ton
• Pricing: in EUR per ton
• Tick size: 0.25 EUR per ton
• Trading hours: 14.30 - 17.40
• Settlement: physical settlement unless the parties agree on a different settlement methodology

Trading participants on AGREX will have to become members of the new segment at Euronext Clearing called Derivatives Segment on Agriculture Commodities

Other Instruments:
SeDeX (Securitised Derivatives Market) 
SeDeX is the Borsa Italiana market dedicated to the trading of certificates and covered warrants, collectively defined as securitised derivatives. 
SeDeX is a regulated market, subject to CONSOB supervision and disciplined by a set of clear and non-discretionary rules designed to protect investors. The SeDeX segments are the following:

1. Plain vanilla covered warrants- These are options which give the holder the right to receive at the date of exercise, in the case of a call CW, the difference – if positive – between the value of the underlying and the strike price (vice versa in the case of a put CW).
2. Structured/Exotic Covered Warrants- These are covered warrants whose main feature is a combination of options
3. Leverage Certificates- These are certificates tracking an underlying activity allowing an holder to participate to its performance with leverage
4. Investment Certificates- Class A: instruments which replicate in a linear manner the performance of the underlying asset; class B: instruments which embody a particular investment strategy.

MOT is the screen-based retail market for Government securities and non-convertible Bonds. All Government bonds can be traded in this market (BOTs, BTPs, CTZs, and CCTs) as well as bonds issued by private or government-owned companies. As of November 7, 2005 Euromot trades have been transferred to the MOT platform. Effective November 2010, MOT is a guaranteed market.

Borsa Italiana has created a single market for the trading of bonds, which is divided into two segments:

• DomesticMOT- It is where Italian Government Securities (BOT; BTP; BTPi; CCT; CTZ) and Debt Securities in euro or in a currency other than euro are traded.
• EuroMOT - It was launched in January 2000 for the trading of Euro-Bonds and Asset Backed Securities (ABS), foreign securities and other debt securities.

ExtraMOT - is the new multi-trading facility (MTF) managed by Borsa Italiana and dedicated to trading of bonds. Extra for the wide range of listed corporate bonds issued by Italian and foreign companies; Extra for the accessibility of information, through simple and comprehensive informative sheets for each listed bond.

In March 2013, Borsa Italiana launched with a new professional segment on its ExtraMOT market, dedicated to the trading of debt instruments issued by both listed and unlisted Italian companies.

The new segment, called ExtraMOT PRO, was launched to offer listed and unlisted Italian companies of any size a national market on which to benefit from opportunities arising from recently-implemented regulatory reforms (Decree-Law No. 83/2012).

ExtraMOT PRO is specifically targeted at professional investors.

Equity MTF market

The Borsa Italiana Equity MTF market has two segments:
• Borsa Italiana Global Equity Market segmet (BIt GEM)
• After Hours segment (TAH)

All shares and bonds are traded electronically through a continuous computerised system that links all securities houses.

Monday to Friday:

MTA Market

ISIN (International Securities Identification Numbering): Yes

Other: None

Commissione Nazionale per la Societa e la Borsa (CONSOB)
CONSOB was established following Law 216 of June 1974. CONSOB is an independent administrative authority responsible for regulating the Italian securities market.

Its activity is aimed at the protection of public investments and it supervises the stock exchanges, monitors market operating practices and regulates broker activities. It is responsible for investigating potential violations and has the legal powers to enforce regulations. CONSOB is also responsible for authorising all share listings and controlling public offerings.

CONSOB issues the code of behaviour, regulating the respect of confidentiality (rules inspired by other international markets), market transparency, the protection of all investor categories and the resolution of eventual conflicts of interest. It also conducts investigations with respect to potential infringements of insider dealing and market manipulation law.

In this scenario, CONSOB is responsible for verifying:

• transparency and correct behaviour of securities market participants;
• disclosure of complete and accurate information to the investing public by listed companies;
• accuracy of the facts represented in the prospectuses related to offerings of transferable securities to the investing public;
• compliance with regulations by auditors entered in the Special Register.

Bank of Italy
The Bank of Italy is the Central bank overseen by the Ministry of Treasury. 
Bank of Italy is a public law institution, responsible for supervising banking and financial institutions on all markets as well as for safeguarding competition in the financial market.

The Bank of Italy, together with CONSOB, is responsible for monitoring the activity and financial status of the market participants, including the correct observation and respect of all liquidity and risk coefficients. The Bank of Italy also oversees the wholesale market in Government Bonds as well as the operation of the futures and options markets. 

The Bank of Italy is part of the European System of Central Banks. In this environment, its function is to determine monetary policy decisions for the entire Euro area that will be implemented in the Italian money and financial markets.

Since January 1, 1999, all Government bonds securities are held in a dematerialised form. With effect from December 9, 2000, all Government Bonds, previously deposited at Bank of Italy, are deposited in Monte Titoli, which became the only Italian Central Securities Depository. 

Government bonds can not be in registered form; they are all deposited in the account the agent bank holds at Monte Titoli for further benefit of the client. 

Equities are issued in registered form. The registration process is no longer applicable for dematerialised securities which are only registered in the Monte Titoli book-entry system.

Borsa Italiana markets

• on shares traded on MTA the minimum quantity is 1 share
• on shares traded on AIM / MAC the minimum quantity depends on ISINs

on other instruments traded on EFT, Domestic MOT, SEDEX markets there are minimum tradable quantities that depend on the ISIN

Bond Wholesale Markets
(MTS Cash and Repo) settling in Monte Titoli, the minimum quantity is 2 millions.

