English translation of the French original, for information purposes only
Valeo
Code of good conduct relating to trading in financial instruments and regulations applicable to insider trading
Date: Document dated 29 February 2024
As Valeo's shares are traded on the regulated Euronext market in Paris, French law and regulations set down by the European Union and the Autorité des Marchés Financiers ( AMF
Financial Markets Authority), together with AMF recommendations, relating to the monitoring of trades in financial instruments and the prevention of insider trading apply to the corporate officers of both Valeo and its subsidiaries (the Group ), and to their employees,
where the latter have access to Inside Information (as defined below).
This code of good conduct (the Code ), approved by Valeo's Board of Directors on
29 February 2024, has been uploaded to the Valeo internet and intranet sites.
I.
Definitions
1) Concept of inside information
Inside information ( Inside Information ) is information that:
ð·
is of a precise nature, meaning it indicates a set of circumstances which exists or which may reasonably be expected to come into existence, or an event which has occurred or which may reasonably be expected to occur, where it is specific enough to enable a conclusion to be drawn concerning the possible effect of that set of circumstances or event on the price of Valeo financial instruments or related derivative financial instruments;
ð·
has not been made public, meaning that is has not been made generally available to the public. The information is notably considered public when the public has been informed (i) by an official press release (made by a press agency, a broadcasting service or a mass-circulation daily newspaper) and on the company's website,
(ii) at the time of an audio or video conference which can be accessed by any investors by telephone or internet, or (iii) in a public information document filed with a stock exchange authority (for example, the annual report, a prospectus, etc.);
ð·
concerns, directly or indirectly, the Group or one or more of its financial instruments; and
ð·
if it were made public, would be likely to have a significant effect on the prices of
Valeo financial instruments, or of related derivative financial instruments, meaning it is information a reasonable investor would be likely to use as part of the basis of his or her investment decisions.
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