In accordance with Federal Law № 224-FZ «On combatting the unlawful use of insider information and market manipulation», dated 27.07.2010, as well as the Regulations on Insider Information of Gazprom Neft PJSC (as revised in 2013) persons who are insiders of PJSC Gazprom Neft must be included in the Company’s list of insiders.
As soon as a person is included in the insiders list of Gazprom Neft PJSC, he or she becomes subject to restrictions on the dissemination of insider information about the Company, assumes duties to provide information about transactions with securities of Gazprom Neft PJSC and is liable to sanctions for unlawful use of insider information.
The duties of a person who is a Company insider apply only to transactions for the purchase and sale of shares and (or) bonds of Gazprom Neft PJSC carried out by the insider (or by a professional market participant on behalf of the insider) and only on the market inside the Russian Federation.
The insider shall, from the date of receipt of notification of inclusion in the list of insiders, be responsible for providing notification to the Company of transactions with shares and/or bonds of Gazprom Neft PJSC within 10 working days from the date when the transaction is carried out.
Information submitted to Gazprom Neft PJSC, should be sent to the Corporate Governance Department at the following address: ul. Pochtamtskaya 3–5, St Petersburg 190000, Russian Federation; telephone: +7 (812) 363-31-52. E-mail: UKR@gazprom-neft.ru.
Relationships connected with financial instruments, foreign currency and (or) goods, which are admitted to trading on organized markets in the Russian Federation, are regulated by the Federal Law.
Insider information is exact and specific information, that has not been distributed or provided (including information constituting commercial, official and other secrets protected by law), the distribution or provision of which may have significant impact on the value of the Company’s securities or products.
The law prohibits the following uses of insider information (Article 6 of the Federal Law):
- to carry out operations with financial instruments (shares, bonds of Gazprom Neft), which are affected by insider information, at the insider’s own expense or the expense of a third party;
- transfer of the information to another person, except for transfer of the information to a person who is included in the list of insiders;
- use of the information to give recommendations to third parties, to oblige or otherwise encourage them to acquire or sell financial instruments and (or) goods.
It is also prohibited to carry out the following actions, which are defined by the Federal Law as market manipulation:
- to deliberately disseminate through the media, or by any other means, information that is known to be false, as a result of which the price, demand, supply or volume of trading in a financial instrument deviates from the level, which would have occurred if such information had not been disseminated;
- to carry out operations with a financial instrument when, as a result of such operations, the price, demand, supply or volume of trading in the financial instrument deviates from the level that considerably differs from the level which would have occurred without such operations;
- to carry out transactions several times during the trading day on organized markets at the expense of or on behalf of a person by means of bids, which, at the time they are made, represent the highest purchase price or lowest sale price for a financial instrument, as a result of which the price of the instrument significantly deviates from the level that would have occurred without such transactions, for the purpose of subsequently carrying out, at the expense of or on behalf of that person or another person, the opposite transactions at those same prices, and where such opposite transactions are carried out;
- to carry out transactions several times during the trading day on organized markets at the expense of or on behalf of a person in order to mislead as to the price of a financial instrument, as a result of which the price of the instrument is maintained at a level significantly different from the level, which would have occurred without such transactions;
- to repeatedly and intentionally fail to perform commitments in operations on organized markets with the same financial instrument, as a result of which the price, demand, supply or volume of trading in the financial instrument deviates significantly from the level, which would have occurred without such operations.