For the purposes of the automatic control of the regularity of trading the following price variation limits shall apply:
a) maximum variation of the price of orders with respect to the control price:

• shares, warrants, rights, convertible bonds and shares of closed-end funds ± 90%;

1. b) maximum variation of the price of the contracts with respect to the control price:

• shares making up the FTSE MIB index ± 7.5%
• other shares and shares of closed-end funds ± 10%;
• warrants and rights ± 30%;
• convertible bonds ± 5%;

1. c) maximum price variation between two consecutive contracts:

• shares making up the FTSE MIB index ± 3.5%
• other shares, warrants and shares of closed-end funds ± 5%;
• rights ± 15%;
• convertible bonds ± 2.5%

1. d) for the financial instruments making up the FTSE MIB index (The FTSE MIB (Milano Italia Borsa) (the S&P/MIB prior to June 2009) the index consists of the 40 most liquid and capitalised shares of the Borsa Italiana Official list. FTSE MIB index is also the underlying asset of futures, mini-futures and options, listed on IDEM, the derivatives Market of Borsa Italiana. Companies which belong to FTSE MIB index are also traded After Hours), in the opening pre-auction phase of the expiry days of the derivatives traded in the IDEM market and of the revision days of the related baskets, the maximum variations in the prices of orders and opening auction prices with respect to the control prices shall be determined as follows:

• the maximum price variation referred to in subparagraph a) ± 10%;
• the maximum price variation referred to in subparagraph b) ± 5%.

EUR

Over-the-counter trading between brokers and other dealers is conducted via telephone Securities intermediaries are only allowed to execute orders outside the stock exchange on behalf of third parties. The application of the MIFID by the intermediaries ensures the best executions of client orders. Block trading is also allowed, however only under specific conditions and it is strictly regulated by the Italian authorities. 

Settlement Hours: Monday to Friday: 08:30 – 18:00 (normal banking working hours)

The Settlement Cycle

Transactions on Italian securities are settled with a rolling settlement on T+2 basis. Repo trades are settled on the basis of T+n.On Trade Date (SD -2) the trade is executed. Transactions executed out of the electronic market are called "off-exchange" trades. The two investors agree the details over the phone. Starting from trade date, the trading counterparts can send the instruction to their local custodian/ agent banks.

The Italian Settlement system migrated to Target2-Securities (T2S). Italian trades settle according to the rules of the platform. T2S Settlement system is composed of two different Settlement cycle:

The "Night Settlement cycle (NTS)" is composed by two cycles with four sequences each. At the end of each sequence and cycle T2S generates settlement confirmations and status updates. Any failing instruction at the end of the first cycle will be automatically processed in the second cycle. A window for partial Settlement is available in one of the fourth sequence of the second cycle. At the end of the NTS, a two hours maintenance window is available. Messages sent to T2S during this phase are processed after the maintenance window. 

The "real Settlement cycle (RTS)" is available for processing of new settlement instructions as well as trades that failed to settle in the night cycles. As during the NTS, T2S forsees two windows for partial Settlement. They are automatically activated on trades matched and released by both parties during specific windows: 10:00pm-10:15pm, 12:00pm-12:15pm 2:00pm-2:15pm and 3:45pm-4:00pm CET. A minimum partial threshold is set in the T2S static data with two options available:

• Threshold on the quantity: Defined by the issuer CSD
• Threshold on the countervalue defined by the Eurosystem and harmonised as follow:
• EUR 10,000 for equities
• EUR 100,000 for debts instruments

During the RTS, T2S allows to modify process and "hold and release" indicators and to cancel trades.

Unmatched settlement instructions remain valid in T2S for 20 working days, after that they are automatically cancelled by T2S while matched instructions remain valid for an unlimited period of time.

In T2S, matching of instructions is mandatory and occur as soon as the two legs are proposed in any of the Settlement cycle. The matching process is done on the mandatory matching fields, the additional ones and optional ones if populated:

Mandatory matching fields are:

Trade date 
It is always a mandatory field even for FOP transactions and, combined with additional matching fields, defines the eligibility of the underlying settlement instruction for market claims and reverse claims that will be automatically processed by T2S.

CSD of the delivering/receiving party
Participants will have to populate the place of Settlement field (PSET) in their instruction with the 11 BIC code of the CSD from which their counterparty will deliver/receive the involved securities directly or through an agent.

Settlement amount
T2S allows automatic matching between settlement instructions (DVP delivery versus payment and PFOD payment free of delivery) with different cash tolerances that are set at system level:

• EUR 2.00: trades countervalue equal or less than EUR 100,000
• EUR 25.00: trades countervalue greater than EUR 100,000

Additional matching fields:

Additional fields in T2S are non-mandatory. If quoted by one counterparty, though, they have to be populated with the same values by both parties (matching to "blank" is not allowed). Any discrepancy in the values quoted in the additional matching fields will prevent the trade from matching.
The two Additional matching fields that will be introduced in T2S are as follows:

Opt-out ISO transaction condition indicator 
The opt-out indicator is used to instruct the CSD whether a given transaction is eligible for the application of the corporate actions on flow (market claims, reverse market claims and transformations). Whenever this field is populated by both parties with "NOMC", the CSD will not activate the corporate actions on flow process regardless the other details of the trade.

Cum / Ex indicator
Cum/Ex can be used by trading counterparties to establish an entitlement outside of regular entitlement dates. The usage of the additional matching have been defined within a market practice agreed in November 2014. The full details of this market practice can be found under the below link:

http://www.lseg.com/sites/default/files/content/documents/MonteTitoli/area-download/express-ii/Market%20Practice%20-%20Additional%20matching%20field%20in%20T2S.pdf

Optional matching fields:
Optional matching fields are not mandatory and can match to "blank". However, any discrepancy in the values instructed by the two parties in these fields will prevent the trade from matching. The optional matching fields in T2S, which can be used to prevent mismatching, are listed in the below table.

Common trade reference
The two parties of a trade have to quote the same reference for a trade to match. Matching will occur even if one of the two parties leaves this field "blank.

Client of the delivering/receiving CSD participant
These are the so called "second layer matching fields", which allow automatic matching of the CSD participants' clients directly in T2S. In line with the market practice already agreed in Italy in April 2014, parties are requested to populate the relevant field with the 11 digit BIC code of their counterparty.

Securities account of the delivering/receiving party 
This is the securities account number (SAC) of the counterparty in T2S. In case this information is quoted, it becomes a matching criteria (in fact, the party T2S securities account is available in all instructions).

In addition to the above Settlement changes, T2S will introduce enhanced functionalities that can be used by market participants on an optional basis.

