Statement from the ONEXIM Group on the results of a limited audit of transactions with JCS OPIN shares in 2012 conducted by the Bank of Russia
Over the period from February 14, 2012 to February 28, 2012 Onexim Holdings Limited acquired 33.63% of JSC OPIN shares on the secondary market. All the transactions were concluded and executed at prices formed as a result of trading the issuer's shares on MICEX.
On March 2, 2012, Onexim Holdings Limited notified JSC OPIN and Federal Financial Markets Service (FFMS) about increasing the voting shares of JSC OPIN from 30.12% to 63.75% and sent FFMS an advance notice of intention to make a mandatory offer for the acquisition of JSC OPIN securities. After 15 days, the company sent the mandatory offer to JSC OPIN.
Almost two years later, on January 9, 2014, the Bank of Russia sent LLC Onexim Group an order to provide documents and information due to a limited audit conducted in accordance with the Law 'On countering the misuse of insider information and market manipulation'. LLC Onexim Group provided the requested information within the period established in the order. Onexim Holdings Limited did not receive any requests for information from the Bank of Russia.
On May 27, 2014, the Bank of Russia sent Onexim Holdings Limited an order to eliminate breaches of the Law and ordered to avoid violations in future activities, as well as to implement a set of organizational and administrative actions aimed at excluding breaches of this Law.
In May 2014, Onexim Holdings Limited provided the Bank of Russia with its legal arguments to the effect that its actions did not breach the current legislation. Nevertheless, despite its disagreement with the assessment formulated by the results of the limited audit, ONEXIM Group, pursuant to the order of the Bank of Russia, developed and implemented more stringent internal control procedures for conducting transactions. The implementation of these procedures is aimed at excluding divergence in the interpretation of the relevant legislation with state regulatory agencies when such transactions are conducted in the future.
On June 6, 2014, the ONEXIM Group sent the Bank of Russia a relevant report. As yet, the ONEXIM Group has not received any comments or objections from the Bank of Russia regarding the submitted report and considers the incident closed.