SEGREGATION AND PORTABILITY

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1 SEGREGATION AND PORTABILITY 19 th July 2013 Version 1.0

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3 Contents 1. Introduction 4 2. New account structure 5 3. The individual segregated account (ISA) 6 4. Omnibus accounts 7 5. Non-Clearing Member registered in an omnibus account (Main Omnibus) 9 6. Reports and Data Files for the Clearing Member 9 7. Portability Fee structure Appendix Reports Data Files 18

4 1. Introduction The new European regulation EMIR provides, in Article 39, that the CCPs should offer their Clearing Members the ability to record positions and assets (cash and securities) of their clients 1, separately from their own, in: a. omnibus accounts (omnibus segregation), or b. segregated accounts (segregation for individual client). The Article 48 of the same regulation also establishes that the CCPs, in case of default of one of their Clearing Members, must be committed to trigger procedures for the transfer of assets and positions of the defaulting Clearing Member s clients - recorded in the accounts indicated above at points a and b to another Clearing Member (so-called: portability). For both types of segregation above, portability will be possible only in the presence of a contractual agreement between the clients of the defaulting Clearing Member and another Clearing Member, called Designated Clearing Member. It follows that the portability of an omnibus account will only be possible in case where all the clients belonging to that account subscribe to the agreement of portability with the same Designated Clearing Member. This situation may be difficult if the omnibus account contains numerous clients. Therefore, in order to facilitate the achievement of the agreements of portability, CC&G will offer to Clearing Members the possibility to open multiple omnibus accounts for recording positions and assets of specific groups of clients. For the omnibus accounts, the agreement of portability will have to be signed before the Clearing Member default occurs, while segregated accounts will be given a time window 2 after the default, to allow clients to achieve an agreement with the Designated Clearing Member. In cases of failure to reach agreements of portability or if the transfer to another Member fails for any reason, in accordance with the provisions of EMIR, CC&G will take all the measures permitted by its rules, including the liquidation of the assets and positions held by the defaulting Clearing Member on behalf of its clients. The information relating to the two types of account indicated above and the consequent functional implications are illustrated inside the document. 1 According to Emir, the client is a legal person linked to a Clearing Member by a contractual relationship that allows it to clear its transactions through the interested CCP and, therefore, that concept includes both the current Non-Clearing Members both the clients (legal entities) of the Clearing Member. 2 Not yet defined. 4

5 2. New account structure As mentioned in the introduction, CC&G will allow Clearing Members to open one or more individual segregated accounts (hereafter ISA), for the registration of positions and assets of individual clients in a segregated mode, and one or more omnibus accounts, for the registration of positions and assets of specific groups of clients. Within one of the omnibus accounts (hereinafter: Main Omnibus), will be possible to record the positions of Non-Clearing Members separately, in a House account and in a Client account. Therefore the new account structure of CC&G will be the following: Figure 1 5

6 3. The individual segregated account (ISA) The individual segregated accounts (ISA) will be introduced to allow Clearing Members to segregate positions and assets of individual clients, including Non-Clearing Members, in accordance with Article 39, paragraph 3, of EMIR. If the segregated client is a Non-Clearing Member, CC&G will open for it, into the Clearing System, two segregated accounts (a House account and a Client account) that will be managed in a totally segregated for the purposes of the positions, margins and assets (see e.g.1 in Figure 1). In the other cases CC&G will open only one account (see e.g.2 in Figure 1). The characteristics of the new ISA account that the Clearing Member will be able to open are described in the follow. Positions The Contractual Positions, at the time of registration in the account, will be netted with the Contractual Positions already registered in the same account and having the same characteristics. For Derivatives Sections, the allocation of positions in the account will be done through the use of the client code, now used for the registration of the positions in the sub-accounts. For Cash Sections, the allocation of positions in the account will be done at the Settlement Services through the use of an appropriate ced code that will be assigned to the Clearing Member. Margins Margins will be calculated according to the current methodology. Cash call The margins calculated will be compared with the assets deposited, on behalf of the client, in the related segregated account, under the current methodologies (initial margins will be covered by financial instruments and cash, while variation margins, premium and other liabilities, only by cash). In case of insufficient assets, a cash call will be made and the coverage will have to be guaranteed by the Clearing Member. 6

