Information for Insiders of the Company
In order to secure the compliance with the Federal law as of the 27th of July, 2010-FZ No. 224-FZ “About the counteraction against the unlawful use of insider information and market manipulating” (further 224-FZ) the Board of Management of the Company confirmed the Regulation about the insider information of “RossetiLenenergo”, PJSC (Minutes No.45 of 06.06.2019) which sets the order of access to the insider information, the rules of securing its confidentiality and control of its compliance with 224-FZ and adopted laws and regulations.
In the Company, according to the Procedure for keeping the List of Insiders up to date, the List of insiders for whom a special procedure has been established for dealing with the company's financial instruments, as well as the List of insider information.
Since the moment of putting the person into the List of insiders of the Company, liabilities and requirements are put on him that are foreseen by Article 6 224-FZ, the responsibility is defined in accordance with Article 7 224-FZ, and the obligations are put on such a person in accordance with Article 10 224-FZ as well as the responsibility of implementation requirements of the Regulation on the insider information of the Company. In addition, the legislation of the Russian Federation defines administrative and criminal liability in accordance with Article 15.21 and part 3 of Article 15.35 of the Code of Administrative Offenses of the Russian Federation and Articles 185.3 and 185.6 of the Criminal Code of the Russian Federation.
Those who are put into the list of insiders of the Company must comply with the order of confidentiality of insider information set by the Company – Rules of handling insider information (Addendum No. 4 to the Regulation).
Those having the access to the insider information relating to the Company or their financial instruments are not allowed to use the insider information:
1) in order to conduct transactions with financial instruments of the Company which are covered by the insider information at one’s own expense or at the expense of the third person. The exception is conducting operations concerning the implementation of obligation of buying or selling financial instruments of the Company maturity date of which has already come if such an obligation has occurred as a result of a transaction that has been carried out before the person get to know the insider information;
2) by giving it to the other person, for the exception of cases when the information is given to the person who is included into the list of insiders in case of keeping compliance with laws of Russian Federation or in case of implementing labor obligations or civil law contract;
3) by giving recommendations to the third parties, oblige or motive them to buy or sell financial instruments of the Company in other way;
4) in order to manipulate the market.
Company insiders shall abstain from any transactions with the insider financial instruments of the Company during closed periods.
In accordance with clause 5 of the Regulations on Insider Information of «Rosseti Lenenergo», PJSC, the closed period starts in not later than 15 calendar days before signing of the accounting (financial) statements executed in compliance with the Russian Accounting Standards (RAS) and consolidated financial statements executed in compliance with the International Financial Reporting Standards (IFRS) and ends on the day following the date of publishing of the above statements.
In accordance with FZ-224 as well as Directive of the Bank of Russia No. 5128-U dated April 22, 2019, insiders shall submit the information on transactions with securities of the Company closed by them and on the signing of contracts forming derivative financial instruments with the price depending on such securities (hereinafter referred to as the transactions) by the deadline specified in the request, but no less than 10 working days from the date of receipt of the request by the insider.
If during the reporting period specified in the request the insider closed no transactions, then the insider shall provide the information on absence of any transactions in the response to the request.
The insider shall provide the response to the request in the form of an electronic document in one of the following formats: .dbf, .xls, .xlsx, .txt, .csv or in paper form.
The response to the request on an electronic data carrier (CD, flash drive) shall be submitted by the insider together with an accompanying letter in paper form.
The response to the request in the form of an electronic document shall be signed by the electronic signature of the insider or the insider’s authorized person (for individuals) or the head / authorized person of the insider (for legal entities).
The response to the request in paper form containing more than one sheet shall be numbered, bound and sealed with the endorsement on the reverse side of the last sheet stating in words and digits the number of bound pages and signed by the person executing such endorsement stating the surname, name and patronymic (if any), as well as the date of execution. The response to the request shall be signed by the insider (for individuals) or the head / authorized person of the insider (for legal entities) and contain the information allowing to identify the insider.
If the response to the request is submitted by the authorized representative of the insider, it shall be accompanied by a document confirming the powers of such representative.
The contact person responsible for maintenance of the list of insiders is Ilya Berezin.
In case of any questions related to the insider status, performance of obligations stipulated by the Law, detection of violation of the procedure of insider information use, please immediately contact us by email IR@lenenergo.ru or telephone +7 (812) 494-39-06.
Correspondence address: 1, Ploshchad Konstitutsii, Saint Petersburg, 196247, Department for Corporate Governance and Interaction with Shareholders.
