REPORT ON THE ADHERENCE TO THE MOSCOW EXCHANGE CORPORATE GOVERNANCE CODE (HEREINAFTER, THE “MOEX CGC”) AND THE RESULTS OF THE IMPLEMENTATION OF GOVERNANCE PRINCIPLES PRESENTED IN MOEX CGC In accordance with Bank of Russia Ordinance No. 5062-U of 17/01/2019.

Moscow Exchange (hereinafter also referred to as “MOEX”) fully complies with its own Corporate Governance Code whose new version was approved by the Resolution of the Supervisory Board of 14/10/2019.

Information on the results of the implementation of corporate governance principles is set out in Chapter I, Section 4, Clause 4.2, of MOEX CGC:

No.	Principle	Implementation Results
1	Support of MOEX governance system that corresponds to its strategic goals, corporate values, operational specifics and clients’ needs and interests	A special feature of MOEX is that, on the one hand, it is a public company with shares traded on the regulated market and, on the other hand, it sets corporate governance standards for Russian public companies (including itself) as a part of the listing procedure. In this regard, active participation of MOEX and MOEX Group (hereinafter, the Group) in improving the level of corporate governance of Russian companies is one of its strategic initiatives, set out in its strategy. Compliance with the principles and best practices of corporate governance, as well as Group’s strategy, is a key condition for MOEX successful development. MOEX aims to set the example for other public companies in implementing high standards of corporate governance. MOEX’s corporate governance system includes the system of governing bodies, supervisory bodies and other MOEX bodies and the system of the relationship between control bodies, supervisory bodies, other MOEX bodies and its shareholders, as well as their engagement with stakeholders. The system of MOEX bodies engagement with MOEX shareholders and stakeholders is based on the following principles: safety and effective use of shareholders’ funds; mitigation of risks that investors are not able to assess; corporate accountability; respecting the interests of MOEX customers; disclosure of the information in order to ensure transparency of MOEX activities to stakeholders.
2	Support to MOEX Supervisory Board’s activities based on the following:
	Strategic governance	In accordance with MOEX Charter, the Supervisory Board performs strategic governance of MOEX through the following: identification of the priorities and main focuses of the activity; participation in the development and approval of the strategy, supervision of its implementation, as well as determination of the development strategy and evaluation of the results of controlled companies’ activity; approval of the budget (business plan), amendments to the budget (business plan), as well as approval and evaluation of its implementation. MOEX strategic goals are defined under the MOEX Group Strategy 2028. Strategic goals of MOEX are subject to continuous monitoring based on the MOEX Group Strategy 2028. Thus, the Supervisory Board approved by its Resolution dated 27/09/2023 the MOEX Group Strategy 2028 (pre-considered at the meeting of the Strategy Planning Committee of the Supervisory Board). The Strategy defines MOEX strategic goals until 2028. In 2023 the Supervisory Board reviewed and (or) approved the following strategies of MOEX and the MOEX Group: MOEX Group Strategy 2028 (resolution dated 27/9/2023); NSD Strategy 2028. (resolution dated the 04/12/2023). In 2024, the Supervisory Board approved (set) criteria to monitor the implementation of MOEX Group Strategy 2028 (resolution dated the 27/9/2023).
