Compliance with Article 36 of Consob Regulation 16191/2007 concerning market regulations

Considering that Pirelli & C. S.p.A. controls, directly and indirectly, certain companies established and regulated under the law of non-EU countries*, which are deemed to be of material significance pursuant to art. 36 of Consob Regulation 16191/2007 concerning Market Regulations, the company has decided to adopt a specific and suitable “Group Operating Instruction” which ensures immediate, constant and integral respect for the provisions of the above-mentioned Consob regulation, even though there are already administrative/accounting and reporting systems of the Pirelli Group in place so that the company is substantially in line with the requirements of the market regulation. As stated in the above Operating Instruction, the competent corporate functions of the parent, in abiding by the market regulation, at specific dates and periodically, shall identify and publicize materially significant non-EU companies as defined in the market regulation, and - with the necessary and timely collaboration of the interested companies - guarantee the collection of the data and information and the verification of the circumstances as stated in article 36, ensuring that the information and data provided by the subsidiaries are available in the event of a request by Consob.

Furthermore, a periodical flow of information shall also be provided in order to ensure that the Pirelli & C. board of statutory auditors can carry out the required and necessary tests.

Finally, the operating instruction adopted by the company, in keeping with the provisions of the market regulation**, instructs how the financial statements (the balance sheet and income statement) of the materially significant non-EU companies prepared for the purpose of the consolidated financial statements are to be made available to the public.

It can therefore be stated that the company has fully complied with the provisions of article 36 of the above Consob 16191/2007.

* Non-EU companies controlled, directly and indirectly, by Pirelli & C. S.p.A., relevant pursuant to article 36 of the Market Regulation are currently: Turk Pirelli Lastikleri AS; Pirelli Tyre CO LTD; Pirelli Pneus LTDA; Pirelli Tyre (EUROPE) S.A.; Pirelli Tire LLC.

** It should be noted that - as elucidated by Consob – article 36, paragraph 1, letter a) of the Market Regulations will be applied “in respect of financial statements for the years in progress at the date the same comes into effect” and therefore the financial statements shall be made available to the public starting from the approval of the financial statements for year 2008 for the non-EU companies controlled by Pirelli & C. which carry material significance at December 31, 2008.