7 Assets in excess In accordance with the provisions of EMIR, any assets in excess (i.e. the assets that the Clearing Member will require from the client, in excess of those required by CC&G from the Clearing Member for the coverage of the contractual positions of the same client), must be deposited at CC&G. These assets will be registered in the segregated account as assets in excess (and they will not be used to cover margins due by the other clients or by the Clearing Member for its House account). The Clearing Member will be able to request the return of the assets in excess according to the current procedures (permanent request or, when necessary, by fax). The refund will be made by CC&G to the Clearing Member, which will be required to transfer the assets received to the interested client. Reports and Data Files The report related to the financial position will be the MS11 and the corresponding data file will be the DS07. These will contain information about the margins requested, assets (available, used and in excess), liabilities and cash calls. The report, while maintaining the structure of the current MS11 (except for the cash call that will be added in the last row), will function as the current MS01, in consideration of the fact that in the account will be recorded segregated assets and that the assets can also be deposited in excess of the quantity required by CC&G. There will be no changes in the data file DS07. Clearing functions on derivatives positions The clearing functions on derivatives positions registered in the segregated account (transfers of trades and positions, splitting, exercises, etc.) may be made through the existing Technological Infrastructure (BCS) that CC&G makes available to the Clearing Members of the Derivatives Sections. 4. Omnibus accounts In order to facilitate the achievement of the agreements of portability, CC&G will offer to Clearing Members the possibility to open more than one omnibus accounts for the recording of positions and assets of specific groups of clients. The following describes the characteristics of omnibus accounts that the Clearing Member shall open. Positions The Contractual Positions, at the time of registration in the account, will be netted with the Contractual Positions already registered in the same account and having the same characteristics. For Derivatives Sections, the allocation of positions in the account will be done through the use of the client code, now used for the registration of the positions in the sub-accounts. 7

8 For Cash Sections, the allocation of positions in the account will be done at the Settlement Services through the use of an appropriate ced code that will be assigned to the Clearing Member. Margins Margins will be calculated according to the current methodology. Cash call The margins calculated will be compared with the assets deposited in the related account under the current methodologies (initial margins will be covered by financial instruments and cash, while variation margins, premium and other liabilities, only by cash). In case of insufficient assets, a cash call will be made and the coverage will be guaranteed by the Clearing Member. Assets in excess The assets deposited by the Clearing Member to cover an omnibus account, even if they exceed the amount required by CC&G, will be used to cover that account (therefore they will not be used to cover the other omnibus accounts and/or the individual segregated accounts and/or the Clearing member's House account). The Clearing Member will be able to request the return of the assets in excess according to the current procedures (permanent request or, when necessary, by fax). The refund will be made by CC&G to the Clearing Member, which will be required to transfer to the interested clients the assets received. Reports and Data Files The report related to the financial position will be the MS11 and the corresponding data file will be the DS07. These will contain information about the margins requested, assets (available, used and in excess), liabilities and cash calls. The report, while maintaining the structure of the current MS11 (except for the cash call that will be added in the last row), will function as the current MS01, in consideration of the fact that in the account will be recorded segregated assets and that the assets can also be deposited in excess of the quantity required by CC&G. Instead, there will be no changes in the data file DS07. Clearing functions on derivatives positions The clearing functions on derivatives positions registered in the segregated account (transfers of trades and positions, splitting, exercises, etc.) may be made through the existing Technological Infrastructure (BCS) that CC&G makes available to the Clearing Members of the Derivatives Sections. 8

9 5. Non-Clearing Member registered in an omnibus account (Main Omnibus) For each Non-Clearing Member for which the General Clearing Member does not require the opening of ISA accounts, CC&G will: open two accounts (one House account and one Client account) which must be separately registered, within one of the omnibus accounts (Omnibus Main), the contractual positions on the basis of the information received in the trades; cover margins, relative to the positions recorded in the two accounts, with the assets deposited by the General Clearing Member to cover the Main Omnibus account; make available, with the approval of the General Clearing Member, the Technological Infrastructure (BCS and/or ICWS) for carrying out the clearing functions regarding the Derivatives Sections and for the distribution of reports and Data Files. The General Clearing Member may opt for recording the positions of the Non-Clearing Member in the above mentioned two accounts (House and Client referred to the Non-Clearing Member itself) or in the net section of the omnibus account (along with those of all the other clients). Reports and Data Files The Reports and Data Files related to the Non-Clearing Members registered in the Main Omnibus account distinctly from the other clients of the same account will be those already in use for the existing Non-Clearing Members with the only exception of the report MS11 (Financial Position) and the corresponding Data File DS07, whose relevant information 3 will be made available in the new report MS12 and in the corresponding Data File D07A. 6. Reports and Data Files for the Clearing Member The Clearing Member will receive the following reports: Report MS11 A report MS11, made out to the Clearing Member itself, which will report, in the column "House Account", the financial position related to the same Clearing Member s House account and, in the column "Client Account", the financial position relative to all clients (including Non-Clearing Members) of the Main Omnibus account. A report MS11, made out to each additional omnibus account (hereinafter: AOA), which will report the financial position related to the group of clients that are part of the same account; A report MS11, made out to each ISA account, which will report the financial position related to each individually segregated client. 3 Items: Initial margin, Futures variation, Options premium, E/A settlement, Cash adjustments/buy-in, Clearing Fees, Collateral Fees, Membership Fees/Clearing Services/Buy-In, Interest. 9

