In addition to NSD's communications from December 23, 2022, to February 1, 2023, NSD informs that on April 26, 2023, a call took place with Clearstream Banking S.A. (hereinafter — Clearstream), during which Clearstream reported receiving a memorandum from an external legal advisor regarding clarifications from the Luxembourg Ministry of Finance concerning the General Authorization posted on the MoF Luxembourg website on December 20, 2022.

The memorandum was sent to NSD depositories via communication channels stipulated in the depository service agreement on April 28, 2023.

On February 1, NSD sent targeted notifications to clients regarding further interaction procedures between NSD, clients, and Clearstream.

On January 12, NSD sent targeted notifications to clients regarding further interaction procedures between NSD, clients, and Clearstream.

On January 11, NSD sent targeted notifications to clients regarding further interaction procedures between NSD, clients, and Clearstream.

On January 10, NSD sent targeted notifications to clients regarding further interaction procedures between NSD, clients, and Clearstream.

On January 9, NSD sent targeted notifications to clients regarding further interaction procedures between NSD, clients, and Clearstream.

In addition to communications dated 23.12.2022, 26.12.2022, 27.12.2022, 28.12.2022, 29.12.2022, 30.12.2022, 04.01.2023, and 05.01.2023, NSD notifies depositories of the following:

• To initiate payment transfers due to NSD depositories to bank accounts opened at correspondent banks, you must upload an Inventory in the prescribed form to the DATAROOM, which was sent individually to depositories on 28.12.2022.

Uploading this Inventory to the DATAROOM is considered a request and client consent for document transfer to Clearstream.

If you previously uploaded such an Inventory to the DATAROOM, re-upload is not required.

This information will be available to Clearstream in the DATAROOM; login and password credentials for accessing the Clearstream DATAROOM have been provided.

Additionally, please note that the Offer and Acceptance applies to both foreign securities stored at Clearstream and foreign securities stored at Euroclear.

Please note that after termination of the agreement (acceptance of the offer), obligations to transfer payments on foreign securities credited prior to termination remain in effect.

On January 5, 2023, NSD sent targeted information to clients regarding the further procedure for interaction with Clearstream regarding asset unlocking.

Attention to depositories whose NSD depository accounts hold foreign securities

1. In response to numerous client inquiries regarding interaction with Clearstream and Euroclear for asset unlocking, NSD sent targeted Offer letters to clients on January 4, 2023, to terminate depository account agreements regarding foreign securities.
   
   All depositories intending to submit applications for asset unlocking under the issued licenses must send NSD an Acceptance of termination in the form attached to the offer. The contractual relationship will be terminated from the date NSD receives the Acceptance.
   
   Upon request, NSD may provide clients with a confirmation letter regarding the termination of contractual relationships for foreign securities servicing.
   
   If your depository account holds foreign securities and you have not received the aforementioned offer, please contact your personal NSD manager.

2. Additionally, NSD sent targeted additional information to clients regarding the data transmission format to foreign depositories Clearstream and Euroclear under current restrictions.

At the working meeting with Clearstream on December 30, 2022, Clearstream informed NSD that, as a result of its interaction with the Luxembourg Ministry of Finance, previously received information regarding asset unlocking changed significantly:

1. The General Authorization cannot be executed by Clearstream as the applicant, as it requires full termination of contractual relations with NSD for all assets accounted for at NSD, which, in Clearstream's view, is not feasible.

2. According to the General Authorization, only securities issued in Luxembourg are eligible for exemption. For assets from any other EU countries and any other jurisdictions, regulator consent must be obtained by January 7, 2023. The procedure for obtaining regulator consents from other jurisdictions has not been defined.
   
   Thus, the General Authorization cannot be executed.

3. As an alternative mechanism, the Luxembourg MoF will consider issuing licenses for individual applicants, analogous to the Belgian Treasury.

4. Information on ceasing separate accounting of securities for unlocking via Clearstream and the algorithm for calculating securities eligible for unlocking via Euroclear has been sent targeted to depositories.

NSD continues work aimed at finding a solution for unlocking client assets.

NSD continues daily interaction with clients within the asset unlocking process. On December 29, NSD sent a message to clients containing:

• Clarifications on interaction procedures, including document submission

• Invitation to a webinar on DATAROOM operations on 30.12.2022.

