Management Transactions

Members of the governing bodies of companies with a primary listing are required to report transactions involving equity securities (shares) or related financial instruments of their employer. These management transactions are disclosed by the primary listed company. The publicly accessible reports enhance transparency for investors.

Persons subject to the reporting obligation are the members of the board of directors and the executive committee of companies with a primary listing (equity issuers).

In particular, the following transactions must be reported:

• Transactions that directly or indirectly affect the assets of the person subject to the reporting obligation.
• Transactions of related parties (natural or legal persons) that are carried out under the significant influence of a person subject to the reporting obligation.
• Transactions between persons subject to the reporting obligation and their related parties (natural or legal persons).

For transactions settled via an exchange, the reporting obligation arises with the execution of the order. For off-exchange transactions, the reporting obligation arises when the corresponding reportable transaction is concluded.

Disclosure takes place in a two-stage procedure:

1. Notification to the primary listed company:
   The person subject to the reporting obligation must notify the primary listed company of the transaction within two trading days of the reporting obligation arising.
2. Notification to SIX Exchange Regulation AG:
   The primary listed company must subsequently notify SIX Exchange Regulation AG within three trading days of receipt. The notification is submitted via the electronic reporting platform and is publicly accessible from that point in time.

Two-stage procedure: