List of Insider Information of Gazprombank (Open Joint-Stock Company) 1. General Provisions

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1 Approved by Order No.79 issued by Gazprombank (Open Joint-Stock Company) on July 28, 2011 List of Insider Information of Gazprombank (Open Joint-Stock Company) 1. General Provisions 1.1. The list of insider information of Gazprombank (Open Joint-Stock Company) (the List ) is made pursuant to Order No.11-18/pz-n issued by the Federal Financial Markets Service of the Russian Federation on May 12, 2011 "On Approving the List of Information Constituting the Insider Information of the Persons Mentioned in Clauses 1 to 4, 11 and 12 of Article 4 of the Federal Law On Combating Illegal Use of Insider Information and Market Manipulation and Amending Individual Statutory Acts of the Russian Federation as well as Procedure and Timing for Disclosing Such Information This List contains the comprehensive list of information constituting the insider information of Gazprombank (Open Joint-Stock Company) (hereinafter referred to as "GPB (OJSC)") The terms "controlling person", "controlled person (controlled entity)" and "entity controlled by issuer being of significant importance for it" are used in this List as defined in Federal Law No. 39-FZ "On Securities Market" dated April 22, The information concerning issue-grade securities to be offered by GPB (OJSC) mentioned in sub-clauses 2.13 to 2.16 of clause 2 of the List shall constitute the insider information of GPB (OJSC) if: the issue-grade securities of GPB (OJSC) are to be offered during the trading process conducted by a trade organizer operating in the securities market; the issue-grade securities of GPB (OJSC) to be offered represent an additional issue in relation to the issue-grade securities of the issue that has been admitted to trading at the trade organizer in the scurrilities market or in respect of which an application seeking their admission to trading at the trade organizer operating in the securities market has been filed The information about placed (circulating) issue-grade securities of GPB (OJSC) contemplated by sub-clauses 2.12, 2.18, 2.19, 2.23, 2.37 and 2.41 of clause 2 of the List shall constitute the insider information of GPB (OJSC) if such issue-grade securities have been admitted to trading at a trade organizer operating in the securities market or in respect of which an application seeking their admission to trading at the trade organizer operating in the securities market has been filed The information about a person who has granted a security for bonds issued by GPB (OJSC) and about conditions of granting such security as contemplated by sub-clauses 2.7 to 2.11, 2.30, 2.33, 2.34 and 2.36 of clause 2 of the List shall constitute the insider information of GPB (OJSC) if such bonds have been admitted to trading at a trade organizer operating in the securities market or in respect of which an application seeking their admission to trading at the trade organizer operating in the securities market has been filed The information about a person who has granted a security for issuer bonds contemplated by sub-clauses 2.7 to 2.11, 2.30 and 2.34 of clause 2 of the List shall not constitute the insider information of GPB (OJSC) if such person is the Russian Federation that has issued a government guarantee of the Russian Federation or a constituent entity of the Russian Federation that has issued a government guarantee of constituent entity of the Russian Federation and (or) a municipal formation that has issued a municipal guarantee covering issuer bonds Insider information shall not include any information and (or) data based on it that is (are) disclosed by GPB (OJSC) and (or) by a person(s) designated by it to potential buyers or is (are) used by GPB (OJSC) or a person(s) designated by it to issue recommendations to or inducing potential

2 2 buyers to purchase the relevant securities in connection with the placement (arrangement of placement) and (or) offering (arrangement of offering) of issue-grade securities of GPB (OJSC) in or outside the Russian Federation, including by placing securities of a foreign issuer confirming rights or titles to issue-grade securities of GPB (OJSC) provided that the potential buyers have been notified that such information (data) may be used by them only to make a decision on whether or not to purchase the securities being placed (offered) Information contained in instructions mentioned in clauses 3.1 to 3.3 of the List that have been received from customers and are required to be fulfilled shall constitute insider information if it is about the price and amount (number) of securities, currencies, exchange-traded commodities, contracts being financial derivatives or actions that must be done to fulfill such instructions (purchase (buying) or disposal (selling), entry into a contract (contracts) being a financial derivative). 2. List of Information Constituting the Insider Information of GPB (OJSC) as That of an Issuer The insider information of GPB (OJSC) as that of an issuer shall include information: 2.1. About the convening and holding of a General Meeting of Shareholders of GPB (OJSC) including information about its agenda, date of the meeting, date on which the list of persons authorized to take part in the General Meeting is made as well as information about resolutions adopted by the General Meeting of Shareholders of GPB (OJSC) About the agenda of a meeting of the Board of Directors of GPB (OJSC) and resolutions adopted by it About any facts when the Board of Directors of GPB (OJSC) has failed to adopt any resolutions that have to be adopted pursuant to federal laws: for convening an annual (regular) general meeting of shareholders of GPB (OJSC) or other resolutions associated with preparation for or the convening or holding of an annual (regular) general meeting of shareholders