Work With Insider Information
In accordance with the requirements of the legislation of the Russian Federation in the field of information protectionIncluding the Federal Law dated July 27, 2006 No. 149-FL “On Information, Information Technologies and Information Protection”, the Federal Law dated July 29, 2004 No. 98-FL “On Commercial Secrets”, the Federal Law of July 27, 2010 No. 224-FL “On Counteracting the Illegal Use of Insider Information and Market Manipulation and on Amendments to Certain Legislative Acts of the Russian Federation”., the Company approved the List of information containing confidential materials, which include insider information.
In order to enhance information security, reduce the risks of information threats and the consequences of information security rules violation, the Company approved and put into effect a number of regulatory documents in the field of information protection, including insider information:
- Regulations on the protection of information of IDGC of the South, PJSC;
- Regulations of work with the automated system Service Desk;
- Regulations for the use of corporate IT infrastructure.
As of December 27, 2018, the Company approved and transferred in the prescribed manner to Moscow Exchange PJSC (hereinafter referred to as the Moscow Exchange) the list of IDGC of South PJSC insiders in the amount of 1,808 insiders.
A quarterly analysis of the information received from shareholders — insiders of the Company is carried out, internal control over the use of insider information is carried out, information is being monitored for disclosure on the subject of possible use in securities transactions.
Insider category | As of December 31, 2017 | Q1 of 2018 | As of March 31, 2018 | Q2 of 2018 | As of June 6, 2018 | Q3 of 2018 | As of September 30, 2018 | Q4 of 2018 | As of December 31, 2018 | ||||
---|---|---|---|---|---|---|---|---|---|---|---|---|---|
incl. | excl. | incl. | excl. | incl. | excl. | incl. | excl. | ||||||
1 | 31 | – | – | 31 | 5 | – | 36 | 4 | 4 | 36 | 1 | 8 | 29 |
2 | 1 746 | 32 | 25 | 1 753 | 35 | 34 | 1 754 | 37 | 29 | 1 762 | 51 | 54 | 1 759 |
3 | – | – | – | – | – | – | – | – | – | – | – | – | – |
4 | 20 | 1 | 2 | 19 | 1 | – | 20 | 1 | – | 21 | – | 1 | 20 |
Total | 1 797 | 33 | 27 | 1 803 | 41 | 34 | 1 810 | 42 | 33 | 1 819 | 52 | 63 | 1 808 |