10 The report will maintain the structure of the current report MS11 (except for the cash call that will be added in the last line) and will operate as the current report MS01 in order to allow the segregated registration of clients assets. Therefore this report will provide information relating to margin requirements, liabilities, assets (used and in excess) and cash calls related to each part of the Client account (Main Omnibus account, AOA and ISA). However, there will be no changes in the corresponding data file DS07. Report MS12 The new report MS12, sent only to the General Clearing Members, will detail, within the Main Omnibus account (of the Client account), the financial position of the clients and of each Non-Clearing Member. Therefore, A report MS12, made out to the Clearing Member itself, will report the financial position relative to all its clients (excluding Non-Clearing Members) of the Main Omnibus account; A report MS12 will report the financial position relative to each Non-Clearing Member of the Main Omnibus account. The General Clearing Member may authorize the Non-Clearing Member to receive, through the Technological Infrastructure BCS/ICWS, the report MS12 related to the Non-Clearing Member itself. The corresponding Data File will be the D07A. Report MS01 The report MS01, unchanged from the current, will report; in the column House account, the indication for the debit/credit payment relative to the House account; and, in the column Client account, the indication for the debit/credit payment relative to the Client account, calculated as a sum of the cash calls relative to the Main Omnibus account, AOA and ISA, shown in all the reports MS11. Each individual item of the report will be obtained from the sum of the corresponding items of the reports MS11. Also the corresponding Data File DS05 will remain unchanged from the current. 10

11 The scheme below illustrates the new functioning of reports produced for the Clearing Member: Figure 2 7. Portability As indicated in the introduction, in the event of default of one of their Clearing Members, CCPs are required to initiate the transfer of the assets and positions of the defaulting Member s clients, registered in the segregated accounts and omnibus accounts, to another Clearing Member, defined "Designated Clearing Member". For this purpose, CC&G intends to use the following structure. Clients registered in the individual segregated accounts (ISA) CC&G will automatically perform the procedures for the transfer of the positions and assets where the segregated clients have previously notified the Designated Clearing Member to CC&G. 11

12 The notification of the Designated Clearing Member shall be effected by sending a form (which will be attached to the Instructions of CC&G), in which will be stated: The contractual relationship established with clients, pursuant to which the Designated Clearing Member undertakes to accept the assets and positions of the clients themselves; The accounts of the Designated Clearing Member dedicated to the settlement of positions at the Settlement Service. In the event that the client should assume the status of Non-Clearing Member, the above documents will be supplemented by the Agreement between the Non-Clearing Member itself and the Designated Clearing Member, the effectiveness of which will be deferred to the date of the default of the original Clearing Member. The notification of the Designated Clearing Member will be changeable at any time prior to the declaration of default of the Clearing Member and does not represent a necessary condition for the opening of the segregated account. Segregated clients, who at the time of the default of their Clearing Member had not already notified the Designated Clearing Member and the corresponding settlement accounts will be given a time window (to be determined) for providing it. If the client fails to reach an agreement with a Designated Clearing Member within the time period established, CC&G would consider the portability not practicable and would apply the other procedures for the management of the default. During the above mentioned time window: 1. The clients will become temporary Members of CC&G. CC&G will define the specific mode of communication with those Members who, on the occurrence of the default of the Clearing Member will be required to pay margins for their open positions. The margin payment, carried out in Central Bank money, could be carried out through a Settlement Agent identified by the same temporary Members; 2. In the event that clients do not proceed to the payment of margin requirements, CC&G will liquidate their positions; 3. After the closing of the positions not segregated, the Default Fund paid by the defaulting Clearing Member shall be retained by CC&G to guarantee the positions of the temporary Members until the transfer or liquidation of the relevant positions is concluded. Thus, in the face of the positions of the temporary Members, CC&G will be in possession of all types of assets necessary for the ordinary operation; 4. In the event that clients do not complete the documentation within the time window given, CC&G will proceed with the liquidation of the relevant positions. 5. Clients will be able to give up the possibility of integrating the documentation relating to the portability during the time window, giving timely notice to CC&G; in this case, CC&G will proceed with the liquidation of the relevant positions. Clients registered in the omnibus accounts As mentioned above, in order to facilitate the achievement of the agreements of portability, CC&G will offer to Clearing Members the possibility to open more omnibus accounts for recording positions and assets of specific groups of clients. The transfer of positions and assets of each omnibus account is subject to the fact that all the clients of that account have identified and notified in advance to CC&G, through the Clearing Member, the Designated Clearing Member. 12