	MOEX Supervisory Board’s supervision of activities of MOEX executive bodies, as well as of decision-making aimed at the elimination of faults in the activity of MOEX executive bodies, in the case of their detection as a result of such supervision	The Supervisory Board controls activities of executive bodies by means of the following: election of sole (temporary sole) and collegiate executive bodies, early termination of their powers and approval of terms of employment contracts with them, including the establishment of the amount of their remuneration; approval of positions overlapping for members of executive bodies in governing bodies of other organisations; approval of the policy on remuneration payable to members of executive bodies and control of its implementation; control of strategy implementation; consideration of annual reports and, if necessary, interim reports of the Chairman of the Executive Board and members of the Executive Board on their performance, as well as quarterly reports of the Executive Board on the results (including financial highlights) of MOEX activity and decision-making on the results of their consideration, including decisions on bonus payment; approval and assessment of corporate and individual key performance indicators (targets) achievement by the Chairman of the Executive Board and members of the Executive Board for the reporting year. In 2023 the Supervisory Board reviewed and took under advisement the following documents: report of the MOEX Executive Board on performance results, financials and implementation of the MOEX Group Strategy in 2022 (resolution dated 07/3/2023); report of the MOEX Executive Board on performance results, financials and implementation of the MOEX Group Strategy in Q1 2023 (resolution dated 08/6/2023); report of the MOEX Executive Board on performance results and financials of the MOEX Group for 7 months of 2023 (resolution dated 11/9/2023); report of the MOEX Executive Board on performance results and financials of the MOEX Group for 10 months of 2023 (resolution dated 07/12/2023); 10-month report on the status of implementation of MOEX key projects for 2023 (resolution dated 07/12/2023). On 07/12/2023, the Supervisory Board of Moscow Exchange decided to acknowledge the interim assessment of the performance of the Group’s net profit plan and that the conditions for payment of a part of the annual bonus to employees for 2023 were met, and to pay the annual bonus in December 2023 to the Members of the Executive Board in accordance with the terms of their employment contracts based on their performance in 2023. On 10/3/2023 the Supervisory Board: considered the achievement of general corporate key performance indicators (targets) of Moscow Exchange for the reporting year 2022; considered the annual reports of executive bodies’ members regarding their performance for 2022 and setting the size of their annual bonus; set the amounts of annual bonuses for members of executive bodies of Moscow Exchange depending on their performance in 2022; decided to pay our bonus for 2022 according to terms and conditions of employment contracts. The Supervisory Board approved/set that the general corporate KPIs for 2023 as approved by the Supervisory Board of Moscow Exchange on 15/12/2022 (Minutes No. 12) shall be individual KPIs for members of the Executive Board (resolution dated 28/04/2023).
	Assessment of working efficiency of the MOEX Supervisory Board, as well as assessment of the quality of committees work under the MOEX Supervisory Board and disclosure of the results of such assessments	The MOEX Supervisory Board assesses its own performance and performance of its members, as well as performance of committees under the Supervisory Board. Working efficiency of the Supervisory Board and committees of the Supervisory Board is assessed on the basis of the MOEX Methodology of Corporate Governance Assessment approved by the MOEX Supervisory Board on 21/10/2016. Performance assessment is carried out in the form of internal assessment (self-assessment and competence assessment) – once a year, and independent evaluation (with the involvement of an independent expert) – once in 3 years. In spring 2022, an external independent consultant, LEADERSHIP VECTOR company, assessed the Supervisory Board’s performance. The findings of the external assessment (Report of the independent consultant On the Results of the External Assessment) were considered at the in-person meeting of the MOEX Supervisory Board on 08/06/2022. A substantial part of the recommendations mentioned in the Report was implemented, while some recommendations are in the process of implementation. In 2023, an internal assessment of Supervisory Board members was conducted. Following the assessment, the Director of the Corporate Governance Department carried out an analysis and prepared a report along with an action plan to improve current corporate governance processes. The self-assessment of the Supervisory Board’s committees is planned for the early 2024, as the years 2022-2023 mark active changes in the membership of the Supervisory Board and its committees. Information on findings of performance assessment of the Supervisory Board and committees at the Supervisory Board is included in the annual report and is disclosed on the official website of MOEX.