If you did not receive this information, please contact your personal NSD manager.

NSD sent a message to clients containing:

• Letter of certification form.

• Instructions for uploading documents to the DATAROOM.

• Inventory of funds related to securities payments, segmented by ultimate securities owners.

• Updated list of securities by storage locations eligible for unlocking.

• Detailed information on funds related to securities payments that may be claimed for unlocking via Clearstream Banking SA (Luxembourg) in foreign currencies other than USD, RUB, and CNY. Information is as of 23.12.2022. Information on payments after 23.12.2022 will be provided separately.

NSD sent a message to clients containing:

• Details of operational and technological interaction within asset unlocking actions, including information on procedures and deadlines for securities segregation.
  
  Operations for segregating or returning securities to the sections from which they were debited will not be tariffed. At the same time, NSD notes that execution of operations from these sections via Clearstream Banking SA (Luxembourg) will not be tariffed within previously established marketing periods valid until March 31, 2023.
  
  Asset unlocking operations will be carried out in compliance with restrictions established by current Russian legislation.

• Inventory of ultimate owners and nominee holding chain.

• Detailed information on funds related to securities payments that may be claimed for unlocking via Clearstream Banking SA (Luxembourg) in the following currencies: USD, RUB, CNY. Information is as of 23.12.2022. Information on payments after 23.12.2022, as well as payments in other currencies, will be provided separately.

Please note that the following information was sent to you individually:

• list of securities by storage locations eligible for unlocking;

• minimum set of data for owner identification (KYC);

• unlocking event schedule.

If you did not receive this information, please contact your personal NSD manager.

From 29.12.22 to 04.01.23, NSD will accept documents for unlocking. The document acceptance procedure will be provided separately.

Information regarding the Euroclear license will be posted on December 27, 2022.

This Procedure does not constitute an interpretation of the General License issued by the Luxembourg Ministry of Finance; it contains a preliminary description of the NSD and depositories interaction process for investor asset exemption under the Luxembourg MoF General License, based on NSD-available information obtained from official sources, as well as results of working consultations with Clearstream, and may be changed, clarified, or supplemented.

1. Unlocking investor assets and their due payments is carried out through direct interaction between NSD and Clearstream.

Clearstream acts as the applicant, obligated to terminate agreements with NSD no later than January 7, 2023, and submit to the Luxembourg MoF confirmations as stipulated in points 3.4.2–3.4.3 of the License.

Instructions and all necessary documents, in turn, are received by Clearstream exclusively from NSD.

Securities that will not be transferred under the License will continue to be accounted for at Clearstream; depository servicing restrictions will be discussed separately, with mandatory corporate actions preliminarily confirmed.

2. NSD includes in the transferable scope securities that are held on NSD depository accounts and have, according to the security questionnaire, a single storage location — Clearstream.

For securities with questionnaires specifying two storage locations, NSD determines the number of securities eligible for exemption on a proportional basis, provided the following conditions are met:

• the security issuer is not under sanctions;

• the depository-depository of NSD and all depositories through which ultimate owner rights are accounted for are not under sanctions;

• the ultimate owner is not under sanctions.

Hereinafter, "sanctions" refers to US and European blocking sanctions.

The NSD depository confirms the absence of entities under the aforementioned sanctions in submitted documents and depository lists within the accounting chain, as well as among ultimate owners. NSD verifies issuer sanctions.

Regarding sanctions imposed on issuers, accounting chain depositories, and ultimate owners in other jurisdictions, the NSD depository must disclose the existence of such circumstances and assumes all responsibility and risks associated with non-execution of submitted instructions for unlocking investor assets, as well as any additional restrictions that may be imposed on the exempted assets.

3. Regarding securities payments, payments to which their ultimate owner (not under sanctions) is entitled may be exempted, regardless of whether the depository in the accounting chain is under sanctions.

