Dealing Code

According to the Corporate Governance Best Practices and the Belgian Code of Corporate Governance which is based on the European Directive 2003/6 EC on Insider Dealing and Market Manipulation, UCB adopted the "Dealing Code" for its Employees and third parties to prevent insider trading offences and market abuse.

UCB employees can trade in UCB securities at any time except

1. When in possession of privileged information.
   

   Privileged Information is any information (i) of a precise nature (ii) which has not been made public, (iii) relating directly or indirectly to one or more issuers of Financial Instruments or to one or more Financial Instruments, and (iv) which is material (i.e. if it were made public, would be likely to have a significant effect on the prices of the Financial Instruments or on the price of related derivative Financial Instruments).

2. Key Employees and Insiders cannot trade during Closed Periods
   

   Closed periods extend from

   • one and a half months immediately preceding the preliminary announcement of UCB's annual results and extending through (and including) the Working Day after the announcement; or
   • one month immediately preceding the preliminary announcement of UCB's interim half-year results and extending through (and including) the Working Day after the announcement.

Key Employees are employees who have regular or incidental access to Privileged Information relating directly or indirectly to UCB. Key Employees are personally informed of their status and an updated list of Key Employees is available in an attachment to the Dealing Code.

Insider is any person in possession of Privileged Information about UCB or any of its Affiliates in general or about a specific project of or an event concerning UCB or any of its Affiliates, the disclosure of which UCB has decided to defer. Insiders are personally informed about their status.

Even during trading windows, before performing any transaction on UCB securities, Key Employees and Insiders need to receive clearance for the planned transaction from the Insider Trading Compliance Officer.

Moreover, (Persons who are closely associated with) Persons Discharging Managerial Responsibilities of the Company (Directors of UCB SA, Executive Committee Members and their close family members) have to notify each transaction on UCB (related) securities to UCB within one working day following the transaction and to the Financial Services and Markets Authority (FSMA) within five days following the transaction by sending the form available on the FSMA website financial markets - market abuse - reporting of insider transaction - form B reporting of insider transactions) by email or fax and by post (with piece of evidence).

For more information please contact Mr. Robert Trainor, Insider Trading Compliance Officer and Mrs. Inge Basteleurs, Vice President & General Secretary (Insider.Trading.Compliance.Officer@UCB.com).