	Separation of supervision functions and governance responsibilities and of individual and collective responsibility of members of the MOEX Supervisory Board.	MOEX Supervisory Board’s governance and control functions are segregated according to the Charter. The Supervisory Board controls, among other things, the following: corporate governance practices, including those related to material corporate actionsThe list of material corporate actions is specified in Chapter II, Section 8, Clause 8.1. of MOEX CGC.; financial-economic and business activity; executive bodies’ activities. In regard to governance functions, the Supervisory Board provides, among other things, overall management of MOEX, namely, it determines the main guidelines, development strategy and priorities, approves the consolidated business plan (budget) of the MOEX Group and defines principles and approaches to the organisation of risk management, internal control and internal audit systems. Members of the Supervisory Board in the exercise of their rights and duties act in the interests of MOEX in good faith and reasonably. They are obliged to reimburse MOEX and shareholders acting in the interests of MOEX, for losses caused to the Company through their fault, if it is proved that the member of the Supervisory Board acted in bad faith or unreasonably in exercising his/her rights and duties, including if his/her actions (omissions) were not consistent with the ordinary terms of civil-law transactions or normal business risk.
3	Ensuring the functioning of internal control, internal audit, MOEX risk management system	MOEX has in place the risk management and internal control system that complies, among others, with the requirements of the Russian legislation applicable to MOEX as a market operator, as well as with international recommendations for building risk management and internal control systems. The risk-oriented approach is applied to the internal control system. Internal control is ensured by MOEX governing bodies (General Meeting of Shareholders, Supervisory Board, Executive Board and the Chairman of the Executive Board), Audit Committee of the Supervisory Board, external auditor, Internal Audit Service, Internal Control Service, Internal Control and Compliance Department, risk and business continuity management subdivisions, security subdivisions and other subdivisions and employees of MOEX (including the Chief Accountant and his or her deputies), that ensure control within the scope of their authorities, as outlined in MOEX internal documents. The internal control follows the three lines of defence principle, which is in line with the best international practices. The first line of defence means all representatives of MOEX business functions and employees of operation subdivisions involved in the detection, assessment, and management of risks inherent in daily activity, as well as in development and implementation of policies and procedures that govern existing business processes. The second line of defence comprises the Department for Operational Risk, Information Security and Business Continuity, Internal Control and Compliance Department, Internal Control Service, Security Department, Legal Department and certain employees and subdivisions of the Finance Unit. The second line of defence employees and business units perform continuous risk monitoring and management, and they also control MOEX compliance with the federal laws and regulations adopted in accordance therewith and compliance with trading rules and MOEX constituent and internal documents as part of the following areas: ensuring information security, inclusive of protection of interests (goals) of MOEX in the information domain; ensuring compliance with the legislation of the Russian Federation, MOEX constituent and internal documents; ensuring non-involvement of MOEX and its employees in illegal or unfair activities, including legalisation (laundering) of criminal proceeds and financing of terrorism; eliminating illegal use of insider information and (or) market manipulation; eliminating conflicts of interest, including identification, control and prevention of any consequences thereof. The second line of defence supports the first line of defence on the matters regarding identification of regulatory risks, development and implementation of control procedures, clarification of applicable law requirements and preparation of monitoring reports for governing bodies. The third line of defence is the Internal Audit Service that independently assesses the efficiency of processes developed by the first and second lines of defence and delivers independent and objective information to governing bodies on efficiency and effectiveness of financial and economic activity, efficiency of assets and liabilities management, including assets safety, and efficiency of management of trade organiser risks. The governing bodies of MOEX define internal control and risk management principles and approaches. MOEX has in place a risk management system that is appropriate to the nature and scope of its transactions and includes risk mitigation measures; risk monitoring system that ensures submission of necessary information to MOEX governing bodies; and the process to manage major risk types that may adversely affect its activities as