Federal Law No. 114-FZ “On Making Amendments to the Federal Law ‘On Joint Stock Companies’ and Certain Acts of Law of the Russian Federation” dated 16 April 2022 (the “Law”) provides for the conversion of depositary receipts into the underlying ordinary shares of Russian issuers without the participation of the foreign depository bank.

On 6 June 2025, the Bank of Russia’s Board of Directors resolved to hold another round of the automatic conversion of the depositary receipts of Russian issuers into shares. A conversion procedure of this kind has already taken place in August—September 2022.

The Law requires that the depositary receipts, the rights to which are recorded in Russian depositories, shall be automatically without holders’ participation converted into the corresponding number of ordinary shares issued by Russian entities.

Not later than on 17 June 2025, issuers are obliged to send a notice of the commencement of the conversion procedure to the depository which holds the shares represented by the depositary receipts. Gazprombank is responsible for the custody of the ordinary shares of PJSC Gazprom that represent the receipts issued under the depositary receipts programmes. The issuer of the depositary receipts (The Bank of New York Mellon) has a depo account under the depositary programmes opened at Gazprombank to record the title to PJSC Gazprom shares.