Pursuant to the Federal Law No. 224-FZ dated July 27, 2010, on Countering the Illegal Use of Insider Information and Market Manipulation and on Amending Certain Legislative Acts of the Russian Federation, the insiders of “SIBUR Holding” PJSC (hereinafter referred to as the “Issuer” or “Company”) who has access tothe Insider Information of the Company shall notify the Company of the transactions they have performed with the Company’s securities within ten (10) business days from the date of such transactions.
“Insider information” means any accurate and specific information that has not been disseminated or disclosed (including data constituting a trade, business, banking or communication secret or other legally protected secret) and that, if disseminated or disclosed, could have a significant impact on the Company’s stock price.
A Template of Notification on Transactions with the issuer securities (download)
The signed Notification shall be forwarded to the Company by one of the following ways:
- delivery by registered mail to postal addresses with the acknowledgement of receipt.
- delivery to “SIBUR Holding” PJSC postal address: Krzhizhanovskogo street, 16/3, 117997 Moscow, GPS -7, Russia;
- delivery by e-document, signed by the digital signature in compliance with the requirements of Russian legislation to the email address: firstname.lastname@example.org.
The Notification on transactions performed by insiders submitted in a hard copy shall be:
- signed by the insider or by the insider’s authorized representative;
- if the insider is a legal entity, the notification shall bear the seal of such legal entity;
- if the hard copy includes more than one sheet, it shall be bound and paginated;
- if the notification is sent on behalf of the insider by an authorized representative, the notification shall be supplemented with a power of attorney (or a duly certified copy thereof) or another document (or a duly certified copy thereof) granting the authority to such representative.
The insider has the right to provide information about several transactions in one notification. The terms of each transaction shall be described separately.
The Company’s Insiders are prohibited from:
- using Insider Information for the purpose of transactions with Financial Instruments and Eurobonds at their own expense or at the expense of a third party, except within the framework of fulfillment of an obligation which has become due, provided such an obligation resulted from a transaction which had been performed before the person learned such Insider Information;
- using Insider Information by way of its transfer to another person, except for cases when the information was transferred to a person included in the list of Insiders in connection with the fulfillment of statutory obligations or in connection with the fulfillment of work duties or the performance of a contract;
- using Insider Information by way of issuing recommendations to third parties, obliging or otherwise encouraging them to acquire or sell Financial Instruments and Eurobonds; and
- carrying out acts referring to Market Manipulation under the laws of Russia.
Currently effective applicable laws of the Russia provide for:
Administrative sanctions for the illegal use of insider information and/or market manipulation, as per Art. 15.21, 15.30, 15.35 of the Code of Administrative Offences of the Russian Federation.
Criminal sanctions for market manipulation, as per Art. 185.3 of the Criminal Code of the Russian Federation, and for the illegal use of insider information, as per Art. 185.6 of the Criminal Code.
REGULATION ON MATERIAL NON-PUBLIC INFORMATION PJSC SIBUR HOLDING.Положение об инсайдерской информации. Revision No. 9