13 The consent of all the clients of the omnibus account will be acquired by the Clearing Member and will notify CC&G. Even the signing of the agreement with the Designated Clearing Member is deemed to be borne by the Clearing Member, on behalf of its clients of the omnibus account. To this end, there will be an appropriate form for the signature of the agreements of portability between the Clearing Member and the Designated Clearing Member. The Designated Clearing Member, by signing this form, will confirm to accept the transfer of positions and assets of the clients of the Main Omnibus account of the Clearing Member and to have already established with the same clients a contractual agreement aimed at such transfer. The notification of the Designated Clearing Member may be given (and will be modifiable) at any time up to the declaration of default of the Clearing Member. Without an agreement with a Designated Clearing Member at the time of the declaration of the default of the Clearing Member, CC&G will consider that portability is not practicable and will apply the other procedures provided for the management of the default. With regard to the portability of the clients of the omnibus account, the reference to all of those clients, on their request, set out in Article 48, paragraph 5 of EMIR, must be understood to include all the clients of the relative omnibus account, without the possibility of a partial portability deriving from the opt-out by some of those clients. In the absence of the agreement of all the clients, the portability of the omnibus account in question may not take place. 8. Fee structure To be defined. 13

14 9. Appendix 9.1 Reports MS11 Financial Position The report shows the financial position of the Clearing Member, each segregated client (ISA) and each group of clients who have opted for the recording of their positions and assets within the same additional omnibus account (AOA), with the details of the items that contribute to the final result. This report is different from the current for the addition of the Cash call in the last line. Sample report MS11 MBR : GKK Financial Position RP-MS11 17 JAN 13 20:50:25 Pag. 1 Currency: EURO CASSA DI COMPENSAZIONE E GARANZIA Trade Date: 17 JAN 13 House Acct. Client Acct. Initial margin , ,99 Collateral value, , Cash Margin Call , ,91 Excess collateral,00,00 Other Activity Cash Margin Call,00,00 Cash held , ,62 Uncovered Initial Margin ,25,00 Cash Available, ,71 Realized liabilities Futures variation ,00DR ,00DR Options variation,00,00 Options premium, ,00DR E/A settlement,00,00 Cash adjustments/buy-in,00,00 Clearing Fees,00,00 Collateral Fees/Del.Payment,00,00 Mship Fees/Clearing Services/Buy-In,00,00 Interest,00,00 Net realized liabilities ,00DR ,00DR Excess cash held, , Cash call ,25DR,00 14

15 The report is produced for the Clearing Member, for each of its segregated clients, including the Non-Clearing Members (ISA accounts) and for each group of clients registered in the additional omnibus accounts (AOA). It is available before the start of trading; The report made out to the Clearing Member shows, in the column House Acct., the financial position related to the House account of the Clearing Member itself and, in the column Client Acct., the financial position of all its clients of the Main Omnibus account included the Non-Clearing Members (if present); for General Clearing Members only, the detail of the financial position of the clients, distinct from that of the Non-Clearing Members of the Main Omnibus account, is provided in the new report MS12 indicated below. The report made out to the segregated client, which different from a Non-Clearing Member, doesn t show any information in the column "House Acct.", while in the column "Client Acct." shows the financial position relating to the same segregated client. The report made out to the segregated client that is a Non-Clearing Member shows, in the column "House Acct.", the financial position relating to the House account and in the column Client Acct., the financial position relating to the Client account of the same Non-Clearing Member. The detail of all the items contained in the report MS11 will be provided in the following other reports: Initial Margin: Collateral value: Futures variation: Options variation: Options premium: E/A Settlement: Clearing Fees: Collateral fees: Mship Fees/Clearing Services: Interest: MS22, MSE2, MSE4, MS27, MS67, MS97, MSG1, MSG2, MSG4 MA01 MT55, MTE5, MTG5 MT05 MT05 MT02 MT36, MT37, MT47, MT48 MT48 MT48 MS05 MS12 Detail Financial Position Main Omnibus The new report MS12, sent to the General Clearing Members only, provide the detail of the financial position of the clients and of each Non-Clearing Member of the Main Omnibus account of the General Clearing Members themselves. The aggregated data is provided in the column "Client Acct." of the report MS11 made out to the General Clearing Member. 15