of GPB (OJSC); for convening (holding) or rejecting a request to convene (hold) an extraordinary general meeting of shareholders of GPB (OJSC) made by the Auditing Commission of GPB (OJSC), an auditor of GPB (OJSC) or shareholders (a shareholder) representing at least 10 per cent of voting shares in (members holding in aggregate at least one tenth of the total votes held by the members of) GPB (OJSC); for including or rejecting a request for including items into the agenda of a general meeting of shareholders of GPB (OJSC) or nominees into the list of nominees for election in the relevant body of GPB (OJSC) proposed or put forward by shareholders (a shareholder) holding in aggregate at least 2 per cent of voting shares in GPB (OJSC); for creating a sole executive body of GPB (OJSC) at two consecutive meetings of the Board of Directors of GPB (OJSC) or within two months after the termination or expiration of powers of the sole executive body of GPB (OJSC) created earlier in the case contemplated by Article 69(6) of Federal Law No.208-FZ "On Joint-Stock Companies" dated December 26, 1995; for early terminating the powers of the sole executive body of GPB (OJSC) at two consecutive meetings of the Board of Directors of GPB (OJSC) in the case contemplated by Article 69(7) of the Federal Law On Joint-Stock Companies"; for convening (holding) an extraordinary General Meeting of Shareholders of GPB (OJSC) if the number of members of the Board of Directors of GPB (OJSC) becomes less than required to constitute the quorum necessary to transact business at a meeting of the Board of Directors of GPB (OJSC); for creating a temporary sole executive body of GPB (OJSC) and holding an extraordinary General Meeting of Shareholders of GPB (OJSC) to decide on whether or not to terminate the powers of its sole executive body or management company (manager) and on establishing a new sole executive body or delegating the powers of its sole executive body to a management company

3 3 (manager) if the Board of Directors of GPB (OJSC) resolves to suspend the powers of its sole executive body or of its management company (manager) About filing an application of GPB (OJSC) to make records in the Unified State Register of Legal Entities in connection with a reorganization, winding-up or liquidation of GPB (OJSC) or, where the body responsible for registering legal entities rejects a request for making such records, details of such decision About qualifying an entity controlled by GPB (OJSC) as a controlled entity being of significant importance for it or terminating grounds for controlling such entity About qualifying a person as a person controlling GPB (OJSC) or terminating grounds for such control About any reorganization or liquidation decision adopted by an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) and being of significant importance for it or by a person who has granted a security to cover bonds issued by GPB (OJSC) About any filing by an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) and being of significant importance for it or by a person who has granted a security to cover bonds issued by GPB (OJSC) of an application to make records in the Unified State Register of Legal Entities in relation to any reorganization, winding-up or liquidation thereof About qualifying an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) and being of significant importance for it or by a person who has granted a security to cover bonds issued by GPB (OJSC) as meeting the insolvency (bankruptcy) test contemplated by the insolvency (bankruptcy) laws of the Russian Federation About the filing of a petition with an arbitration court seeking the declaring of GPB (OJSC) or an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) and being of significant importance for it or by a person who has granted a security to cover bonds issued by GPB (OJSC) bankrupt or a decision made by an arbitration court to declare them bankrupt or to initiate bankruptcy proceedings in respect of them or terminate bankruptcy proceedings initiated against them About a legal action brought by GPB (OJSC) or an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) and being of significant importance for it or by a person who has granted a security to cover bonds issued by GPB (OJSC), where the amount of the claim is 10 or more per cent of the book value of their assets as of the end date of the reporting period (quarter, year) preceding the legal action, for which the prescribed reporting period has expired, or any other legal action which (if successful) may have a material effect on the financial and business position of GPB (OJSC) or such persons About a fixed record date on which the list of holders of GPB's registered securities or certificated issue-grade bearer securities (requiring mandatory centralized safekeeping to enable the exercise of rights attached to such issue-grade securities) is to be made About the following decisions made by the competent bodies of GPB (OJSC): offering of issue-grade securities of GPB (OJSC); approving a resolution authorizing an issue (an additional issue) of issue-grade securities of GPB (OJSC); approving a prospectus in relation to securities of GPB (OJSC); fixing the date for offering issue-grade securities of GPB (OJSC) About completion of the offering of issue-grade securities of GPB (OJSC) About the filing (submission) by GPB (OJSC) of an application seeking the state registration of an issue (additional issue) of issue-grade securities, offering prospectus or amendments in a resolution authorizing an issue (additional issue) of issue-grade securities and (or) offering prospectus relating thereto or state registration of a report on the results of an issue (additional issue) of issue-grade securities About the filing (submission) by GPB (OJSC) of a notice on the results of an issue (an additional issue) of issue-grade securities.

