Dealing code Approved by the Board of Directors on 24 March 2021
INTRODUCTION In implementation of the Corporate Governance Code, WDP, as an issuer and a listed company, has worked out a prevention and integrity policy for an effective application of the regulations pertaining to market abuse. Market abuse is the concept that encompasses unlawful behaviour on the financial markets. It should be understood to consist of (i) insider dealing, (ii) unlawful disclosure of inside information and (iii) market manipulation. Such behaviour prevents full and proper market transparency, which is a prerequisite for trading for all economic actors in integrated financial markets. To date, the regulations regarding market abuse have been recorded in Regulation No. 596/2014 of the European Parliament and the Council of 16 April 2014 on market abuse (together with its implementing regulations), the Act of 2 August 2002 on the supervision of the financial sector and on financial services and the Royal Decree of 14 November 2007 on the obligations of issuers of financial instruments admitted to trading on a regulated market. The objective of this Dealing Code is to make its addressees aware of the regulations regarding market abuse and the resulting obligations for (i) WDP in its capacity of issuer of financial instruments and (ii) all persons who carry out activities within or for the WDP Group and who could have access to inside information. With this policy, WDP endeavours to avoid market abuse by the persons in question. All words with an initial capital in this document are defined hereafter.
LEGAL STATUS OF THIS DEALING CODE
This Dealing Code is restricted to an overview of the main obligations under Belgian and European law regarding market abuse applied to the Financial Instruments issued by WDP. In no way does it concern legal advice, nor must it be regarded as such. All Directors and Employees of the WDP Group are personally responsible for ensuring that they behave in accordance with the regulations pertaining to market abuse at all times. One’s own advisors should always be consulted in order to determine his or her legal condition with regard to the subjects discussed here. The Company reserves the right to amend the Dealing Code when it deems necessary. Each addressee of this Dealing Code is requested to return it, signed for acknowledgement and agreement, to the Company to the attention of the Compliance Officer by registered mail within five working days of receiving it.
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