Gazprombank (Joint Stock Company) (hereinafter, the “Bank”) informs that in accordance with Executive Order of the President of the Russian Federation No. 138 dated 3 March 2023 “On Additional Temporary Economic Measures Related to Circulation of Securities” (hereinafter, the “Executive Order”) and the Bank of Russia Official Interpretation No. 2-OR dated 24 April 2023 “On the Interpretation of Certain Provisions of Executive Order of the President of the Russian Federation No. 138 dated 3 March 2023 “On Additional Temporary Economic Measures Related to Circulation of Securities”, the depository of the Bank maintains separate accounting of Russian securities [1] (hereinafter, the “Securities”) until the depositor provides documents confirming that their Securities do not meet the criteria stipulated by clause 1 of the Executive Order and/or the requirements of the Executive Order do not apply to transactions/operations with their Securities (hereinafter, the “Confirmation Documents”). Therefore, any operations related to Securities acceptance for record-keeping by the depository of the Bank from other depositories and registrars will be followed by the Securities crediting to a separate subaccount of the securities account, and the depository of the Bank will maintain separate accounting until it receives the relevant Confirmation Documents from the depositor. For Securities to be credited to the depositor’s securities account (avoiding separate accounting), the depositor must provide the Bank with Confirmation Documents at the time of submitting the instruction to accept securities for record-keeping. Deponents may also provide Confirmation Documents for the purpose of separate accounting termination together with the application for termination of separate accounting (hereinafter, the “Application”) or when filing an instruction to withdraw securities from record-keeping and (or) instruction to transfer securities. 1. Confirmation Documents requirements 1.1. Documents confirming title to Securities that were registered by foreign record-keeping systems as of the date (before/after 1 March 2022) as well as continuous ownership of the said Securities from the time of their acquisition to the time of their crediting to the securities account (personal account) of the same depositor with a Russian depository/registrar, include an account statement (a copy thereof), or a report on Securities flow (a copy thereof), or a printed image of an electronic document confirming the account status as it appears in the Customer’s personal account on the website of the foreign broker/depository, or other confirmation documents. If the depository of the Bank maintains separate accounting of shares of Russian issuers obtained as a result of depositary receipts conversion (hereinafter, the “Shares” and “DRs”, respectively), Confirmation Documents are required in respect of both the Shares and the DRs. 1.2. Documents confirming acquisition of Securities (if the depository of the Bank maintains separate accounting of Shares, documents should be provided in respect of the DRs) after 1 March 2022 from an RF resident, a “friendly” non-resident [2] or a controlled foreign company (CFC) [3] may include a sale-and-purchase agreement, another document that constitutes grounds for transfer of title to the Securities, as well as documents confirming the seller’s RF residency and (or) absence of grounds for placing the counterparty (seller) into the category of Parties from Unfriendly Foreign Countries [4], and other documents. 1.3. If the depositor transferred the Securities to the Bank from their securities/personal account with another Russian depository/registrar, the depositor must provide an owner’s securities (personal) account statement (report/certificate) from such depository/registrar [5] demonstrating the Securities flow for the whole accounting period starting from 1 March 2022 or earlier. If the Securities flow statement (report/certificate) does not contain information on the grounds for crediting the Securities to the owner’s account with a Russian depository/registrar after 1 March 2022, and information on the party from whose account the Securities were credited to the owner’s account after 1 March 2022, such information must be provided in a separate statement, report, or certificate issued by the depository/registrar of the deponent’s counterparty. 1.4. Confirmation Documents must contain information, which enables identification of the deponent and the Securities, as well as the counterparty (if the Securities were acquired from an RF resident, a “friendly” non-resident or a CFC). 1.5. Confirmation Documents may be prepared either in Russian or in a foreign language. If a document is issued in a foreign language, a translation into Russian must also be provided. A statement/report/printed image of an electronic document confirming the account status as it appears in the Customer’s personal account on the website of the foreign broker/depository drafted in English does not require translation into Russian. The Securities (as well as DRs) flow statement/report/certificate issued by a Russian depository/registrar must be provided as an original hard copy document, a notarized copy, or an electronic document received via electronic document exchange channels with an electronic signature key certificate of the document issuer. Documents certifying acquisition of Securities must be provided as an original hard copy document/a notarized copy/a copy certified by the deponent (if the deponent is a legal entity). The Bank may accept the above documents is other forms. Please, note that Securities, for which the Bank maintains separate accounting in accordance with clause 7 of the Executive Order, are subject to a special procedure for making transactions (operations) on the basis of permits issued by the Central Bank of the Russian Federation or the Government Commission on Monitoring Foreign Investment in Russia. To submit documents, depositors should address Account Managers in Bank GPB (JSC) offices where depository services are provided: [1] Shares of a Russian joint-stock company, federal loan bonds, bonds of a Russian issuer, the centralized recording of rights to which (mandatory centralized custody of which) is conducted by a Russian depository, investment units of a Russian mutual investment fund. [2] Foreign entities other than Parties from Unfriendly Foreign Countries (in the language of the Executive Order). [3] An entity that meets the requirements of both sub-clause ‘a’ and sub-clause ‘b’ of clause 12 of Executive Order of the President of the Russian Federation No. 95 dated 5 March 2022 “On a Temporary Procedure for Meeting Obligations to Certain Foreign Creditors”. [4] Parties from Unfriendly Foreign Countries include foreign entities associated with foreign countries involved in unfriendly acts towards the Russian Federation, Russian legal entities and individuals (including but not limited to foreign individuals who are citizens of such countries, and foreign entities which have a place of incorporation, principal place of business or place where most of their income is generated in such countries), and entities that are controlled by such foreign entities notwithstanding their place of incorporation (except when the place of incorporation is the Russian Federation) or principal place of business. [5] If on or after 1 March 2022 the Securities were registered by several depositories/registrars, relevant statements/reports from all record-keeping systems must be provided. |