16 Sample report MS12 Mbr: GKK Detail Financial Position Main Omnibus RP-MS12 17 JAN 13 20:50:25 Pag. 1 Currency: EURO CASSA DI COMPENSAZIONE E GARANZIA Trade Date: 17 JAN 13 House Acct. Client Acct. Initial margin , ,99 Realized liabilities Futures variation ,00DR ,00DR Options variation,00,00 Options premium, ,00DR E/A Settlement,00,00 Cash adjustments/buy-in,00,00 Clearing Fees,00,00 Collateral Fees/Del.Payment,00,00 Mship Fees/Clearing Services/Buy-In,00,00 Interest,00,00 Net realized liabilities ,00DR ,00DR The report made out to the General Clearing Member shows in the column "House Acct." the financial position relating to the House account of the General Clearing Member itself and in the column Client Acct. the financial position relating to all its clients of the Main Omnibus account, excluding the Non-Clearing Members. The report made out to the Non-Clearing Member shows the financial position in House account and Client account relating to the Non-Clearing Member itself. The General Clearing Member may authorize the Non-Clearing Member to receive, through the Technological Infrastructure BCS / ICWS, the report MS12 relating to the Non-Clearing Member itself. The detail of all the items contained in the report MS12 will be provided in the following other reports: Initial Margin: Futures variation: Options variation: Options premium: E/A Settlement: Clearing Fees: Collateral fees: MS22, MSE2, MSE4, MS27, MS67,MS97, MSG1, MSG2, MSG4 MT55, MTE5, MTG5 MT05 MT05 MT02 MT36, MT37, MT47, MT48 MT48 Mship Fees/Clearing Services: MT48 Interest: MS05 16

17 MS01 Daily Summary The report shows the final debit/credit amount for the Clearing Member and the details of the various items that contribute to the final result. Sample report MS01 Mbr : GKK Daily Summary RP-MS01 17 JAN 13 20:50:25 Pag. 1 Currency: EURO CASSA DI COMPENSAZIONE E GARANZIA Trade Date: 17 JAN 13 House Acct. Client Acct. Initial margin , ,99 Collateral value, , Cash Margin Call , ,91 Excess collateral,00,00 Other Activity Cash Margin Call,00,00 Cash held , ,62 Uncovered Initial Margin ,25,00 Cash Available, ,71 Realized liabilities Futures variation ,00DR ,00DR Options variation,00,00 Options premium, ,00DR E/A settlement,00,00 Cash adjustments/buy-in,00,00 Clearing Fees,00,00 Collateral Fees/Del.Payment,00,00 Mship Fees/Clearing Services/Buy-I,00,00 Interest,00,00 Net realized liabilities ,00DR ,00DR Other Activity Net Realized Liabilities,00, Excess cash held, , Cash call ,25DR,00 The report is produced for the Clearing Members only and is available before the start of trading; The amounts indicated in the column "Client Acct." are calculated as the algebraic sum of the corresponding items of all the reports MS11 of the Clearing Member, relating to its accounts Main Omnibus, AOA and ISA. The amounts indicated in the column "House Acct." are the same as those indicated in the same column of the report MS11 made out to the Clearing Member. 17

18 9.2 Data Files DS05 Daily Summary Corresponding reports: Send phase: Data File ID: MS01 Daily - post batch DS05 Record Length: 353 Content: Contains the daily settlement financial information related to the activity of each Clearing Member Description Len Type Notes Date 8,0 N Format yyyymmdd ABI code 5,0 N Account 1 A See Annex Initial margins 17,2 N Collateral guarantees avail. 17,2 N Initial margins integration 17,2 N Excess collateral guarantees 17,2 N Cash deposited c/o CC&G 17,2 N Uncovered Initial margins 17,2 N Remaining credit 17,2 N Futures variation margins 17,2 N Option variation margins 17,2 N Option premiums 17,2 N Exercised / Assigned 17,2 N Cash transfers 17,2 N Commission 17,2 N Commission on share account 17,2 N Membership fee 17,2 N Interest 17,2 N 18

