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Insider information
This section provides insiders and other interested persons with the information necessary for performance of their duties established by the current legislation of the Russian Federation, the regulations of the Bank of Russia adopted in accordance with such legislation, and internal documents of the Company in the field of countering 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.
INSIDER INFORMATION
- Specific and concrete information
- Has not been disclosed before
- Disclosure may have a significant impact on the value of the Company’s securities
THE INSIDER IS OBLIGED TO
- comply with the requirements of the legislation and internal documents of the Company in the field of insider information,
- comply with the measures prescribed to ensure access, security and integrity of insider information,
- declare any transactions with NLMK securities: The Company has the right to request information from insiders about their transactions with securities. Insiders who receive a request are required to provide the requested information no later than 10 business days from the date of receipt of the request. If transactions with securities were not carried out during the period specified in the request, the insider must confirm the absence of transactions in response to the request,
- comply with certain conditions when making transactions with the Company's financial instruments: Insiders of the Company, as well as their related persons, cannot conduct any transactions with securities during the "black-out period", except in certain cases which constitute exceptions.
INSIDERS ARE PROHIBITED from performing actions qualified by law as market manipulation and from using insider information:
- to carry out transactions with financial instruments related to insider information at their own expense or at the expense of a third party, except for performing transactions within the framework of fulfilling an obligation to purchase or sell financial instruments, the due date for which has come, if such an obligation arose as a result of a transaction performed before the insider information became known to the person,
- by transferring it to another person, except in cases when this information is transferred to a person included in the list of insiders in connection with the performance of duties established by federal laws, or in connection with the performance of work duties or the performance of a contract,
- by making recommendations to third parties, obliging or otherwise encouraging them to purchase or sell financial instruments.
INSIDER'S RESPONSIBILITY
Any person who has misused insider information may be brought to disciplinary, administrative, criminal or civil liability.
Other persons who are not insiders, but who have gained access to NLMK's insider information and disseminated insider information or performed transactions with the Company's securities using insider information, may also be held liable.
The information concerning NLMK securities
Notification form on insider performing a transaction with NLMK securities (for legal entities)
Notification form on insider performing a transaction with NLMK securities (for individuals)
On issues 1) related to the status of an insider and insider information of the Company, 2) in order to eliminate the risk of misuse of insider information, as well as to prevent transactions with the Company's securities during the "black-out period", it is recommended that the Company's insiders seek advice from NLMK's Corporate Secretary Valerii Loskutov (loskutov_va@nlmk.com) before such transactions are made.
Please direct your requests, complaints and statements related to counteracting the misuse of insider information and market manipulation to: compliance@nlmk.com