RUS

Insiders

Dear insiders,

This section contains information which will help you properly perform your duties as established by legislation of the Russian Federation and the Internal Control Rules to Prevent, Detect and Suppress the Misuse of Insider Information of PAO Sovcomflot and/or Market Manipulation, and will also make it possible to protect lawful interests of PAO Sovcomflot and its investors.

Under the provisions of Federal Law No. 224-FZ dated 27 July 2010* and considering the specifics of its operations, PAO Sovcomflot prepares a proprietary list of insider information including, but not limited to, insider information the list of which is approved the Bank of Russia regulation**.

Proprietary List of Insider Information of PAO Sovcomflot

* Article 3 of Federal Law No. 224-FZ dated 27 July 2010 "On Countering the Misuse of Insider Information and Market Manipulation and Amending Certain Legislative Acts of the Russian Federation".

** Bank of Russia Ordinance No. 3379-U dated 11 September 2014 "On the List of Insider Information of the Entities Mentioned in Clauses 1-4, 11 and 12 of Article 4 of the Federal Law "On Countering the Misuse of Insider Information and Market Manipulation and Amending Certain Legislative Acts of the Russian Federation".

Insider's obligations

Basic information for insiders is contained in a memo prepared for you.

Memorandum for Insiders of PAO Sovcomflot

More detailed information is presented in the Internal Control Rules to Prevent, Detect and Suppress the Misuse of Insider Information of PAO Sovcomflot and/or Market Manipulation approved by the PAO Sovcomflot Board of Directors. The Rules govern relations arising within PAO Sovcomflot and in the course of its interaction with external organisations and individuals in connection with the use of insider information.

Internal Control Rules to Prevent, Detect and Suppress the Misuse of Insider Information of PAO Sovcomflot and/or Market Manipulation

Conditions for making transactions in financial instruments

Conditions for making transactions in financial instruments by insiders and their related persons are set out in Article 6 of the Internal Control Rules to Prevent, Detect and Suppress the Misuse of Insider Information of PAO Sovcomflot and/or Market Manipulation. In particular, the rules prohibit making transactions in the Company's financial instruments during "closed periods", which are determined by taking into account the dates of publication of the Company's financial statements, and establish other restrictions. It is convenient to track "closed periods" with the help of the Investor's Calendar.

NB: Currently there is a "closed period" defined by the investment duration criterion (insiders must have held financial instruments of the Company (directly or through other persons acting on their behalf) for at least six months before selling or otherwise disposing of them).

Notification on transactions executed involving financial instruments

Insiders and their related persons are obliged to notify the Company of transactions in the Company's securities made by them (or by their related persons) and concluded contracts which are derivative financial instruments the price of which depends on such securities within no more than 10 business days of receiving an inquiry from PAO Sovcomflot. The obligation to notify applies to all transactions in which the Insider and the Insider's Related Person is a party, beneficiary, intermediary or representative.

Notification on execution by an insider of transactions involving a financial instrument (.docx form)

Contact Information

If you have any questions concerning the status of an insider, performance of duties imposed on insiders, conditions for making transactions in financial instruments, etc., please send an inquiry to insiders@scf-group.ru. Your inquiry will be received by the Corporate Unit of Sovcomflot's Legal Department and will be processed within one week. If your inquiry requires urgent response, please indicate that in the e-mail subject.