Hold and Release
A process which provides T2S participants with the functionality to hold and release settlement instruction at any time during their lifecycle until they are settled or cancelled.

Partial Settlement
It is a T2S process automatically activated during specific windows in the settlement day schedule. It is activated by default unless one of the 2 counterparties specifies the contrary using dedicated SWIFT field.

Priority 
Allow parties to set two levels of priority to their settlement instructions: normal and high. T2S uses priority levels in case several settlement instructions, belonging to the same ISIN code, belonging to the same account number.

Linkage and Pooling
Enable parties to link instructions together using dedicated SWIFT field. Settlement instructions can be pooled in T2S by using a pool counter. This is a common indicator for a number of instructions that have to be settled "all or none".

Cross Border in TARGET2-Securities
TARGET2-Securities (T2S) will contribute in harmonising and optimising the settlement process in Europe. Depending on where the two CSD participants involved in a trade hold their securities account there will be 3 different types of transactions in T2S:

• Intra-CSDwhen both parties hold their account with the same T2S participating CSD
• Cross-CSDwhen the delivering and receiving parties hold their account with two different T2S participating CSDs
• External-CSD when one of the two parties hold the account in a T2S participating CSD while the other settles through an account with a non-T2S CSD.

As from November 1 2012 the local short selling regulation changed bringing the treatment locally in line with the EU standards. , The main points of the EU Regulation can be summarised as follows:

• mandatory communication to the competent national authorities of individual net short positions on listed shares and government securities, which is triggered by reaching the threshold of 0.2% of the issuer's share capital - or of a certain amount for government securities. When a net short position on shares reaches 0.5% of the share capital, it must be disclosed to the public
• a ban on "naked" short selling, that is selling in the absence of availability of the securities, on shares and government securities
• a ban on assuming speculative positions on credit default swaps (CDSs) on sovereign issuers

The competent supervisory authorities for the purposes of applying the Regulation in Italy are Consob and the Bank of Italy. Both have created a dedicated page on their web-sites with all relevant information on this subject, including net short position reporting notification system, related user manual and exemptions for market makers.
Links to these dedicated web-pages are as follows:
Consob: http://www.consob.it/mainen/markets/short_selling/index.html
Bank of Italy: http://www.bancaditalia.it/sispaga/sms/short_selling

Back to back settlement trades can be supported by using the dedicated functionalities introduced by T2S (linkage and Pooling).

The Clearing of securities in Italy is managed by Cassa di Compensazione e Garanzia for equities, fixed income and LCH.Clearnet for domestic regulated markets (Fixed Income only).

Contracts concluded in the Italian Regulated markets are covered by a Central Counterparty (CCP) System to the following extent:

• Contracts concluded in the MTA, TAH, MIV, ETFPlus, Domestic MOT, IDEM and IDEX markets are guaranteed by a CCP System.The CCP function is carried out by the Cassa Compensazione Garanzia, which takes the counterparty risk starting from the execution of the contracts, acting as buyer towards each seller and as seller towards each buyer, and becomes the guarantor of the final settlement of contracts.
• Contracts concluded in the SEDEX, TAH (only for covered warrants and certificates), MAC and AIM Italia markets are not guaranteed by a Central Counterparty (CCP) System. Concerning ExtraMOT and EuroMOT both the domestic executions and executions settled cross the ICSD.
• Participation in the CCP for cash and repo contracts concluded in the MTS and EuroMTS markets (only Government Bonds and T-Bills) is optional. The CCP role is offered by both Cassa Compensazione Garanzia and LCH.Clearnet.
• Participation in the CCP for cash and repo contracts concluded in the Hi-Mtf and e-MID Repo markets is optional and Cassa di Compensazione e Garanzia offers the CCP role.

Cassa di Compensazione & Garanzia S.p.A (CCG) was established in 1992 with the purpose of guaranteeing market integrity, by intervening as a central counterparty and acting as guarantor for the execution of transactions on the IDEM market and by managing the Trading and Settlement Funds. 

In 2002 it extended its CCP role to the MTS market and in 2003 to the markets of Borsa Italiana as detailed above; at the same time, the Trading and Settlement Funds were abolished and the Default Fund was introduced. In 2000, Borsa Italiana SpA acquired the majority stake of the capital of the CC&G and has been the major shareholder.

In 2007 CC&G became part of the London Stock Exchange Group.

In 2011 CC&G has extended its services to the following Fixed Income markets: Domestic MOT, Hi-MTF and e-MID Repo.

In 2013, CCG extended its CCP services to the transactions executed on EuroMOT, ExtraMOT and HI-MTF to be settled in the ICSDs. 
By the end of November 2013, such Service was extended to transactions executed on EUROTLX and to be settled in the ICSDs.
The activity of CCG is regulated by Banca d'Italia and Consob who have also approved its regulations. 

The London Clearing House Limited and Clearnet S.A. have merged to form the LCH.Clearnet Group ("LCH.Clearnet"). Both LCH.Clearnet Limited (formerly LCH), and LCH.Clearnet SA (formerly Clearnet) are leading Central Counterparty Clearing Houses (CCPs) in Europe.

Monte Titoli is the Central Depository for all Italian securities. As part of Borsa Italiana Group, Monte Titoli has became part of the LSE Group through the merger.

Monte Titoli does not operate directly with the general public, but does so through banks and other intermediaries, which in turn maintain direct operational and administrative contact with their clients. Monte Titoli therefore has no knowledge of the identity of the effective investors or the scale of their respective security deposits. Monte Titoli maintains one custody account for each intermediary's proprietary position and one account for each intermediary's third party (client) positions. In addition, intermediaries can have a number of "Liquidatori" accounts to segregate the activity of each client.

The migration of the Italian market to TARGET2-Securities (T2S) was complete on August 31, 2015.

BIS is an international organisation which fosters cooperation among central banks and other agencies in pursuit of monetary and financial stability. The Committee on Payments and Market Infrastructures (CPMI) uses three common structural approaches, or models, to categorise the links between delivery and payment in a securities settlement system.

