Preventing the use of insider information

RusHydro has put in place Regulations on Insider Information to secure compliance with laws and regulations of the Russian Federation in terms of prevention of unauthorized use of insider information and market manipulation. The Regulations are in line with the world’s best corporate governance practices, including Disclosure and Transparency Rules of the Financial Conduct Authority.

The Regulations specify the persons that are included in the Company’s list of insiders, the rules of access to the insider information and its confidentiality protection, as well as restrictions on the use of insider information in transactions with the Company’s financial instruments and disclosure thereof to the third parties.

The list of insider information is made in Russian and English and published on the Company’s website. In Q2 2018, the Company approved a new revised list of insider informationOrder No. 236 of April 18, 2018..

The data that constitutes the Company’s insider information is also published in Russian in the news feed of an authorized news agency Interfax Corporate Information Disclosure Center (for more information, see the website) and in English in the London Stock Exchange’s News Monitoring Service (for more information, see the website).

RusHydro’s list of insiders is updated upon inclusion or exclusion of insiders. As at December 31, 2018, the Company’s list of insiders incldued 18 legal entities and 86 individuals. During 2018, six legal entities and 16 individuals were added to the list, while four individuals and one legal entity were excluded.

RusHydro sends proper inclusion/exclusion notifications to the insiders. In 2018, 27 notifications were sent.

In response to the requests of security market operator (PJSC Moscow Exchange), RusHydro provided it with 12 lists of insiders as of the respective dates of the requests.

In 2018, RusHydro received two notifications from its insider George Rizhinashvili, the member of the Management Board, First Deputy General Director of the Company, regarding the sale of his ordinary registered shares in RusHydro through organized trading.

The member of the Management Board and First Deputy General Director in charge of the unit of financial and corporate law management supervises the Company’s compliance with the laws on insider information and submits quarterly reports to the Audit Committee of the Board of Directors of RusHydro. The Audit Committee includes the information on the Company’s compliance with these requirements into its annual report.