Information on Following the Recommendations of the Corporate Governance Code

The Company fully complies with 73.4% of the principles of the Bank of Russia Code, and taking into account the non-applicability of four principles (5%) to the Company due to legal requirements, this figure is 78.5%, which corresponds to the overall level (78%) of implementation of the principles by major public joint stock companies whose shares are included in the top quotation lists of the Moscow Exchange.

Compliance with the Corporate Governance Code Principles in 2020
Implementation of the Corporate Governance Code principles by major public joint stock companies whose shares are included in the top quotation lists of the Moscow Exchange (QL1 and QL2).

The Methodology of Estimating Compliance with Corporate Governance Principles Stipulated in the Corporate Governance Code

The Company’s compliance with the principles stipulated in the Corporate Governance Code (CGC) was estimated in accordance with the Bank of Russia Recommendations on Drawing a Report on Adherence to the CGC Principles and Recommendations.

The Corporate Governance Code Principles and Recommendations Adherence Report (Appendix No. 6) explains the key reasons, factors and (or) circumstances that barred the Company from full compliance with the principles of the CGC.

Results of estimating compliance with the CGC principles
Corporate Governance Principles Principles Recommended in the CGC 2018 2019 2020
Full compliance Partial compliance No compliance Full compliance Partial compliance No compliance Full compliance Partial compliance No compliance
Shareholder rights and equal treatment of all shareholders 13 9 2* 2* 9 2* 2* 9 2* 2*
Board of Directors 36 25 9 2 28 7 1 28 7 1
Corporate Secretary 2 1 - 1 1 - 1 1 - 1
The Company’s Board of Directors and executive management remuneration system 10 7 1 2 7 1 2 7 1 2
Risk management and internal control and audit 6 2 4 - 2 4 - 3 3 -
Information disclosure 7 6 1 - 7 - - 7 - -
Material corporate actions 5 1 3 1 2 3 - 3 2 -
Total score 79 51 20 8 56 17 6 58 15 6
100% 64.6% 25.3% 10.1% 70.9% 21.5% 7.6% 73.4% 19.0% 7.6%

* 4 CGC principles (5%) are not applicable to the Company and cannot be fully observed due to the fact that all voting shares (100%) belong to the sole shareholder represented by the Russian Federation.