a market operator, DFA exchange operator and financial platform operator. Risk management functions are distributed between the Supervisory Board and its committees, executive bodies, heads of subdivisions responsible for particular directions of MOEX activities where risks may arise, special subdivision responsible for risks arising in the activities of the trade organiser, Internal Control Service, as well as consultative and advisory bodies of MOEX. In 2023, risk management priorities for MOEX were ensuring trusted and reliable systems in the current macro situation, implementing the new Development Strategy of MOEX Group until 2028 and updated risk management roadmap of MOEX Group for 2023-2024 (hereinafter, “RMS Strategy 2024”) (Executive Board resolution dated 17/11/2023). The Risk Management Strategy 2024 outlined the following risk management development areas: supporting the key business development areas identified in the RMS Strategy 2028; improving risk and capital management tools and processes at the Group level; maintaining the infrastructural role of the Group; risk-culture development across the Group; outsourcing risk management. Among other priorities for the RMS Strategy in 2023 were import substitution and regulatory compliance in terms of operational reliability. The Risk Management Strategy 2024 also identified the system’s success criteria, risks related to the RMS Strategy 2024 implementation and measures aimed at preventing such risks. Information on the risk management system is brought to shareholders, trading and clearing members, the Bank of Russia and other stakeholders on a regular basis either in the form of reports or on the website. In 2023, for the first time, ISO 37301:2021 Compliance Management System certification at the Group level was achieved. Auditors of Bureau Veritas Certification Rus assessed the efficiency of compliance management according to the standard, and also highlighted the uniform compliance methodologies and processes across the Group. The Exchange completed an independent audit to confirm compliance of the corporate control system with the international standard ISO 37301:2021 in the following areas: internal control of licensed activities; fight against the legalisation of illegal earnings (money laundering), the financing of terrorism and proliferation of weapons of mass destruction (AML/CFT/CFPWMD); fight against illegal use of insider information and market manipulation; foreign tax control (FATCA/CRS); fight against corruption; conflict of interest management; economic restrictions. MOEX ensures independent internal audit function (Internal Audit Service) by segregating its functional and administrative accountability. Under functional accountability, the Supervisory Board: approved the Plan of the Moscow Exchange Internal Audit Service for 2023 as amended with new audits for Q4 2023 (resolution dated the 27/09/2023); approved the Concept of (approaches to) group-wide audit for MOEX Group, the Concept’s roadmap and Regulation on interaction between internal audit functions when implementing group-wide internal audits (resolution dated 15/12/2023); approved the Moscow Exchange Internal Audit Plan for 2024 (resolution of 15/12/2023); reviewed the report on the Moscow Exchange Internal Audit on self-assessment of their performance for 2022 (resolution of 07/3/2023). reviewed the report on the Moscow Exchange Internal Audit Service on their performance (the audits performed) for H2 2022 (resolution dated 07/3/2023); reviewed the report on the Moscow Exchange Internal Audit performance (the audits performed) for H1 2023 (Appendix 1) (resolution dated 27/9/2023); approved the performance indicators (targets) for 2023 for the Head of Moscow Exchange Internal Audit (resolution dated 26/01/2023; approved ceilings for the remuneration payable to Internal Audit employees (except the Head of Internal Audit) (resolution dated the 28/04/2023, 27/9/2023); approved the size of the annual bonus and pay the bonus to the Head of internal Audit and employees of Internal Audit for 2022 (resolution of 10/3/2023); approved amendments to the terms and conditions of the employment contract with the Head of the Internal Audit (resolution dated 27/9/2023); approved the size and structure of the Moscow Exchange Internal Audit Service (resolution dated 15/12/2023); approved ceilings for remuneration payable to Internal Audit employees (except the Head of Internal Audit) (resolution dated 15/12/2023); resolved to pay out annual bonus for 2023 to the Head and employees of Moscow Exchange Internal Audit (resolution dated 15/12/2023); approved key performance indicators (targets) for 2024 for the Head of Moscow Exchange Internal Audit (resolution dated 15/12/2023. Within administrative accountability, the Chairman of the Executive Board: allocated the necessary funds within the approved budget of the Internal Audit Service; provided support in dealing with the divisions of the Exchange. Internal audits at the Exchange, including relations between the Internal Audit Service and other divisions and the external auditor of Moscow Exchange, are organised and performed in accordance with the Internal Audit Regulations. Internal audit employees operate within the framework of applicable laws and professional standards.