BIS Model 3 for the two net settlement cycles of EXPRESS II - a system in which securities and fund transfers occur on a net basis at the end of the processing cycle. 

BIS Model 1 for the real-time gross settlement system of EXPRESS II - a system in which there is a simultaneous transfer of securities and associated funds from the buyer to the seller. All transfers occur on a trade-by-trade (gross) basis with all transfers made via book entry. All transfers are final.

Due to dematerialisation of the Italian market, registration is not applicable.

Book-Entry: positions are adjusted automatically on settlement date through the subcustodian's omnibus account. Subaccounting records are maintained by the subcustodian in Monte Titoli. There are strict rules regarding the disclosure of beneficial ownership.

Physical: unlisted securities may be physical or dematerialised depending on the issuer and the local authorities' requirement.

The only securities requiring registration are the few remaining physical certificates and "Banche Popolari" (local bank) shares (to allow the possibility to attend the Annual General Meeting). As a general principle, registration must take place in the name of the final beneficiary of the securities. 

The endorsement of the physical certificates is handled directly by the subcustodian and it is not subject to registration by the issuing company (in Italy registration of shareholders is done upon specific corporate events). Upon proper client request, the endorsement is done on the back of the physical certificate, by applying the Company stamp for Endorsement, signed by two authorised signatures, and the date of the Endorsement.

Physical securities have to report the name of the final beneficiary.

N/A.

Share holdings may be required to be disclosed by the beneficial owner, particularly when holdings reach or exceed or fall below prescribed disclosure limits. Investors must ensure that they comply in full by reporting such holdings to the appropriate organisations for this market, within the timeframe required. If you have any questions regarding this issue we encourage you to consult your legal counsel. 

Failure to comply with reporting requirements may lead to penalties and/or other sanctions.

Anyone holding shares with voting rights in a listed company must communicate to CONSOB and to the issuing company:

1. when their investment exceeds the limit of 3% (the disclosure threshold for listed SMEs is 5%);
2. when their investment exceeds the limits of 5%, 10%, 15%, 20%, 25%, 30%, 35%, 40%, 45%, 50%, 66.6%, 75%, 90 % and 95%;
3. when their investment falls below the above threshold limits

There are two other scenarios where the disclosure could be requested:

1. The request of disclosure coming from a third party Proxy solicitation. Consob and Bank of Italy rules enacting the Shareholder Directive, effective from 22 January 2010 introduced the process of shareholder identification by third parties exercising their rights to solicit a proxy from other shareholders. "Third Party Proxy Solicitation" is the process by which a third party may solicit from shareholders their proxy to vote in a particular manner. The rules have simplified the procedures through which Third Party Proxy Solicitors can request identification of shareholders and have introduced a presumption of consent to disclosure, unless the shareholder has given express denial to identification. This means that non-resident clients with holdings may choose to not allow their identification
2. The request of disclosure coming from the issuing company: The rules enacting the Shareholder's Rights Directive in Italy (article 83-duocecies, specified in the Italian Financial Services Act through legislative decree No. 27/2010 to enact Directive 2007/36/EC) introduced a general assumption that investors agree for intermediaries to disclose shareholder names and holdings to an Italian issuer unless express denial to disclosure has occurred. Therefore, an Italian issuer can require an intermediary to disclose any shareholder information available in its records. Disclosure can also occur upon request of minority shareholders at certain conditions

Buy-ins exist in the Italian market only for those trades executed on-exchange. Not applicable for off-exchange transactions. Buy-ins may occur for on-exchange transactions that are against a CCP (Euronext Clearing or Clearnet).

Under Decree 5/5/2004, The Ministry of Economy and Finance has announced the introduction of penalties for auction trades, and repurchase and bond exchange operations that fail to settle on the settlement date (SD).

Euronext Clearing introduced changes to the existing buy- in rules in order to make them compliant with the new EU Short Selling Regulation. For cash equities markets and listed Derivatives the procedure provides that, should a trade not settle on the original settlement date due to a lack of securities, a buy-in notification is automatically sent by the Euronext Clearing to the failing counterparty on SD+1. The failing party has three additional days to settle the trade. Otherwise, in the evening of SD+4 the trade will be deleted from the system and in the morning of SD+5 the buy-in will be executed.

The buy –in rules on ETFs, convertible bonds, bonds and funds remained unchanged. For these instruments, should a trade not settle for three days following the original settlement date due to a lack of securities, a buy-in notification is automatically sent by the Central Counterparty to the failing party on SD+4. 
The failing party has three additional days to settle the trade. Otherwise, in the evening of SD+7 (currently defined as 7th "Market opening day" following the original settlement date), the trade will be deleted from the system and in the morning of SD+8 the buy-in will be executed.

Members who have not delivered the financial instruments for a given "end of validity date" are charged with a commission consisting of a fixed fee of EUR 1,000.00 plus a variable fee of 0.1% of the countervalue of the financial instruments purchased through the buy-in agent on each buy-in executed

Should a trade not settle on due settlement date due to a lack of cash, a sell out notification is sent by CCG to the receiving counterpart who is failing to settle on the morning of SD+1, requiring that the cash amount is covered by 10:00 on SD+1. Should the party due to receive the securities be unable to cover the cash requirement within this time, the CCG immediately initiates a sell-out process.

The sell out is executed by a broker appointed by the CCG. If the sell out agent is partially or wholly unable to execute the trade on the sell out date due to lack of demand on the market, they e-submit the sell order on the outstanding amount until 15:00 on SD+2, after which the CCG requires separate cash settlement. Euronext Clearing may postpone the terms of the Sell-Out, by notifying the postponement to the Member involved.

Any costs or losses associated with the buy-in or sell-out procedure will be charged back to the failing counterparty with any gains being kept by the Ministry of Finance.

When a participant fails to settle an auction, repurchase or exchange trade with Bank of Italy three times during the period of six months, the participant will not be able to take part in any Bank of Italy auctions, repurchase or exchange operations for 30 days from the first day of the third fail.

In T2S and following the introduction of the Buyer Protection, Euronext Clearing has also revised the procedure for the management of the buy-in by foreseeing that Euronext Clearing may postpone the buy-in execution in order to allow the exercise of the Buyer Protection.