4 About a decision rendered by an arbitration court invalidating an issue (an additional issue) of issue-grade securities of GPB (OJSC); About a redemption of issue-grade securities of GPB (OJSC) About income accrued and (or) paid on issue-grade securities of GPB (OJSC) About the execution by GPB (OJSC) of a contract with a Russian trade organizer operating in the securities market to include issue-grade securities of GPB (OJSC) in the list of securities admitted to trading in the securities market and an agreement with a Russian securities exchange to include issue-grade securities of GPB (OJSC) in its quotation list About the execution by GPB (OJSC) of a contract to include issue-grade securities of GPB (OJSC) or securities of a foreign issuer confirming rights or titles to issue-grade securities of GPB (OJSC) in the list of securities admitted to trading in a foreign organized (regulated) financial market and an agreement with a foreign securities exchange to include such securities in its quotation list About the inclusion of issue-grade securities of GPB (OJSC) or securities of a foreign issuer confirming rights or titles to issue-grade securities of GPB (OJSC) in the list of securities admitted to trading in a foreign organized (regulated) financial market or their exclusion from it as well as inclusion of such securities in the quotation list of a foreign securities exchange or exclusion of them from such list About the execution by GPB (OJSC) of a contract to maintain (stabilize) prices for issuegrade securities of GPB (OJSC) (or securities of a foreign issuer confirming rights or titles to issuegrade securities of GPB (OJSC)), conditions of such contract or termination of such contract About the filing by GPB (OJSC) of an application for obtaining a permission from the federal executive authority responsible for the securities market for offering and (or) arranging the placement of its issue-grade securities outside the Russian Federation About a failure of GPB (OJSC) to meet its obligations towards holders of its issue-grade securities About the acquisition by a person of the right, or termination of a person's right to exercise, directly or indirectly (through persons controlled by him or her), individually or jointly with other persons being parties to a trust agreement and (or) simple partnership agreement and (or) commission agreement and (or) shareholders' agreement and (or) any other agreement whose subject matter is the exercise of rights attached to shares in GPB (OJSC), a particular number of votes attached to voting shares constituting the share capital of GPB (OJSC) if such number of votes is 5 per cent or has become more or less than 5, 10, 15, 20, 25, 30, 50, 75 or 95 per cent of the total number of votes attached to voting shares constituting the share capital of GPB (OJSC) About a voluntary offer, including a competing one, or binding offer to purchase issue-grade securities of GPB (OJSC) received by GPB (OJSC) pursuant to Chapter XI.1 of the Federal Law On Joint-Stock Companies or amendments made in such offers About a notice of an existing right to request a redemption of issue-grade securities of GPB (OJSC) or a request for such redemption received by GPB (OJSC) pursuant to Chapter XI.1 of the Federal Law On Joint-Stock Companies About any errors revealed in financial (accounting) reports disclosed by GPB (OJSC) earlier if such errors may have a material effect on the price of issue-grade securities of GPB (OJSC) About the execution by GPB (OJSC) or a person who has granted a security in relation to bonds issued by GPB (OJSC) of a transaction whose amount is 10 or more per cent of the book value of the assets of GPB (OJSC) or of such person as of the end date of the reporting period (quarter, year) preceding the execution of the transaction for which the prescribed reporting period has expired About the execution by an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) and being of significant importance for it of a transaction being a major transaction under the law of the Russian Federation About the execution by GPB (OJSC) of a related party transaction or a transaction that has to be approved by a competent body of GPB (OJSC) pursuant to the law of the Russian Federation if the amount of such transaction exceeds RUR 200 million or is 2 or more per cent of the book value of

