Information for Insiders of the Company

Dear Sir / Madam!

Public Joint-Stock Company of energy and electrification Lenenergo (further Company) is a public company securities of which are included into the quotation lists of MICEX Stock Exchange.

In order to secure the compliance with the Federal law as of the 27th of July, 2010 No. 224-ФЗ “About the counteraction against the unlawful use of insider information and market manipulating” (further ФЗ-224) the Board of Management of the Company confirmed the Regulation about the insider information of Lenenergo PJSC (Minutes No.45 of 06.06.2019) which sets the order of access to the insider information, the rules of securing its confidentiality and control of its compliance with ФЗ-224 and adopted laws and regulations.

The Company keeps up-to-date the List of insider information and the List of insiders which have the special order of carrying out transactions of the Company (Addendum No. 5 to the Regulation).

Since the moment of putting the person into the List of insiders of the Company, liabilities and requirements are put on him that are foreseen by Article 6 ФЗ-224, the responsibility is defined in accordance with Article 7 ФЗ-224, and the obligations are put on such a person in accordance with Article 10 ФЗ-224 as well as the responsibility of implementation requirements of the Regulation on the insider information of the Company.

Those who are put into the list of insiders of the Company must comply with the order of confidentiality of insider information set by the Company – Rules of handling insider information (Addendum No. 4 to the Regulation).

Those having the access to the insider information relating to the Company or their financial instruments are not allowed to use the insider information:

1) in order to conduct transactions with financial instruments of the Company which are covered by the insider information at one’s own expense or at the expense of the third person. The exception is conducting operations concerning the implementation of obligation of buying or selling financial instruments of the Company maturity date of which has already come if such an obligation has occurred as a result of a transaction that has been carried out before the person get to know the insider information;

2) by giving it to the other person, for the exception of cases when the information is given to the person who is included into the list of insiders in case of keeping compliance with laws of Russian Federation or in case of implementing labor obligations or civil law contract;

3) by giving recommendations to the third parties, oblige or motive them to buy or sell financial instruments of the Company in other way;

4) in order to manipulate the market.

In carrying out security transactions insiders must:

1. Inform the Company of carrying out the transactions with its financial instruments in the set form (Addendum No. 8 to the Regulation);

2. Send the Company a Notice of the state of ownership of securities of the Company as of the election to the position in the set form (Addendum No. 6 to the Regulation) and the Confirmation about the volumes of the insider’s securities as of the end of the report quarter and transactions with securities carried out during the report quarter (Addendum No. 7 to the Regulation);

Please pay attention that non-compliance with the requirements of the law in the field of counteraction against unlawful use of insider information leads to civil, administrative and criminal liability according to article 15.21 of the Code of Russian Federation about the administrative violations and article 185.6 of the Criminal Code of Russian Federation.

Detailed information is provided in the sector of anticorruption compliance procedures of Lenenergo PJSC :

Telephone: +7 (812) 494-32-41.

Correspondence address: 196247, St. Petersburg, Constitution Square, 1

E-mail: Chumak.YV@nwenergo.com