For Bank Insiders

In accordance with the requirements of Article 9 of Federal Law No. 224-FZ of 27.07.2010 "On Combating the Unlawful Use of Insider Information and Market Manipulation and on Amending Certain Legislative Acts of the Russian Federation" (hereinafter referred to as the Law) the Bank maintains a list of insiders and sends notifications to persons included in the list of insiders about their inclusion in such a list and exclusion from it, as well as informs these persons about the requirements of the Law.

Insiders are the following persons who have actual access to insider information:
- legal entities on the basis of agreements providing for access to information classified as insider;
- natural persons on the basis of labor and (or) civil law agreements;
- members of Boards.
The full list of insiders is given in Article 4 of the Law.

Article 6 of the Law establishes restrictions on the use of insider information and (or) market manipulation: Use of insider information is prohibited:
1) for transactions with financial instruments, foreign currency and (or) goods related to insider information, at its own expense or at the expense of a third party, except for transactions in the performance of the obligation to purchase or sell financial instruments, foreign currency and (or) goods whose due date has come if such obligation arises from a transaction made before the insider information becomes known to the person;
2) by transferring it to another person, except for the cases of transferring this information 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 labor duties or the performance of the contract;
3) by giving recommendations to third parties, obliging or otherwise inducing them to purchase or sell financial instruments, foreign currency and (or) goods.

It is forbidden to carry out actions related to market manipulation in accordance with the Law.

In accordance with Article 10 of the Law, the Bank is entitled to request information from Insiders on transactions carried out by these insiders with financial instruments, foreign currency and (or) goods, which are covered by the insider information to which these insiders have access. For details on the procedure for notifying Insider of transactions, please refer to the Insider Memo.

Financial instruments, foreign currency or goods in respect of which a person included in the list of insiders of ISBANK JSC must send notifications about its transactions in accordance with Article 10 of the Insider Law are indicated in List of financial instrument.

In accordance with Clause 1 of Article 7 of the Law, any person who illegally used insider information and (or) performed market manipulation shall be liable in accordance with the legislation of the Russian Federation.

Contact person responsible for maintaining the insider list:
Davydov Dmitry Viktorovich
phone: + 7 (495) 232-12-34 (доб. 2201)
email address: Dmitry.Davydov@isbank.com.ru