5 5 the assets owned by GPB (OJSC) as of the end date of the reporting period (quarter, year) preceding the approval of such transaction by the competent body of GPB (OJSC) or, if such transaction has not been approved by the competent body of GPB (OJSC) before its execution, as of the end date of the reporting period (quarter, year) preceding the execution of the transaction for which the prescribed reporting period has expired About the composition and (or) amount of a pledge securing collaterized bonds issued by GPB (OJSC) or, in case of a change in the composition and (or) amount of a pledge securing mortgage-backed bonds issued by GPB (OJSC), information about such change if it results from a replacement of any mortgage-backed claim constituting a mortgage collateral in relation to the bonds or a replacement of a property constituting a mortgage collateral in relation to the bonds whose value (monetary value) is 10 or more per cent of the mortgage collateral securing the bonds About a change in the value of assets owned by a person who has granted a security for bonds issued by GPB (OJSC) that is 10 or more per cent or any other significant, in the opinion of GPB (OJSC), change in the financial and business position of such person About the acquisition by or termination of the right of GPB (OJSC) to exercise, directly or indirectly (through persons controlled by it), individually or jointly with other persons being parties to a trust agreement and (or) simple partnership agreement and (or) commission agreement and (or) shareholders' agreement and (or) any other agreement executed with GPB (OJSC) whose subject matter is the exercise of rights attached to shares (stock) in an entity whose issue-grade securities have been included in the list of securities admitted to trading by a trade organizer operating in the securities market or whose assets value exceeds RUR 5 billion, a particular number of votes attached to voting shares constituting the share capital of such entity if such number of votes is 5 per cent or has become more or less than 5, 10, 15, 20, 25, 30, 50, 75 or 95 per cent of the total number of votes attached to voting shares (stock) constituting the share capital of such entity About the acquisition by a person of the right, or termination of a person's right to exercise, directly or indirectly (through persons controlled by him or her), individually or jointly with other persons being parties to a trust agreement and (or) simple partnership agreement and (or) commission agreement and (or) shareholders' agreement and (or) any other agreement executed with such person whose subject matter is the exercise of rights attached to shares (stock) in an entity that has issued a surety in relation to bonds issued by GPB (OJSC), a particular number of votes attached to voting shares (stock) constituting the share capital of such entity if such number of votes is 5 per cent or has become more or less than 5, 10, 15, 20, 25, 30, 50, 75 or 95 per cent of the total number of votes attached to voting shares (stock) constituting the share capital of such entity About the execution by GPB (OJSC) or an entity controlling GPB (OJSC) or an entity controlled by GPB (OJSC) of contract imposing an obligation to acquire issue-grade securities of GPB (OJSC) About a receipt, suspension, restoration, re-issuance, revocation (cancellation) or termination due to other reasons of a permission (license) issued to GPB (OJSC) to enable it to carry out a particular activity being of significant financial and business importance for it About the expiration of the powers of the sole executive body and (or) members of the collegial executive body of GPB (OJSC) About any change in the share held in the share capital of GPB (OJSC) or entities controlled by GPB (OJSC) being of material importance for it by: persons being members of the Board of Directors or of the collegial executive body of GPB (OJSC) or the person holding the position or performing the functions of the sole executive body of GPB (OJSC); persons being members of the Board of Directors or of the collegial executive body of the management company or the person holding the position or performing the functions of the sole executive body of the management company if the powers of the sole executive body of GPB (OJSC) have been delegated to the management company.

