For a considerable period of time USG People N.V. has had a regulation in force relating to securities transactions in the company by members of the Supervisory Board, Executive Board and the Executive Committee. This is the so-called “Model Code”. Effective 1 January 2005 members of the Supervisory Board, Executive Board and the Executive Committee have also been subject to the Tracking Compliance Program. Briefly, up to 1 January 2005 this regulation involved mandatory reporting of all transactions in companies with registered offices in the Netherlands, whereby the shares and depositary receipts of shares were listed on a government-recognised stock exchange.

At the end 2005 of the Supervisory Board and the Executive Board jointly evaluated this regulation and it was decided to alter the regulation effective 1 January 2006. Instead of mandatory reporting after the event for all Dutch, publicly listed securities, as of 1 January 2006 there is mandatory reporting in advance for all securities of the so-called Peer Group of direct competitors. This prior mandatory reporting means that trading in stocks of direct competitors is permitted on the condition that permission is obtained in advance from the Compliance Officer of USG People N.V. Download Tracking Compliance Program