Monte Titoli penalties
Effective September 1, 2011 a new penalty regime was introduced and systematically applied regardless of the performance of the settlement system. Also, penalties are applied on the countervalue of the net short positions per ISIN and no longer as a fixed amount. 

Net short positions are calculated as follows:

• Net short positions per ISIN code will be calculated per each Monte Titoli account as algebric sum of failed delivery instructions, failed receipt instruction and available position in the account.
• The calculation will be done each day at the closing of the RTGS, taking into account all trades failed in the system at that time for that value date (independently from the intended settlement date).
• The value of net short positions, on which penalties will be applied, will be calculated using the market reference price of the day before for listed instruments or the nominal value for non listed instruments (except for warrants and CW, that will be valued at 0.30 Euro in case of missing market price).

Penalties are calculated applying the following percentages for the different asset classes to the value of the net short positions calculated as above:

• 001% for corporate and government bonds
• 02% for all other securities (i.e. shares, warrants and ETFs)

Penalties are not applied when the value of the net short position is below the following amounts:

• EUR 5 Million for fixed income
• EUR 250,000 for other securities

The percentage of the penalties and the exemption thresholds might be changed by the Italian Authorities Bank of Italy and Consob. 

Under the new rules, " in bonis" net receipt positions in each ISIN is credited an amount equal to the amount of penalties collected for each ISIN and divided on a pro rata basis amount the in bonis participant less administrative costs. Also in this case the net receipt position is calculated per each Monte Titoli account. 

Failed trades involving pre-emptive rights
With the migration of Monte Titoli's settlement system from EXPRESS II platform to the T2S platform, and the application of international standards in the management of corporate actions, Borsa Italiana and Euronext Clearing have revised the respective rules and, following a consultation with market and post trading participants, they intend to change their provisions.

The Buyer Protection allows the in-bonis purchaser of securities, which has acquired the right to elect on a corporate action and has a pending matched trade on record date of the corporate action, to benefit of the full range of available options regardless of the default choice of the event, by instructing the in-malis seller. The current fails' adjustment management are abolished. In this regard, no longer expected cash will occur settlement in case of non-settlement of contracts fail on rights option and the only protection for the in-bonis counterpart is the exercise of the Buyer Protection. The market practice for the Buyer Protection's management is still to be finalised.

Charges
With regards to Bank of Italy Auctions, should a trade fail on SD due to short cash positions, the Bank of Italy will apply a penalty to the failing counterparty which comprises of the following fixed and variable fees:

• Fixed fee of EUR 500 per day for each day the trade fails
• Variable fee using the Central European Bank's refinancing rate of +5% on the first day and +10% on the second to fifth day.

In the situation where a counterparty fails to settle an agreed exchange or repurchase operation in Central Government Bonds with the Bank of Italy as a result of a short security position, the Bank of Italy will apply a fixed penalty to the failing counterparty of EUR500 per day for each day the trade fails.

All securities listed on the Italian stock market are eligible for lending. Commercial banks and other market participants also offer securities lending and borrowing facilities.

CCG Member Default 
In its role as central counterpart, the CCG covers the losses generated by the default of a CCG participant by applying (in order):

• Margins paid by the defaulting members (initial margins and the contribution to the default fund of the defaulting party)
• CCG assets to a value of 5 million Euros
• Remaining default fund (applied on a loss sharing principle)
• Remaining CCG assets.

The overall amounts of the Default Fund are the following:

• Shares and Equity Derivatives Default Fund: EUR 1,200 million
• Bond Section: EUR 3,300 million
• Energy Derivatives EUR 5 million
• Agricultural Commodities Derivatives EUR 0.45 million

In order to implement the third AML Directive 2005/60/CE in Italy, the Law Decree 21st November 2007, no. 231 was introduced.

Law Decree 231/2007 substantially modified Italy's anti-money laundering legislation with the introduction of a more active role for banks in the fight against money laundering and terrorist financing, focusing on three main aspects, through a risk based approach:

• Know Your Customer (KYC)
• Collecting and keeping records of customers' information and transactions
• Reporting of suspicious transactions

Other obligations covered by the LD 231/07 are: mandatory employee training, limit to the use of cash transactions, etc.

After the introduction of the decree 231/2007:
The Italian Ministry of Finance published a "white list" of countries with equivalent legislation on AML.
Bank of Italy further introduced the secondary Regulation with detailed obligations and instructions for banks and intermediaries on AML rules among which the regulation on the mandatory institution of an AML Function for Financial intermediaries.

For clients serviced out of certain locations this is an FII market. Please refer to the Terms & Conditions for Global Custody or contact your RBC Investor Services' Client Manager before making portfolio investments.

There are limitations concerning how much a foreign investor can hold of banks and Insurance companies. All other types of companies establish their foreign ownership limits.

Profits, capital and income can be repatriated freely. Non-residents open external Euro accounts to facilitate securities settlements and foreign exchange transactions.

N/A

Eur high value payments are executed though EBA CLEARING and TARGET2

EBA CLEARING was established in June 1998 by 52 major European and international banks with the mission to own and operate the EURO1 large-value payment system.
Today EBA CLEARING counts 64 shareholder banks and offers payment services to a wide community of banks in the European Union

Payments processed through EURO1 are irrevocable and with immediate finality. Following the cut-off of EURO1, the final positions of banks participating in the system are settled via the European Central Bank. EURO1 enables its participants to send and receive payment messages in a technological and legal environment that fulfils the banks' requirements for efficiency and security in transaction processing and liquidity usage. The EURO1 settlement uses the Ancillary System Interface, module 4 (ASI 4) of the TARGET2 system.