6 About conferring on holders of bonds issued by GPB (OJSC), and (or) terminating, the right to require that the bonds issued by GPB (OJSC) be early redeemed by the issuer About contracting or replacing companies that provide intermediary services to GPB (OJSC) to ensure that it complies with its obligations under bonds or other issue-grade securities of GPB (OJSC) with the specification of their names, locations and fees payable for the services provided or of any changes in such information About a dispute connected with the creation, management of or a shareholding in GPB (OJSC) if the settlement of such dispute may have a significant impact on the price of its issue-grade securities About the making of claims against a person who has granted a security for bonds issued by GPB (OJSC) to ensure the performance of obligations under such bonds About the offering, outside the Russian Federation, of bonds or other financial instruments evidencing loan obligations being performed at the cost of GPB (OJSC) About the acquisition (or alienation) of voting shares in GPB (OJSC) or securities of a foreign issuer evidencing rights to voting shares in GPB (OJSC) by GPB (OJSC) or entities controlled by GPB (OJSC) other than controlled entities that are brokers and (or) trustees and enter into the transaction on their own behalf but for the expense of a customer that is not GPB (OJSC) and (or) an entity controlled by GPB (OJSC) Forwarded or submitted by GPB (OJSC) to a competent authority (relevant entity) in a foreign jurisdiction, foreign exchange and (or) other companies pursuant to foreign laws for the purposes of disclosing the same to foreign investors in connection with the offering or circulation of issue-grade securities of GPB (OJSC) outside the Russian Federation, including by purchasing securities issued by a foreign issuers being offered (or placed) pursuant to foreign laws Constituting annual or interim (quarterly) accounting (financial) statements of GPB (OJSC), including its annual or interim summary accounting (consolidated financial) statements Comprising the conditions of offering securities as determined in the relevant resolution approved by a competent body of GPB (OJSC) and authorizing an issue (additional issue) of securities if: the securities are to be offered during the trading process conducted by a trade organizer operating in the securities market; the securities of an additional issue are to be offered, where the securities of the issue (in relation to which the securities to be offered represent an additional issue) have been admitted to trading at the trade organizer operating in the securities market or in respect of which an application seeking their admission to trading at the trade organizer in the securities market has been filed Contained in a report (notice) about the results of an issue of issue-grade securities approved by a competent body of GPB (OJSC) if: the securities are to be offered during the trading process conducted by a trade organizer operating in the securities market; the securities of an additional issue are to be offered, where the securities of the issue (in relation to which the securities to be offered represent an additional issue) have been admitted to trading at the trade organizer operating in the securities market or in respect of which an application seeking their admission to trading at the trade organizer in the securities market has been filed Contained in an issue prospectus approved by a competent body of GPB (OJSC) except for information that has been disclosed or submitted at a prior time as required by the securities laws of the Russian Federation Contained in quarterly reports signed by authorized persons of GPB (OJSC) except for information that has been disclosed or submitted at a prior time as required by the securities laws of the Russian Federation Contained in annual reports signed by authorized persons of GPB (OJSC) except for information that has been disclosed or submitted at a prior time as required by the securities laws of the Russian Federation.

7 7 3. List of information constituting insider information of GPB (OJSC) as professional player of the securities market, exchange intermediary and credit organization performing transactions in foreign currencies on the currency exchange in the interests of customers who have received insider information from their customers 3.1. The insider information of GPB (OJSC) as a professional player of the securities market that carries out transactions in financial instruments in the interests of its customers shall include the following information received from the customers: Information contained in customers' orders to enter into securities transactions that must be fulfilled if the fulfillment of such orders may have a material impact on the prices of the concerned securities Information contained in customers orders seeking the entry into contracts that have to be fulfilled, where such contracts are: financial derivatives if the fulfillment of such orders may have a material impact on the prices of the concerned securities; financial derivatives underlain by an exchange commodity if the fulfillment of such orders may have a material impact on the prices of the concerned exchange commodity; Information constituting the material terms of a trust management agreement associated with the execution of securities transactions and (or) execution of contracts being financial derivatives where the performance of trust management functions may have a material impact on the prices of the concerned securities The insider information of GPB (OJSC) as that of an exchange intermediary shall include: Information contained in customers' orders to enter into transactions involving exchange commodities that must be fulfilled if the fulfillment of such orders may have a material impact on the prices of the concerned exchange commodities; Information contained in customers' orders seeking the execution of contracts being financial derivatives underlain by an exchange commodity if the fulfillment of such orders may have a material impact on the prices of the concerned exchange commodity The insider information of GPB (OJSC) as a credit organization that carries out transactions in foreign currencies in the interests of its customers on a currency exchange shall include the following information received from the customers: Information contained in customers' orders seeking the purchase (buy) or sale of a foreign currency on a currency exchange that must be fulfilled if the fulfillment of such orders may have a material impact on the price of the concerned foreign currency Information contained in customers' orders seeking the execution of contracts being financial derivatives underlain by a foreign currency if the fulfillment of such orders may have a material impact on the prices of the foreign currency.