In this section, insiders and other concerned persons may consult the information necessary for the fulfillment of their obligations established by the current legislation of the Russian Federation, Bank of Russia regulations adopted in accordance with it, other applicable laws and internal documents of the Company in the matter of countering the misuse of insider information and market manipulation, as well as information on the legal consequences of the misuse of insider information of the Company and (or) market manipulation.
For questions concerned with the status of the insider and insider information of the Company, you can contact the Corporate Secretary V.A. Loskutov.
NLMK has developed and approved the following by-laws to ensure due compliance with the Russian legislation on counteracting the misuse of insider information and market manipulation:
- Regulations on procedure for accessing insider information, rules for protecting its confidentiality and their internal enforcement P CG-307-0040-2020 (approved by the Corporate Secretary on 23.03.2020);
- Regulations on insider information (approved by the Board of Directors, MoM No.270 d.d. 19.03.2020);
- NLMK list of insider information.
From the moment a person is included in the list of insiders, restrictions are imposed on him as provided for in Article 6 of the Federal Law-224 and the Regulations on the Company's insider information, responsibility is determined in accordance with Article 7 of the Federal Law-224 and the obligations stipulated in Article 10 of the Federal Law-224 are assigned. In addition, the legislation of the Russian Federation defines administrative and criminal responsibility in accordance with Article 15.21 and part 3 of Article 15.35 of the Code of Administrative Offenses and Articles 185.3 and 185.6 of the Criminal Code.
Insiders belonging to the category of persons discharging managerial responsibilities in the Company and persons closely associated with them are required to inform the Corporate Secretary of their transactions with the company's securities and the conclusion of contracts that are derivative financial instruments and the price of which depends on such securities (hereinafter referred to as operations) performed by them after reaching the total amount of previously completed transactions in the amount equivalent to 5,000 euros per calendar year within 2 business days from the date of the relevant transaction. Information on transactions performed by the indicated persons should be sent to the email address of the Corporate Secretary of the company V.A. Loskutov ( email@example.com)
Other insiders are obliged at the request of the Company to provide information on the transactions performed by them or on the absence of facts of the transactions for the period and time specified in the request. If there are circumstances that prevent an insider from fulfilling the request within the time period specified in it, the insider shall submit to the Company no later than 5 working days before the expiration of the deadline indicated in the request a motivated claim to extend the deadline for fulfilling the request, being guided by the Bank of Russia regulatory act.
The information concerning NLMK securities
Insiders, as well as those who belong to persons closely associated, should abstain, and insiders belonging to persons discharging managerial responsibilities in the Company are prohibited from carrying out operations with securities during the “close period”, except the certain cases, which are exceptions. Close periods are shown in the table below:
Corresponding event date
|09 January – 12 February 2021||08-12 February 2021: 12M 2020 Consolidated Financial Results (based on International Financial Reporting Standards or IFRS)|
|20 March – 23 April 2021||19-23 April 2021: Q1 2021 Financial Results (IFRS).|
|19 June – 23 July 2021||19-23 July 2021: H1 2021 Financial Results (IFRS).|
|18 September – 22 October 2021||18-22 October 2021: 9M 2021 Financial Results (IFRS).|
Please direct your requests, complaints and statements related to counteracting the misuse of insider information and market manipulation to: firstname.lastname@example.org