Information for insiders
Information disclosure on the website of Interfax News Agency (in Russian)
This section contains information required for the insiders of Gazprom to perform their duties under the current laws of the Russian Federation, the regulatory acts of the Bank of Russia adopted thereunder, and the internal documents of Gazprom on countering the illegal use of insider information and market manipulation, as well as information on the legal consequences of illegal use of the Company's insider information and/or market manipulation by insiders.
According to Article 2 of Federal Law No. 224-FZ dated July 27, 2010, on Countering the Illegal Use of Insider Information and Market Manipulation and on Amending Certain Legislative Acts of the Russian Federation (hereinafter referred to as the “Law”), “insider information” means any accurate and specific information that has not been disseminated or disclosed (including data constituting a trade, business, banking or communication secret or other legally protected secret) and that, if disseminated or disclosed, could have a significant impact on the price of the Company's stock and derivatives.
Pursuant to the requirements of the Law:
- the Gazprom Board of Directors approved the Regulation on monitoring compliance with laws on countering illegal use of insider information and market manipulation at PJSC Gazprom
(PDF, 34.5 KB)by Resolution No. 3338 dated November 19, 2019;
- the Gazprom Board of Directors outlined the Terms and conditions of transactions with financial instruments by individuals and entities included in Gazprom’s insiders list and by their affiliated persons
(PDF, 382.4 KB)by Resolution No. 3452 dated June 11, 2020;
- the Company designated a structural unit to monitor compliance with the Law and the regulatory acts adopted thereunder by Order No. 305 dated November 2, 2012;
- the Company approved the Access procedure for insider information of Gazprom and the confidentiality protection rules by Order No. 34 dated January 30, 2014;
- the Company approved the List of insider information by Order No. 417 dated December 30, 2011 (as amended by the Company's Order No. 716 dated November 16, 2016, and Order No. 200 dated April 23, 2018).
All individuals and entities included in or removed from the Company's Insiders List are notified thereof in writing by Gazprom.
All individuals and entities included in the Company's Insiders List are subject to restrictions under Article 6
The insiders and their affiliated persons are prohibited from carrying out any transactions with the Company’s financial instruments during the “prohibitive periods.”
The procedure and timelines for sending the notifications mentioned in Article 10 of the Law are determined by the Federal Financial Markets Service's Order No. 13-51/pz-n dated June 18, 2013, on the approval of the Regulation governing the notification of individuals or entities of their inclusion in the insiders list and removal from such list, Regulation on the submission of insiders lists to the trade organizers that manage transactions in financial instruments, foreign currencies and/or commodities, Regulation on the procedure for and timelines of sending notifications by insiders on the transactions conducted (hereinafter referred to as the “Regulation on Notification”).
Pursuant to the Law and the Regulation on Notification, Gazprom's insiders shall, within ten (10) business days from the date of receiving a request/demand/instruction to that effect from Gazprom/the Bank of Russia, notify the Company and/or the Bank of Russia of the transaction performed (notifications forms for insiders performing transactions in financial instruments).
The insider has the right to combine information about several transactions in one notification. The terms of each transaction shall be described separately.
Notification methods and addresses:
- delivery to Gazprom's correspondence division with a note confirming the receipt (address: 16 Nametkina St., 117997, Moscow; 156A Moskovsky Ave., 196105, St. Petersburg);
- delivery via Russian Post by registered mail with the acknowledgement of receipt to the Company to PO BOX 1255, 190900, St. Petersburg.
Notifications may be addressed to Head of Department 105 (Elena Mikhailova).
- delivery to the dispatch office of the Bank of Russia (3 Sandunovsky Ln., Bldg. 1, Moscow);
- delivery by registered mail with the acknowledgement of receipt to the Bank of Russia to 12 Neglinnaya St., 107016, Moscow.
Notifications shall be addressed to the head of the Bank of Russia.
If the notification on transactions performed by the insider is issued as a hard-copy document, it shall be signed by the insider or by the insider's authorized representative; if the insider is a legal entity, the notification shall bear the seal of such legal entity.
If the hard copy includes more than one sheet, it shall be bound and paginated. If the insider sending the notification is a legal entity, the hard copy shall bear the seal of such legal entity at the binding and the signature of the authorized representative of such legal entity. If the insider sending the notification is an individual, each page of the hard copy shall be signed by such individual.
If the notification is sent on behalf of the insider by an authorized representative, the notification shall be supplemented with a power of attorney (or a duly certified copy thereof) or another document (or a duly certified copy thereof) granting the authority to such representative.
The insider's liability for the illegal use of insider information and/or market manipulation is determined in Article 7
Moreover, the applicable laws of the Russian Federation provide for:
Administrative sanctions for the illegal use of insider information and/or market manipulation, as per Articles:
(PDF, 187.6 KB),
(PDF, 183.7 KB),
(PDF, 96.3 KB)of the Code of Administrative Offences of the Russian Federation.
Criminal sanctions for:
- market manipulation, as per Article 185.3
(PDF, 191.4 KB)of the Criminal Code of the Russian Federation,
- illegal use of insider information, as per Article 185.6
(PDF, 187.1 KB)of the Criminal Code of the Russian Federation.
If you are an insider of the Company and you have revealed violations concerning the use of insider information or have any questions concerning the performance of obligations under the Law, please call +7 812 609-76-50.
The contact person is Elena Romanova.