Other information

Equity Interest held by directors, statutory auditors, general managers and key managers

Pursuant to Article 79 of the Consob Regulation approved with Resolution no. 11971 of May 14, 1999, the table below shows the equity interests held in the company Pirelli & C. S.p.A. and in its subsidiaries by Directors, Statutory Auditors, General Managers and key managers, by their spouses if not legally separated and by their minor children, directly or through controlled companies, trust companies or intermediaries, as resulting at December 31, 2010 from the Shareholders' Register, from notices received and from other information acquired from the same Directors, Statutory Auditors, General Managers and key managers.

Surname and name lnvestee company Number of shares held at 12/31/2009 Number of shares purchased/ subscribed Number of shares sold Number of shares held at 12/31/2010
Tronchetti Provera Marco Pirelli & C. S.p.A. 13,764 - - 1,251*
  Pirelli & C. S.p.A. (held indirectly) 1,369,504,3981 - - 124,500,500*
  Pirelli & C. S.p.A. (held indirectly) 1,217,3982 - - 110,673*
  Pirelli & C. Ambiente S.p.A. (held indirectly) 2,998,8002 1,605,779 2,364,299 2,240,2803
  Pirelli & C. Eco Technology S.p.A. (held indirectly) 16,228,8002 - 7,501,900 8,726,9003
Pirelli Alberto Pirelli & C. S.p.A. 1,447,925 - - 131,629*
PuriNegriCarlo Alessandro4 Pirelli & C. S.p.A. 66,500 - - 66,500
MorattiMassimo Pirelli & C. S.p.A. 11,551,427 - - 1,050,129*
  Pirelli & C. S.p.A. (held indirectly) 37,427'7325 - - 3,402,521*
  Pirelli & C. S.p.A. (held indirectly) 13,435,5446 - - 1,221,413*
Roth  Luigi Pirelli & C. S.p.A. 44,0007 - - 4,0007*

* The number of shares takes into account the reverse stock split carried out by Pirelli & C. S.p.A. on July 26, 2010.
1 Shares held through Camfin S.p.A.
2 Shares held through Cam Partecipazioni S.p.A.
3 The number of shares has been reduced due to share capital decrease and a further share capital increase (this for Pirelli & C. Ambiente S.p.A.), carried out during 2010.
4 Post of Director and Vice President held until July 29, 2010.
5 Shares held through CMC S.p.A.
6 Shares held in trust by Istifid S.p.A.
7 Shares held by spouse.

Stock option plans

The information on stock option plans disclosed pursuant to Consob Regulation no. 11971 of May 14, 1999 has been provided in the Explanatory Notes to the Financial Statements.
The Company did not have any stock option plan in place at December 31, 2010.

Information on ownership structure (pursuant to art. 123 bis of the consolidated law on finance-TUF)

The information pursuant to Article 123 bis of Legislative Decree 58 of February 24, 1998 can be found in the Corporate Governance Report that accompanies the Financial Report and published in the Governance section of the Company website (www.pirelli.com).

Security policy document

In accordance with the provisions of Appendix B, paragraph 26 of Legislative Decree 196 of June 30, 2003, notice is given that Pirelli & C. S.p.A. has updated its Security Policy Document for the year 2010.

Foreign subsidiaries not in the european union (NON-EU COMPANIES)

Pirelli & C. S.p.A. directly or indirectly controls a number of companies with registered offices in countries that are not members of the European Union (Non-EU Companies) and which are of material interest pursuant to Art. 36 of Consob Regulation 16191/2007 on market regulation ("Market Regulation").
At December 31, 2010, the Non-EU Companies that were directly or indirectly controlled by Pirelli & C. S.p.A. and of material interest pursuant to Article 36 of the Market Regulation were: Pirelli Pneus Ltda (Brazil); Pirelli Tire LLC (USA); Pirelli Tyre Co. Ltd (China); Turk Pirelli Lastikleri A.S. (Turkey); Pirelli de Venezuela C.A. (Venezuela); Alexandria Tire Company S.A.E. (Egypt); Pirelli Neumaticos S.A.I.C. (Argentina).
Also under the terms of the same regulations, the Company has in place specific and appropriate "Group Operating Rules" which ensure immediate, constant and full compliance with the provisions contained in the said Consob Regulations1. Under the terms of the said Operating Rules, the competent corporate functions of the Parent precisely and periodically identify and disclose all Non-EU Companies of material interest under the Market Regulations, and – with the necessary and timely collaboration of the companies involved – guarantee collection of the data and information and verification of the circumstances as required by Article 36 of the Market Regulations, ensuring that the information and figures provided by the subsidiaries are available in the event of a request by Consob. Furthermore, a regular flow of information is provided for in order to ensure that the Board of Statutory Auditors of the Company can carry out the required and appropriate audits. Finally, the above "Operating Rules," in keeping with the regulatory provisions, prescribe how the financial statements (balance sheet and income statement) of significant Non-EU Companies prepared for the purpose of the consolidated financial statements are to be made available to the public.
Therefore, it is certified that the Company has fully complied with the provisions of Article 36 of Consob Regulation 16197/2007 and that its conditions have been satisfied.