TARGET2 is the real-time gross settlement (RTGS) system owned and operated by the Eurosystem. TARGET stands for Trans-European Automated Real-time Gross settlement Express Transfer system. TARGET2 is the second generation of TARGET. Payment transactions are settled one by one on a continuous basis in central bank money with immediate finality. There is no upper or lower limit on the value of payments. TARGET2 mainly settles operations of monetary policy and money market operations. TARGET2 has to be used for all payments involving the Eurosystem, as well as for the settlement of operations of all large-value net settlement systems and securities settlement systems handling the euro. TARGET2 is operated on a single technical platform. The business relationships are established between the TARGET2 users and their National Central Bank. In terms of the value processed, TARGET2 is one of the largest payment systems in the world.

Yes, cash overdrafts are permitted in the Italian Market.
The Bank may, at its sole discretion and without any obligation to do so, grant to the Client overdrafts on the cash account on a case by case basis. Any overdraft is immediately due and payable to the Bank and the Bank may at any time request the Client to credit sufficient cash to the cash account to ensure that, after such payment of cash, the balance of the relevant cash account is at least equal to zero. Any tolerance by the Bank of an overdraft shall not oblige the Bank to allow further or additional overdraft.

The first payment value date in the Italian Market is ex date+2

• On ex-date + 1 (evening) Monte Titoli automatically calculates the gross dividends based on the settled positions as of ex date+1 close of business (excluding any positions for which a delayed dividend payment has been requested, please refer to special procedure explained at the end of this section).
• On ex-date + 2 subcustodian receives the gross dividend payment on the final entitled positions as of ex-date +12 (deducting any suspended amounts).
• The net dividend amounts is credited upon receipt for direct accounts (positions belonging to a single final beneficiary), according to the proper relief-at-source documentation on file.
• Dividends proceeds for all direct accounts meeting one of the above conditions for all clients' accounts (fixed tax rate, no breakdown required) are credited net of tax on ex-date+2 with value ex-date + 2.

In case of omnibus account (position belonging to multiple final beneficiaries in the same account) subcustodian should receive a breakdown of the final beneficiaries no later than ex date + 3. The net dividend proceeds for omnibus positions is credited no later than 3 business days of receipt of the final beneficiaries breakdown information, provided that the reported positions reconcile with the total entitled position of the account.

Annual or twice a year. This depends on what has been proposed by the Board of Directors to the shareholders meeting. It is also possible that a Company decides not to distribute any dividend.

Annual or semi-annual or quarterly.

Italian bonds underwent a reconvention (i.e. the modification of the interest accrual calculation). Interest accrues on a 360 basis for money market instruments and actual/actual for bonds.

Corporate actions information can be found from "IL SOLE 24 ORE" and "MILANO FINANZA"(Italian financial newspapers), notifications retrieved from Borsa Italiana S.p.A. website (the Italian Stock Exchange) and Monte Titoli (the Central Depository) on a daily basis.

Impact of T2S on Corporate actions:
Corporate Actions "on stock" means events processed by the Italian CSD based on the eligible securities position existing on record date. The Italian CSD will continue to apply proper corporate actions management rules that will be consistent with the standard defined in the Corporate Actions Joint Working Group (CAJWG). T2S will not have any direct impact on services for corporate actions on stock.

In T2S, Corporate Actions "on flows" were introduced on 23/01/2017 on the Italian market. This means events processed by the Italian CSD on pending trades failing across record date of an event or settled "cum" instead of "ex". The Italian CSD is automatically creating compensation trades in order to allocate the proceeds (stock or cash) to the entitled counterparty or amend trades to change the terms of a fail transaction according to the corporate action features. A description of the Corporate Actions on flows is provided here below:

Market claims 
They areapplicable to distribution events (i.e. bonus issue and dividends) for a detection period of 20 days after record date. Pending matched transactions at the end of record date are kept unchanged and a cash/security transfer to the entitled party is generated for the amount/quantity of the proceeds.

Reverse market claims 
To adjust fails trades across entitlement date for corporate actions reverse market claims has been introduced. They are applicable based on transactions settled within record date with some "ex" details (e.g. the trade date), on close of business of record date a reverse claim is generated to return the cash/stock proceed from the buyer to the seller.

Transformations 
Transformations are applicable to fails trades across entitlement date for corporate actions such as reorganization events (i.e. merger, mandatory conversion).
Pending transactions at the end of record date are cancelled and replaced by new transactions with details amended according to the type of corporate event.

Unrestricted voting rights.

For shareholder meetings of listed companies, shares are not blocked (with the exception of a little number of limited co-operative companies, i.e. Banche Popolari). Voting rights are based on the amount shares held on record date.

The record date has been set at seven business days before the meeting for listed companies. Therefore, shareholders who wish to attend a meeting must hold positions in the relevant securities at that time. Instructions received until record date is kept in a pending status and processed starting from the day after record date.

For non-listed companies and for above described exceptions, shares are blocked until the meeting date and the record date is not applicable.

Provided in English. Meetings' agendas are sent via swift message within 24 hours from the day of publication. Meeting agendas are also available on our web-site through a dedicated username and password on "Custody Services Online".

A shareholder or a group of shareholders who hold at least 2.5% of the issued stock capital, have the right to add items to the meeting agenda.

Produced within the day after the meeting.

Upon request, usually only available in Italian.

Required.

• It is important to note that the name included on the meeting communication is the name that will be registered in the books of the issuing company.
• Electronic voting has been introduced.
• Issuers have the ability to appoint an independent third party to represent shareholders who are unable to attend a meeting.
• It is possible for proxy solicitors to require intermediaries to disclose the identity of account holders in order to contact them asking to vote as per their suggestion. However, a shareholder's right to confidentiality will be safeguarded with the right to refuse disclosure. We have foreseen a permanent denial disclosure form tobe used by clients in each case of proxy solicitation.
• Amended Law Decree, "anti-takeover clause", which grants banche popolari the power to include in their by-laws a limit on the exercise of voting rights in their meetings. Banche popolari can set a minimum cap of 5% to the voting rights of each shareholder, regardless of the number of shares held. Any limit to the shareholders voting rights applies for a maximum period of 24 months.

The recently introduced rules on shareholders voting rights in the Italian legislation with The Competition Decree (Law decree no. 91/2014) enable listed companies to grant increased voting rights to a maximum of two votes for each share held by the same shareholder for a continuous period of at least 24 months. Such period of times starts from the date of registration of such holding in the dedicated shareholders' list maintained by the issuing company.

