Insiders

• Shares
• Bonds

• Comply with the requirements set forth in Nizhnekamskneftekhim's Regulations on Insider Information and the applicable laws
• Take all possible measures to protect and prevent the misuse and dissemination of insider information
• Upon the Company’s request, send information in a digital format on their transactions with the Company’s financial instruments and commodities, as well as on signed contracts that constitute derivative financial instruments and whose price depends on such financial instruments and commodities within ten (10) business days from the date such request is received

• Sharing insider information in any form with third parties, except for parties included in the Company’s list of insiders to fulfil statutory obligations or to perform work duties or contracts
• Using the Company’s insider information for purposes unrelated to their work activities and/or not stipulated by the terms of contracts/agreements entered into with the Company
• Using insider information to carry out transactions with financial instruments or commodities at one’s own or a third party’s expense, save for transactions to perform obligations that have become due if such obligations result from a transaction closed before the person becomes aware of such insider information
• Carrying out other activities that constitute market manipulation under the laws of Russia

• From the reporting year’s end date until the publication of the Company’s annual financial statements under the International Financial Reporting Standards (IFRS) or Russian Accounting Standards (RAS) for the relevant reporting year, whichever is earlier
• From the first business day of each quarter until the publication of the Company’s quarterly report prepared in respect of the preceding quarter. If the Company does not disclose information via a quarterly report, transactions with financial instruments are prohibited from 1 July until the publication of the Company’s 6M report for the relevant reporting year

Effective laws of the Russian Federation provide for:

• Administrative liability for misuse of insider information and/or market manipulation (articles 15.21, 15.30, and 15.35 of the Code of Administrative Offences of the Russian Federation)
• Criminal liability for market manipulation (article 185.3 of the Criminal Code of the Russian Federation) and misuse of insider information (article 185.6 of the Criminal Code)