Neinor Homes S A : Informe sobre cumplimiento del RIC (solo disponible en ingles)

➢Rules of conduct regarding:

•

Transactions carried out on a party's own behalf

•

Inside information

•

Market manipulation

•

Treasury share transactions

➢Correspondence records and register of activities

a

Monitoring of the register of persons with permanent access to

inside information and of the register of persons with access to

inside information of a transaction or event.

Insider list

The Compliance Officer shall always keep the list of insiders

updated and shall keep the data for at least five years from the

date of its creation or its last update.

➢Register of covered persons and associated persons

➢Supervision of compliance with the internal code of conduct

This Code shall apply to:

Covered Persons:

Related Persons:

•

Members of the company's Board of

• Spouse or person deemed equivalent.

Directors.

• Dependent child.

•

Company's Senior Managers.

• Any other relatives that have lived with

• Secretary and Vice-Secretary of the Board

the Covered Person for at least one year

of Directors.

prior to the date on which a transaction is

• Managers and employees that perform

conducted.

their duties in areas related to securities

• Any legal entity in which the Covered

markets or that have regular access to the

Person or the Related Person hold a

Inside Information and, in any case, the

management position or is in charge of its

Declaration of

Model of

Confirmation of

Declaration of

receipt,

identification of

understanding and

adherence to the

understanding and

Internal Code of

related parties and

acceptance of

acceptance of NH'

Conduct (RIC) in the

conflicts of interest

inclusion in the NH

Code of Ethics and

securities markets

with NH

insider list

Internal Policies

of Neinor Homes

Who are the subject persons with access to privileged

Compliance Training and raising awareness in

contents

information and who should be part of the insider list

What is meant by Inside Information

November 2023 for all directors and employees.

Main obligations of the persons subject to or with access to

The Internal Code of Conduct in the securities

Training

Inside Information

markets is a part of the content of Compliance

Protocol for the management and dissemination of Inside

Training.

Information and other relevant information

Procedure for the management and dissemination of

economic-financial and corporate information

persons belonging to the financial, investor

management; or any that is/are directly or

relations, legal and business development

indirectly controlled by such person; or

departments.

that was created for his/her benefit; or

• Any other person included by decision of

whose financial interests are, to a great

the Secretary General.

extent, equivalent to those of such person.

• Any other individuals or entities that are

given this status under the legal provisions

in force at any given time.