In accordance with Article 4 of Federal Law No. 224-FZ of 27 July 2010 On Combating Insider Information Misuse and Market Manipulation and on Amendments to Certain Legislative Acts of the Russian Federation (hereinafter the “Federal Law”), VEB.RF belongs to the following categories of insiders:
- issuer (paragraph 1, Article 4 of the Federal Law);
- professional securities market participant that acts as a broker in transactions involving financial instruments, foreign currencies and/or commodities and receives insider information from its clients (paragraph 4, Article 4 of the Federal Law);
- person that has access to insider information of the persons specified in paragraphs 1, 3 and 4 of Article 4 of the Federal Law under contracts with the relevant persons (paragraph 5, Article 4 of the Federal Law);
- person that holds, directly or indirectly (through controlled entities), voting power of at least 25 per cent in the highest governing body of the persons specified in paragraphs 1, 3 and 4 of Article 4 of the Federal Law and also a person that has access to insider information under federal laws, constituent documents or bylaws by virtue of having shares (stakes) in the said persons (paragraph 6, Article 4 of the Federal Law);
- person that has access to information concerning a voluntary, compulsory or competitive bid for shares prepared and/or filed in accordance with the legislation of the Russian Federation on joint-stock companies, including a person that submits a voluntary, compulsory or competitive bid for shares or a call for the redemption of securities to a joint-stock company (paragraph 8, Article 4 of the Federal Law).
As required by the Federal Law, VEB.RF approved:
- Internal control rules to prevent, detect and combat insider information misuse and market manipulation on the part of VEB.RF;
- VEB.RF’s Insider Information List;
- Rules for transactions conducted by VEB.RF’s insiders and their related parties in relation to financial instruments;
- Procedure for access to VEB.RF’s insider information, insider information non-disclosure, and supervision of compliance with the Federal Law and related regulatory acts.
In accordance with Article 10 of the Federal Law, VEB.RF’s insiders shall notify VEB.RF of their completed transactions upon request, using the method of communication specified in the request.
Any document in reply to VEB.RF’s request or any notification submitted by insiders or their related parties in hard copy form shall have bound and numbered sheets and shall be signed by an authorised representative.
If any reply to VEB.RF’s request/notification is signed on behalf of insiders or their related parties by their authorised representatives, then information on the completed transactions shall be accompanied by proof of authority (a duly certified copy thereof).