19 Net charges 17,2 N Excess cash 17,2 N Credit/debit amount 17,2 N General ABI code 5,0 N Currency 3,0 A DS07 Financial Position Corresponding reports: Send phase: Data File ID: MS11 Daily - post batch DS07 Record Length: 353 Content: Contains the daily financial information related to the activity of each Clearing Member, each segregated client (ISA) and each group of clients registered in an Additional Omnibus Account (AOA). Description Len Type Notes Date 8,0 N Format yyyymmdd ABI code 5,0 N Account 1 A See Annex Initial margins 17,2 N Collateral guarantees avail. 17,2 N Initial margins integration 17,2 N Excess collateral guarantees 17,2 N Cash deposited c/o CC&G 17,2 N Uncovered Initial margins 17,2 N Remaining credit 17,2 N Futures variation margins 17,2 N Option variation margins 17,2 N Option premiums 17,2 N 19

20 Exercised / Assigned 17,2 N Cash transfers 17,2 N Commission 17,2 N Commission on share account 17,2 N Membership fee 17,2 N Interest 17,2 N Net charges 17,2 N Excess cash 17,2 N Credit/debit amount 17,2 N General ABI code 5,0 N Currency 3,0 A D07A Detail Financial Position Main Omnibus Corresponding reports: Send phase: Data File ID: MS12 Daily - post batch D07A Record Length: 196 Content: provides details of the financial position related to the activity of the General Clearing Member and its clients and Non-Clearing Members of the Main Omnibus account. Description Len Type Notes Date 8,0 N Format yyyymmdd ABI code 5,0 N Account 1 A See Annex Initial margins 17,2 N Futures variation margins 17,2 N 20

21 Option variation margins 17,2 N Option premiums 17,2 N Exercised / Assigned 17,2 N Cash transfers 17,2 N Commission 17,2 N Membership fee 17,2 N Interest 17,2 N Net charges 17,2 N General ABI code 5,0 N 21

22 July This document is adopted pursuant to relevant laws. Cassa di Compensazione e Garanzia S.p.A. accepts no liability, arising, without limitation to the generality of the foregoing, from inaccuracies and/or mistakes, for decisions and/or actions taken by any party based on this document. AGREX, BEST VENUE INDICATOR, BORSA ITALIANA and BORSA ITALIANA s logo, BORSA ITALIANA ITALIAN STOCK EXCHANGE, BORSA VIRTUALE, CITY FOR GOOD, DDM, ELITE, ETFplus, EUROMOT, EXPANDI, EXTRAMOT, IDEM-THE ITALIAN DERIVATIVES MARKET, IDEX, MARKET CONNECT, MIB, MIB 30, MIBTEL, MIDEX, MINIFIB, MIV, MOT, MTA, MTF, NIS, SEDEX, STAR, STAR SEGMENTO TITOLI CON ALTI REQUISITI, TECHSTAR are registered trademarks owned by Borsa Italiana S.p.A. CC&G is a registered trademark owned by Cassa di Compensazione e Garanzia S.p.A. MONTE TITOLI, X-TRM, MT-X are registered trademarks owned by Monte Titoli S.p.A. MTS, BOND VISION, EUROMTS are registered trademarks owned by MTS S.p.A. PALAZZO MEZZANOTTE CONGRESS CENTRE AND SERVICES, BEST VENUE INDICATOR, MARKET CONNECT are registered trademarks owned by BIt Market Services S.p.A. London Stock Exchange, the coat of arms device and AIM are registered trademarks of London Stock Exchange plc. FTSE is a trademark of the London Stock Exchange Group companies and is used by FTSE International Limited under licence. GATElab, Traderpath, Algorithmicpath, Exchangepath are registered trademarks owned by Gatelab S.r.l. The above trademarks and any other trademark owned by London Stock Exchange Group cannot be used without express written consent by the Company having the ownership on the same. The Group promotes and offers the post-trading services of Cassa di Compensazione e Garanzia S.p.A. and Monte Titoli S.p.A. in an equitable, transparent and non-discriminatory manner and on the basis of criteria and procedures aimed at assuring interoperability, security and equal treatment among market infrastructures, to all subjects who so request and are qualified in accordance with national and community legislation, applicable rules and decisions of the competent Authorities. Contact details Cassa di Compensazione e Garanzia S.p.A. Via Tomacelli 146, Roma Membership, Client Services & Business Development Clearing & Settlement

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