Further references:

• FHC – Foreign Holding Company

• ESO – Economically Significant Organization

• FHC securities – shares and/or depositary receipts for FHC shares

If rights to FHC securities held by holders are recorded in Russian depositories, such persons may transition to direct ownership of shares in an ESO acquiring public status in accordance with a specific procedure. This procedure is determined by the following documents and legislation:

Timelines for transitioning to direct ownership are determined by the timelines for the arbitration court's decision to suspend the FHC from exercising corporate rights over the ESO.

Article 7 of Law No. 470-FZ states:

• persons indirectly owning ESO shares belonging to the FHC, who are citizens of the Russian Federation and/or residents of the Russian Federation in accordance with Federal Law No. 173-FZ dated December 10, 2003 “On Currency Regulation and Currency Control”, are obliged to transition to direct ownership of ESO shares

• at the same time, persons who are not citizens of the Russian Federation and/or not residents of the Russian Federation have the right to transition to direct ownership of such shares.

For your convenience, the information below is grouped into sections depending on the record-keeping chain for FHC shares or securities of a foreign issuer certifying rights to FHC shares (hereinafter – FHC depositary receipts).

You are a resident of the Russian Federation in accordance with Federal Law No. 173-FZ dated December 10, 2003 “On Currency Regulation and Currency Control”. The rights to FHC securities owned by you are recorded in any of the following depot accounts (subaccounts), including Type 'C' depot accounts, opened in Russian depositories, including NSD:

• owner depot account, trustee depot account, deposit depot account, escrow agent depot account, investment partnership depot account;

• trading depot accounts opened in accordance with Article 15 of Federal Law No. 7-FZ dated February 7, 2011 “On Clearing and Clearing Activity” (hereinafter – Federal Law No. 7-FZ), which are the owner's trading depot account, the trustee's trading depot account;

• owner and trustee subaccounts opened to a clearing depot account opened in accordance with Article 16 of Federal Law No. 7-FZ.

In this case, your Russian depository will provide NSD, acting as the central depository, with information about the corresponding depot account (subaccount) and the quantity of FHC securities recorded in such account (subaccount). NSD will forward the corresponding information to the ESO, after which ESO shares will be credited in accordance with the procedure provided for by the BoR Resolution.

For NSD clients with the accounts listed above, no additional actions are required; ESO shares will be credited to the same depot account (subaccount) opened at NSD where rights to FHC securities are recorded.

If you hold FHC securities not in a Russian depository, to transition to direct ownership of ESO shares, you must apply directly to the ESO.

The date by which the list of FHC security holders must be compiled in accordance with the BoR Resolution will be published on the NSD website in the “Client Notifications” section.

Additionally, NSD will send you a request to compile such a list in the form of a corporate action notification of type “OTHR – Other Event” (hereinafter – CA OTHR) CA311 with an attached Excel form.

• For NSD depositaries, the request will be sent via targeted distribution using EDM.

• For Russian depositories that are not NSD depositaries, the request will be sent via email address indicated in the Register of the Bank of Russia or other public sources.

Russian depositories that maintain record-keeping of rights to FHC securities in nominal holder accounts must forward to NSD information on persons indirectly owning ESO shares, required in accordance with paragraph 1.5 of the BoR Resolution, in an Excel file format using the form attached to the NSD request.

• Additionally, NSD depositaries must forward a CA333 Instruction (operation code – 68/CAIR0) indicating the total quantity of securities with information contained in the Excel file

• Russian depositories that are not NSD depositaries, in addition to information on persons indirectly owning ESO shares, must provide an Instruction in a free format on an official company letterhead signed by an authorized person, along with documents confirming such person's authority (https://www.nsd.ru/en/documents/docs_in/)

Russian depositories that do not maintain record-keeping of rights to FHC securities must notify NSD of the absence of depot accounts where rights to such securities are recorded. For this, an instruction in CA333 format (operation code – 68/CAIR0) indicating the quantity of securities = 0, or an instruction in a free format on an official company letterhead signed by an authorized person (for Russian depositories that are not NSD depositaries), must be forwarded to NSD.