Regulations of Rosneft “Internal control rules for the prevention, detection and suppression of illegal use of insider information in Rosneft and (or) market manipulation”.

Regulations of Rosneft “Internal control rules for the prevention, detection and suppression of illegal use of insider information in Rosneft and (or) market manipulation”.

• On the specialised Interfax-TsRKI news feed
  (http://www.e-disclosure.ru/portal/company.aspx?id=6505);
• on the Company’s official website.

The information loses the status of insider information and the procedure for use and protection of confidential insider information is no longer applied to it.

• for personal purposes or in third parties’ interests;
• for performance of transactions with the Company’s securities;
• by way of its transfer to another person, with exception of cases where such information is transferred to a person included in the List of Insiders, in connection to performance of the duties established by the federal laws or in connection to performance of work duties or contract performance;
• for recommending to / obliging / encouraging other persons to perform transactions with the Company’s securities;
• it is prohibited to perform actions constituting market manipulation under the Law “On Insider Dealing”.

Yes, as it contains data on Rosneft’s insiders (including personal data of those insiders who are persons).

Pursuant to the Regulations of Rosneft “Internal control rules for the prevention, detection and suppression of illegal use of insider information in Rosneft and (or) market manipulation” there have been established closed and open periods for performance by insiders of operations with Rosneft securities, depending on preparation and disclosure of consolidated financial statements in accordance with the IFRS.

If an insider purchased the Company’s securities within the validity of the open period, for example on 15 August 2019, sale is possible not earlier than 15 September 2019, that is after 30 calendar days from the day of purchase (pursuant to the Regulations of Rosneft “Internal control rules for the prevention, detection and suppression of illegal use of insider information in Rosneft and (or) market manipulation”).

• the Company employees, if they have permanent or temporary access to insider information;
• the Company’s counterparties in transactions, if they have access to insider information based on a contract concluded;
• the Company’s management and control bodies members.

After expiry of 6 (six) months.

From an official notice sent to him/her/it by the Corporate Governance Department.