To whom it may concern,
Public joint stock company “Kubanenergo” (hereinafter – the Company) being a public company with its securities traded on trading platforms of the MICEX Stock Exchange (hereinafter – MICEX) without listing (stock symbol — KUBE); ISIN code: RU0009046767, pays great attention to insider information which may significantly influence the cost of financial instruments of the Company (hereinafter – insider information). Applying the best practices in this sphere, the Company ensures equal conditions for all participants of the stock market and directs its efforts towards prevention of illicit use of insider information.
In order to ensure observance of requirements set in Federal law No. 224-FZ dated 27 July 2010 “On prevention of illegal use of insider information and market manipulation and on amendments to certain legislative acts of the Russian Federation” (hereinafter – Federal law 224), the Board of Directors had approved Regulations on insider information of Kubanenergo JSC (Minutes of meeting No.168 dated 5 August 2013), the Regulations define such concepts as “insider” and “insider information”, as well as set the procedure for access to insider information, rules of protection of its privacy and control of observance of requirements set in the Federal law 224 and other legal documents adopted in accordance with the law.
The Company keeps current the List of insiders, for which there is a special procedure for performing transactions with financial instruments of the Company as well as the List of insider information.
When the person is entered in the List of insiders, they get a notification on this fact and specials restrictions and requirements are set upon such person, stipulated by the article 6 of the Federal aw 224 and by Annexes 4 and 5 of the Regulations on insider information.
Pursuant to these requirements, the Company concludes:
- additional agreements to the labour contracts in respect of the protection of confidentiality of insider information with the employees of the Company included in the list of insiders;
- additional agreements to the civil contracts in respect of the protection of confidentiality of insider information with counterparties of the Company included in the list of insiders;
- agreements on the protection of confidentiality of insider information with the persons included in the list of insiders who are not employees or contractors of the Company.
Persons included in the list of the Company's insiders are prohibited to:
Insiders shall be guided by the following documents when dealing in securities:
- cannot perform any transactions in financial instruments of the Company, during the inhibit periods, established within: one month before the date of the publication of quarterly and half-yearly financial statements in accordance with RAS and the Company's financial statements under IFRS; two months before the publication of annual financial statements under RAS and the Company's financial statements under IFRS; before the end of the second trading day after the events;
- can acquire the Company's financial instruments only for the purpose of long-term (more than 6 months) investments;
- must prevent repurchase transactions, as well as sale and purchase of the Company’s financial instruments on credit;
- cannot make derivative transactions in financial instruments of the Company;
- must inform the Company in the prescribed form (Appendix 8 to the Regulations on insider information) on completed transactions in financial instruments Kubanenergo;
- submit to the Company in the prescribed form (Appendix 7 to the Regulations on insider information), “Confirmation of the number securities owned by insider a of the date of the end reporting quarter and securities transactions completed in the reporting quarter”
Please note that for non-fulfillment of legal requirements in the field of combating illegal use of insider information, there is civil, administrative and criminal liability in accordance with Article 15.21 of the Code of Administrative Violations and Article 185.6 of the Criminal Code of the Russian Federation.
Subdivision for Anti-Corruption and Compliance Procedures
Address: 2A Stavropolskaya street, Krasnodar 350033
phone: +7 (861) 212-22-05
1 The exceptions are the operations performed in the framework of performance of the obligation to buy or sell financial instruments of the Company, which implementation time has not come, if such obligation has arisen as a result of the operation, performed before the person became aware of insider information
2 The exceptions are cases of transfer of insider information to a person included in the list of insiders of the Company, in connection with the implementation of the obligations established by federal law, or in connection with the performance of job duties or performance of a contract.
3 The notice must be personally signed and sent to Kubanenergo PJSC by method that allows to acknowledge receipt of the notice (by courier or by mail with return receipt, handed personally to the Department of insider information, sent in a scanned form by e-mail to: email@example.com a request for read notification, etc.)