4	Ensuring prevention, identification, and settlement of conflicts of interest related to Exchange’s activity as well as the fight against corruption	Measures taken by the Exchange as a market operator, financial platform operator and DFA exchange operator to prevent conflicts of interest are regulated by Exchange’s internal documents, including the Provision on Identifying and Preventing Conflicts of Interest in the Exercise of Trade Organiser, Financial Platform Operator Activities and Activities of Digital Financial Assets Exchange Operator by Moscow Exchange, which was approved in 2023 as amended. Such measures aim to prevent situations in which personal interest of Exchange employees may affect their fair and efficient discharge of duties. In terms of managing corruption risks, the Exchange follows key principles set out in the Anti-corruption Policy approved in 2020. Namely, a zero tolerance approach to corruption; employee engagement; development and implementation of measures to minimise the likelihood of involvement of Exchange and its employees in corruption practices; investigations into good-faith reports of violations of procedures for preventing and combating corruption and holding the guilty persons liable regardless of their position, length of service or other conditions, if they commit corruption offences as part of their duties; mandatory screening of counterparties; and monitoring of the efficiency of the anti-corruption standards and procedures that are in effect. The Exchange prevents and detects corruption and manages anti-corruption efforts through the instruments described in the Policy. namely: anti-corruption efforts: existence of a body that controls procurement procedures to decide on contract awards; counterparty due diligence, including checking for conflicts of interest and relations with public officials and Exchange employees; and inclusion of anti-corruption provisions (clauses) in contracts; establishment of criteria for identifying gifts and procedure of gift-taking and gift-giving by employees; possibility of reporting corruption risks (also anonymously) by employees through the Speak Up! whistleblowing line; management of conflicts of interest; monitoring and assessment of corruption risks; setting procedures to identify violations; setting procedures for in-house investigations; defining measures to respond to confirmed cases of corruption. Measures aimed at the management of a conflict of interests, arising in cases of conflict between Exchange’s interests and personal interests of the members of control bodies due to their business, friendly, family and other ties and relations, as well as in cases of conflict between their responsibilities in relation to the Exchange and to other persons, are defined in The Policy on the Management of a conflict of interests and corporate conflict in Moscow Exchange approved by the Supervisory Board. The Policy outlines obligations of the governing body members related to the implementation of measures to manage conflicts of interest. It outlines approaches and methods to prevent and detect conflicts of interest, including identification of transactions involving a conflict of interest (including transactions with securities of Exchange, interested-party transactions and transactions made outside the ordinary course of business that carry a potential conflict of interest).
5	Ensuring equal and fair attitude towards all shareholders (participants) in exercising their right to participate in MOEX governance, as well as the balance between the rights and interests of customers, MOEX contractors and other stakeholders	MOEX ensures equal and fair attitude towards all shareholders in exercising their right to participate in the governance of the Company. One special feature of MOEX’s shareholding structure is the absence of a controlling shareholder. Each shareholder is entitled to take part in the General Meeting of Shareholders held in a form of joint presence, exercising the right to vote in a convenient manner: by sending voting bulletin by mail, personally participating or using an electronic form of voting. In the reporting period, the General Meeting of Shareholders was held in the form of absentee voting (without joint presence of shareholders to discuss agenda items and take decisions on issues put to a vote) in accordance with the applicable law. Each shareholder was allowed to take part in the General Meeting of Shareholders held in the form of absentee voting, exercising their right to vote in a convenient manner: by sending voting bulletin by mail, using an electronic form of voting or giving voting directions (instructions) to record keepers of rights to MOEX’s shares in accordance with the Russian law on securities. MOEX shareholders are allowed to vote electronically by filling in an electronic voting ballot on the website. To ensure equal attitude towards all shareholders, MOEX provides information on holding the meetings, including materials for the meeting, both in Russian and in English. Voting ballots are also available in English, which, in accordance with OECD recommendations, eliminates voting obstacles for foreign shareholders. At General Meetings held in the form of joint presence shareholders are given the opportunity to communicate with MOEX management and receive feedback on the issues of interest to them, whereas members of the executive bodies and the Supervisory Board, the Chief Accountant, representatives of the auditor, and candidates nominated for the election to the Supervisory Board are always invited to attend the Annual General Meeting. Given that many of the MOEX’s shareholders are also its customers, MOEX ensures equal treatment of customers in offering its services, thereby avoiding any unfair advantage. MOEX follows the principle of respecting the best interests of MOEX and MOEX Group service users through creating user committees by type of activities carried out by financial market participants, type of contracts executed in organised trading and type of securities placed by issuers. Along with user committees, which simultaneously serve as market section councils according to law on organised trading, MOEX has voluntarily established individual committees to ensure a regular dialogue with its customers and their participation in shaping business initiatives. The user committees review most of the business innovations that MOEX implements, as well as tariff policy and technological solutions. Moreover, MOEX strives to build long-term and sustainable mutually beneficial relations with its contractors. MOEX has in place a competitive procedure for selecting contractors that makes the contracting process transparent and allows to select the best contractors for the company.
