In accordance with Article 4 of Federal Law No. 224-FZ On Countering the Unlawful Use of Insider Information and Market Manipulation and Amendments to Certain Legislative Acts of the Russian Federation of 27 July 2010 (hereinafter - the Federal Law) VEB.RF is deemed insider as:

  • issuer (paragraph 1, Article 4 of the Federal Law);
  • professional participant in a securities market that is carrying out transactions involving financial instruments, foreign currencies and/or commodities and has received inside information from clients (paragraph 4, Article 4 of the Federal Law);
  • person having access to the inside information of the persons specified in paragraphs 1-4 of Article 4 of the Federal Law under contracts concluded with the relevant persons (paragraph 4, Article 4 of the Federal Law);
  • person having directly or indirectly (via controlled entities) at least 25 per cent of votes in the top managerial body of the persons specified in paragraphs 1, 3, 4 of Article 4 of the Federal Law and also a person that has access to inside information under federal laws or constituent documents by virtue of having shares (stakes) in the charter capital of said persons (paragraph 6, Article 4 of the Federal Law);
  • person having access to information concerning a voluntary, compulsory or competitive bid for purchase of shares prepared and/or filed in accordance with the legislation of the Russian Federation on joint-stock companies, including persons that have sent voluntary or competitive bid for purchase of shares or a call for redemption of securities to a joint-stock company (paragraph 8, Article 4 of the Federal Law);

In accordance with paragraph 1 of Article 3 of the Federal Law, VEB.RF approved a List of VEB.RF’s Inside Information. The following is not deemed “inside information”:

  • the information to which access is given to the general public, for instance as the result of dissemination thereof;
  • research, forecasts and assessment carried out on the basis of generally accessible information in respect of financial instruments, foreign currencies and/or commodities (paragraph 5, Article 3 of the Federal Law);

It is prohibited to use inside information:

  • for entering into transactions in the financial instruments, foreign currencies and/or commodities which are covered by the inside information at one’s own expense or at the expense of a third person, except for transactions related to an undertaking to purchase or sell financial instruments, foreign currencies and/or commodities which has become due if such undertaking came into being as the result of a transaction that had been concluded before the person acquired the inside information;
  • by means of handing it over to another person, except for cases when this information is handed over to a person included in the list of insiders in connection with the execution of duties established by a federal law or in connection with the execution of labour duties or performance of a contract;
  • by means of giving recommendations to third persons or otherwise obligating or urging them to purchase or sell financial instruments, foreign currencies and/or commodities.

It is prohibited to commit the actions deemed “market manipulation” in accordance with Article 5 of the Federal Law.

Any person that has illegally used the inside information and/or has committed market manipulation bears responsibility in accordance with the law of the Russian Federation.

Based on the request of VEB.RF and according to the requirements of Article 10 of the Federal Law insiders included in the list of insiders of VEB.RF send information on the operations that they have performed.

The information shall be submitted to VEB.RF using one of the methods listed in the request.

If the information is submitted in hard copy, the sheets shall be bound, numbered and signed by an authorized representative.

If a reply to the request is signed on behalf of the insider by its authorized representative, a duly certified copy of a document confirming the representative's authority shall be attached to the information on the transactions.

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