The terms and conditions to grant the vote increase and include the shareholders' names in the shareholders' list are defined in the bylaws of each issuer.

Withholding tax is automatically applied on dividend payments distributed to non-resident investors as follows:

• 26% on ordinary, preferred shares and saving shares in registered form
• 26% on saving shares in bearer form

The ordinary tax rate on Financial income increased to 26% from 20% effective July 1, 2014.

Beneficiaries who are resident in countries that have a Double Taxation Agreement in place with Italy are eligible for a reduced withholding tax, as foreseen in the specific DTA, when the rate indicated in the DTA is lower than the standard rate.

A reduced withholding tax rate of 1.2% (1.375% prior to January 1, 2017) is applied to non-resident investors fulfilling the qualifying criteria:

• The entity must be residents in any European Union Member State or in any European Economic Area (EEA) country included in the new White List.
• The entity must be subject to corporate income tax in its country of residence.

This reduced withholding rate is applicable to dividends paid out of profits accrued from fiscal year 2008 (for calendar year issuers).

The 11% tax rate applicable to documented Pension funds EU countries included on the Italian White List has been reintroduced.
The new tax rate is applicable to dividends effective July 29, 2009 subject to the following main conditions being met:

• The dividends must be paid to entities set up as pension funds.
• The pension funds must be resident for tax purposes in an EU Member State or in an European Economic Area (EEA) country included in the White List.
• The pension fund is subject to supervision pursuant Directive 2003/41/EC in its country of residence.

Italian Real Estate Investment Fund
Law decree 78/2010 introduced a 26% withholding tax applicable to all foreign residents receiving income from the participation in Italian Real Estate Investment Funds. The Italian Parliament decided to mitigate its effects by providing the possibility of exemption for some foreign eligible investors. 
More precisely, the rule provides for the total exemption on income paid to:

• Pension funds and investment funds established in "White List" countries
• International bodies exempt from tax under international laws and agreements enforced in Italy
• Central banks or bodies managing the official reserves of the country
• Collective investment vehicles established in White List Countries

In order to be entitled to the exemption, the above mentioned investors need to provide:

• Self Declaration REITs v 2015 duly filled in, signed and stamped by authorised signatories.
• An attestation issued by a supervisory body certifying the supervision under the beneficiary's home country regulations. For this purposes, Assogestioni (Italian Asset Manager Companies Association) clarified in its Circular Letter n 121/2012 that it is enough to obtain the letter sent by regulatory body to the beneficiary authorising the start of the regulated activity (e.g., the authorisation to act as a pension fund/investment fund).

Then other subjects eligible to exemption are:

• A State included in the White List or a public entity established in a White List country
• Insurance companies established in a White List Country and subject to supervision
• A financial institution established in a White List Country and subject to supervision

In order to be exempted the above entities must provide the form Self Declaration REITS 2015 II and for the latter two entities also the attestation issued by a supervisory body certifying the supervision under the beneficiary's home country regulations.

In addition, the same law provision foresees the possibility to grant treaty benefits to beneficiaries resident in those countries having signed a double taxation agreement with Italy. In the absence of a specific provision, the income paid out by the Italian Real Estate Investment Funds will be considered as "interest" and the rate applicable will be the one indicated in the relevant article of the treaty (article 11). 

Capital gains arising from the trading of listed Italian Real Estate Investment Funds are tax exempt for all non-resident investors.

Government bonds:
Withholding tax rate is 12.5%
Exemption on government bond withholding tax is available to eligible foreign investors resident in a country included in the "White list" (official Italian Ministry of Finance's list of countries granting an adequate exchange of information between tax authorities). The exemption is subject to the submission of the self-certification form that has no expiry date. Please contact RBC Investor Services for full details.

Non resident investors are exempt on Capital Gains Tax on Italian listed security. If not listed security, the standard rate of 26% applies except for Government bonds which remain at 12.50%. 

The Law Decree 461/97 identifies two major categories of capital gains from financial instruments: those arising from the disposal of significant holdings and those arising from the disposal of non significant holdings.
The definition of significant holdings is based on the following thresholds being exceeded:
Voting rights in ordinary share capital – 2% listed, 20% unlisted shares. Total holdings – 5% listed, 25% unlisted shares.

The tax treatment is remarkably different in case the investor is holding a "significant participation" in a company's stock capital. The following types of securities must be considered in the determination of a "significant holding" for each issuer:

• number of shares (excluding saving shares) in circulation
• number of warrants
• number of convertible bonds
• number of rights

A calculation of the share-equivalent amounts of the non-share instruments must be made by using the conversion ratios inherent with the specific instrument.

As soon as the "significant" holdings threshold is exceeded, the calculation and payment of the capital gain taxes is no longer effected by the Italian intermediary. The responsibility to communicate that the threshold has been exceeded is up to the final investor. In particular, if an investor's relevant positions are held through more than one Italian intermediary, the communication of having exceeded the "significant" holding threshold can be made only by the investor to all the involved intermediaries. 

In such event, the investor is obliged to fulfil a Tax Revenue Declaration and submit it to the tax authority and in case pay the capital gain tax (if any) associated to the disposal on such significant holding position. It is requested that the position is segregated in a dedicated account under the "tax return" regime. The intermediary does not calculate any capital gain tax but report the trading activity to the tax authority on an annual basis.
In case the investor is documented for relief at source purposes, the above requirement is not needed and the investor will be totally tax exempt even on significant positions.

In order to benefit from the exemption on unlisted securities, investors resident in DTA countries with exchange of tax information should complete a tax exempt application form (self certification). For investors resident in DTA countries without exchange of tax information should complete Form 1 duly legalised by the foreign tax subsidiaries.

Non-residents are exempt.

Stamp duties on communication issued by intermediaries and concerning securities deposits are applicable.

A tax on financial Transactions was introduced for the Italian market. The tax is applied on Shares, Derivatives and HFT – High Frequency Trading. 