6	Ensuring transparency and effective communications with shareholders (participants) and other stakeholders	MOEX sees timely and full disclosure of information as an important tool for building long-term confidence-based relations with shareholders, which contributes to MOEX’s value and its ability to raise capital and to maintain confidence of shareholders, investors and other stakeholders. MOEX seeks to ensure that its shareholders and other stakeholders have access to information on all material facts of MOEX’s operations to enable them to make informed investment and management decisions. The main approaches and principles of information disclosure are established by the Information Policy of MOEX. The new version of the document was approved by the Supervisory Board in 2023. According to the Information Policy, information disclosed by MOEX is divided into three groups: information subject to mandatory disclosure; voluntary disclosed information; information submitted upon stakeholders request. For user convenience, on the official website of the Exchangeon the Internet Information Disclosure and Compliance sections are available. The Information Disclosure section comprises the following subsections: Issuer’s Disclosure, Trade Organiser’s disclosure, Financial Platform Operator’s disclosure, Other disclosure. Information is also disclosed by publishing in the news feed. The Compliance section comprises the following subsections: MOEX Compliance, Codes of Good Practice and Compliance Hotline. In 2023, amidst continued international pressure on Russian companies, MOEX decided to limit disclosures of the personal data of its governing body members, some financial information and client data. However, the ESG report disclosed general information about management bodies of MOEX. MOEX intends to resume its disclosure practices after further research into the risks associated with such disclosures. For foreign shareholders and investors, a special section https://www.moex.com/en/, is available on the English page of the MOEX website. It contains news for investors, key information on MOEX shares, dividend policy and payments, financial and operating results of MOEX activities, compliance, corporate governance, past and upcoming events for investors and shareholders, as well as contact information. The Head of Investor Relations is responsible for shareholder and investor communications. Contact details are available on the website of MOEX. MOEX management regularly communicates with investors and shareholders and their representatives through news feeds, press releases, annual reports, presentations and other investor materials, meetings and special events for analysts and investors, investor conferences, as well as quarterly conference calls and webcasts for analysts and investors, featuring financial highlights for the reporting period and management commentary. The listed special events were mostly digital in 2022, respecting the Bank of Russia’s restrictions and recommendations. MOEX management also actively engages with the media. These measures help both investors and shareholders stay posted to be able to take informed investment decisions. The Corporate Governance Department with the Head of Investor Relations ensure engagement with existing shareholders of MOEX and, where necessary, with shareholders/participants of MOEX Group companies, also in preparing for General Meetings.
7	Striving for further progress with a view to sustainable development of MOEX and increased return on investments in the equity capital	Seeking to ensure sustainable development and increase the return on investments in the equity capital in the long term, MOEX governing bodies acknowledge the need for continuous improvement of MOEX corporate governance system, taking into account its level of development and the impact of external factors, as well as the need for ongoing control over the observance of the rights and interests of shareholders and other stakeholders. On 25/4/2023, the Executive Board of Moscow Exchange approved the report on ESG roadmap 2022 implementation and approved ESG roadmap for 2023 with 59 ESG metrics covering the following five topics: Genuine corporate governance and business ethics. Respect for human rights, equal opportunities and staff engagement. Environmentally friendly and trusted market infrastructure. Advanced practices of responsible investing. Trusted relations with local communities.