To unlock client securities, the NSD depository must submit to NSD in English, French, or German:

a. KYC document package for each ultimate owner¹ or, if documents for ultimate owners were previously submitted to obtain an individual license from the Luxembourg MoF — copies of documents and details of the document submitted to the Luxembourg MoF.

b. The document package must include information on the depository chain, presented as a separate letter signed by the depository's authorized representative confirming the accuracy of the provided data. Form is at the applicant's discretion.

c. Depository instruction (Form 36) specifying ISIN, number of securities, and credit account² simultaneously with the Ultimate Owners and Nominee Holding Chain Inventory (template will be provided separately). Depository instructions are submitted electronically via NSD electronic document management. Inventory form will be provided separately. Instructions are submitted per single ISIN and single credit account.

d. Written certification in two languages — Russian and at the applicant's choice (English, French, or German) regarding circumstances, in which the NSD depository certifies to NSD that all provided information (as of the date) is current, accurate, and complete. The depository confirms that among persons whose information was submitted to NSD for the purpose of unlocking securities owned by said persons, among servicing depositories, and among security issuers, there are no persons under EU (or any other jurisdiction) sanctions, consent to securities blocking, consent to transfer of personal data and legally protected information (depository secrecy). The depository confirms that it will not hold claims against NSD related to potential non-compliance with restrictions established by Federal Law No. 127-FZ³.

The NSD depository confirms the absence of entities under the aforementioned sanctions in submitted documents and depository lists within the accounting chain, as well as among ultimate owners.

Regarding sanctions imposed on issuers, accounting chain depositories, and ultimate owners in other jurisdictions, the NSD depository, if such circumstances exist, bears all risks and responsibility associated with non-execution of submitted instructions for unlocking investor assets, as well as any additional restrictions that may be imposed on the exempted assets.

e. For asset unlocking, NSD will determine and fix the proportion by securities storage locations and inform depositories of this information. In preparing instructions for Clearstream, NSD will rely on the specified proportion and the free balance of securities.

The event schedule will be provided separately.

¹ Requirements for the document list, submission/certification format, and transmission channels are clarified with Clearstream; the necessity of submitting documents for depositories participating in the securities accounting chain is also clarified.

² Simultaneously with the instruction submission, a "specification" is submitted indicating the ultimate owner, accounting chain depositories, and number of securities.

³ Federal Law No. 127-FZ dated 06/04/2018 "On Measures to Counteract (Respond to) Unfriendly Actions of the United States of America and Other Foreign States".

1. To unlock securities payments (USD, RUB, CNY), the NSD depository must submit to NSD in English, French, or German:

a. KYC document package for each ultimate owner⁴ or, if documents for ultimate owners were previously submitted to obtain an individual license from the Luxembourg MoF — copies of documents and details of the document submitted to the Luxembourg MoF.

b. "Specification" for all ultimate owners on whom the depository submits documents, entitled to receive payments, specifying ISIN, amounts per owner, and bank details at non-sanctioned banks of the relevant jurisdiction.

c. Written certification in two languages — Russian and at the applicant's choice (English, French, or German) regarding circumstances, in which the depository certifies to NSD that all provided information (as of the date) is current, accurate, and complete. The depository confirms that among ultimate owners whose information was submitted to NSD for the purpose of unlocking securities payments owned by said persons, there are no persons under sanctions, consent to transfer of personal data and legally protected information (banking secrecy). The depository confirms that it will not hold claims in the event NSD is designated by the depository as the recipient bank for securities payments.

2. NSD informs depositories of the securities payment amounts accounted for on internal accounts segmented by storage locations.

3. NSD executes unlocking of payments in foreign currencies of jurisdictions that have imposed sanctions on NSD (European and Swiss jurisdictions) only if, for unlocking securities payments, the NSD depository has submitted bank account details at credit institutions in the Luxembourg jurisdiction. NSD cannot be designated as the recipient/recipient bank for said payments.

4. NSD executes unlocking of securities payments in Canadian dollars, British pounds, and Hong Kong dollars only if depositories specify bank details in the corresponding jurisdictions. NSD cannot be designated as the recipient/recipient bank for said payments.

Possibility of conversion and payment of income in another currency or Russian rubles is clarified with Clearstream.

When submitting bank details to the specification of persons entitled to receive securities payments, bank details of a sanctioned bank cannot be specified.

The event schedule will be provided separately.

⁴ Requirements for the list, submission/certification format, and transmission channels are clarified with Clearstream.