IFTT on shares (Effective date 1st of March 2013)

1. The IFTT on shares applies on the transfer of ownership of:
   • Shares and other participating financial instruments provided that the issuer is resident in Italy.
   • Securities representing shares and other participating instruments issued by companies resident in Italy, regardless of the place of residence of the issuer of the certificate and of the place where the transaction is executed (reference is made to ADRs and GDRs).
2. The tax is due by the purchaser (i.e.: the transferee), regardless of its place of residence and where the trade is executed ("taxable party"). Banks and other financial intermediaries (even non-resident) involved in the execution of a transaction are responsible for the collection and payment of the tax ("liable party"). In the event that several financial intermediaries are involved, the payment duty falls on the party that receives the order to execute the transaction directly from the purchaser. 
   If no financial intermediary is involved, the purchaser shall pay the tax directly.
3. The taxable base, which has to be determined for each individual taxpayer, is the net daily balance of the purchase and sale transactions settled on the same day and on the same financial instrument.
4. The tax rates applied on the value of the transaction are as follows:
   • 2% for transactions executed outside Regulated Markets or MTFs
   • 1% for the transfers of ownership that occurs as a result of a transaction executed on a Regulated Market or MTF. 
     Only for 2013, the above rates are increased as follows:
   • 22% for transactions executed outside Regulated Markets or MTFs
   • 12% for transaction executed on Regulated Markets or MTFs

IFTT on Derivatives (Effective date 1st of September 2013)

1. The Italian FTT on derivatives applies to:
   • Transactions on derivatives, whose underlying assets are mainly IFTT taxable shares or whose value depends mainly on IFTT taxable shares
   • Transactions on any other financial instrument, allowing to purchase or sale mainly IFTT taxable shares or involving a cash settlement determined with reference mainly to IFTT taxable shares.
2. The tax is due by each party (i.e. final purchaser and seller) involved in the transaction regardless of their place of residence and where the transaction is concluded. Banks and other financial intermediaries (even non-resident) taking part in the transaction are responsible for the payment of the tax (i.e. liable parties).
3. The IFTT on derivatives is a fixed amount that depends on the type of contract and the notional value and for transactions executed outside Regulated Markets and MTFs is determined according to the following table:

The amount of the tax is reduced to one fifth (20%) of the above for transactions executed on Regulated Markets or MTFs. An investor purchasing or selling derivatives on a Regulated Market or MTF through an intermediary can also benefit from the reduced tax amount provided that, the trade between the final investor and the broker and the one executed on a Regulated Market or MTF have the same price, total quantity and settlement date. 

Art. 9 of the Decree provides specific guidelines on how to calculate the notional value of the different types of derivative contracts impacted by the tax and in case it cannot be determined it is considered equal to EUR 2 million.

With regard to the exercise and assignment of derivatives, the Decree specifies that the resulting transactions on underlying shares or similar instrument are subject to the 0.2% tax rate. The authorities have clarified that for 2013 the applicable tax rate to these transactions will be 0.22%. 

IFTT on High Frequency Trading (Effective date 1^st March 2013 for equities and 1^st September 2013 for derivatives) 

Taxable orders

According to article 12 of the IFTT implementation decree, a trading activity is deemed to be high-frequency when orders are automatically submitted, amended or cancelled by a computer algorithm within an interval lower than 0.5 seconds.

The following activities are excluded from the definition of HFT computer algorithms used to: 

• Carry out market making activities, provided that the orders submitted are generated by "market making dedicated desks"
• Solely transmit client orders to comply with the best executionrules foreseen in the MIFID Directive or in the equivalent regulation of other countries.

The explanatory memorandum clarifies that smart order routing algorithms as well as those algorithms that submit orders to execute transactions at a price equal to or better than the weighted average price observed during a pre-defined period of time that can not exceed the day in which the order is submitted are also excluded. 

The FTT on High Frequency Trading (HFTT) is applied to modified or cancelled orders on shares, other participating instruments, securities representing equity investments and securitized derivatives when they are sent to any Italian Financial Market. These are defined as Regulated Markets and Multilateral Trading Facilities authorized by CONSOB pursuant to Articles 63 and 77-bis of TUF (i.e. Italian Financial Code).

It is currently under discussion whether the HFTT will be applied on orders on all the above mentioned types of financial instruments, even though they are not in scope of the IFFT on shares or IFTT on derivatives. The only requirement seems to be that the orders have to be submitted to a Regulated Market or MTF authorized by Consob. 

Taxable and liable party

The HFTT is due by the entity that sends purchase and sales orders as well as modifications and cancellations through a computer algorithm. In other words, the taxable party is the entity on behalf of which the shares would be purchased or sold if the orders were executed.

As defined for the IFTT on shares and derivatives, banks and other financial intermediaries (even non-resident) taking part in the order execution are responsible for the payment of the tax. 

Liable parties calculate the HFTT separately for each taxable party and if a taxable party carries out HFT activity through more than one intermediary the tax is paid separately by each of them. 

Taxable base

The HFTT is triggered when, in any trading day, the ratio between cancelled or modified orders and orders submitted on any financial instrument exceeds 60%. Only previously submitted orders that are cancelled or modified within 0.5 seconds are considered for the calculation of this ratio. 

For orders on shares and similar securities, this ratio is calculated dividing the number of shares of modified or cancelled orders by the number of shares of submitted or modified orders. For orders on derivatives, however, the ratio is calculated dividing the number of standard contracts of modified or cancelled orders by the number of standard contracts of submitted or modified orders 

The value of the cancelled or modified orders exceeding the above mentioned threshold of 60% is the taxable base.

The general consensus is that the HFTT applies on top of the IFTT on shares and derivatives and when a modified order is then executed, the resulting transaction is also in scope of the IFTT. Therefore, there might be situations where the modified order is subject to the HFTT and the executed transaction is IFTT eligible.

Tax rate

Under the conditions mentioned above, a tax rate of 0.02% applies on the value of the cancelled or amended orders in scope of the HFTT.

ITALY Holiday Calendar

• Italian Exchange borsaitalia.it
• Bank of Italy bancaditalia.it
• CONSOB consob.it
• Italian Competition Authority www.agcm.it