Internal Control and Risk Management System > Insider Information Control System

The insider information-related legal requirements to JSC IDGC of the North-West as an issuer arise due to the fact of placing the Company's financial instruments on trade platforms of Russia: the Moscow Exchange Stock Market.

In accordance with the Company's internal control policy, in order to ensure the compliance with the legal requirements the Company carries out three types of compliance control in the field of insider information: preventive, ongoing and follow-up control.

In order to establish preventive compliance control procedures by the Board of Directors the Company approved the Provision on Insider Information of JSC IDGC of the North-West, which takes into account requirement of Federal Law No.224-FZ of July 27, 2010 on Prevention of Illegitimate Use of Inside Information and Market Manipulation and on Amendments to Certain Laws of the Russian Federation. The following procedures are set forth in the Provision:

  • establishment of rules of creation of a list of the Company's insiders;
  • determination of a list of the Company's insider information;
  • establishment of rules of handling insider information;
  • establishment of rules of performing transactions with insider financial instruments of the Company;
  • conclusion of confidentiality agreements for insider information.

Furthermore, in order to improve preventive control the Board of Directors of the Company approved the Corporate Code of Conduct regulating corporate responsibility and ethics of insiders who are the Company's employees.

Within the framework of ongoing compliance control the Company implements the following procedures:

  • keeping a list of insiders;
  • registering notices of inclusion of a person into the list of insiders or exclusion from such list and of transactions made by insiders with the Company's securities;
  • control over compliance with the rules of performing transactions with the Company's insider financial instruments on the basis of information on (notices of) performance of transactions by insiders.

Within the framework of follow-up compliance control the Company carries out the analysis of:

  • the dynamics of prices for financial instruments of the Company in organized markets;
  • transactions with the Company's securities declared in notices given to the Company by insiders;
  • information on transactions performed by shareholders obtained from the registrar of securities.