Pursuant to Articles 2.6.3, 2.6.4 and 2.6.4 bis of the Rules for the Italian Borsa, on 13 November 2002, the board of directors of Class Editori S.p.A. approved the "Code of Conduct" (Internal Dealing) which governs the disclosure of information relative to transactions in securities of the company effected by material persons and the actions necessary to disclose such transactions to the market.

The information relative to transactions exceeding EUR 250,000 shall be communicated to Senior Management without delay, and in any event, no later than the second market business day subsequent to the transaction. Senior Management shall communicate to the aforementioned transactions to the market on or before the second market business day thereafter.

For transactions with a value of between EUR 50,000 and EUR 250,000, the information is to be reported to Senior Management on or before the fifth market business day subsequent to the close of the calendar quarter in which the transaction(s) was(were) executed, and on or before the tenth business day subsequent to the close of the calendar quarter in which the transaction(s) was(were) executed.

Additional information on the Code of Conduct (Internal Dealing) is available by downloading the document in Acrobat format.