Moscow Exchange is committed to ensuring that its activities are as transparent as possible for its shareholders and other stakeholders.

Following the recommendations of the Corporate Governance Code of the Bank of Russia and Moscow Exchange’s development plans, and taking into account the requirements of the legislation on information disclosure by issuers whose securities are admitted to trading, Moscow Exchange adopted a new Information Policy in December 2015 (http://fs.moex.com/files/11122/).

The Information Policy is a set of information-disclosure rules followed by Moscow Exchange (including members of its management bodies, officials and employees) when providing information to shareholders and stakeholders. In particular, the Information Policy determines:

• key information-disclosure objectives and binding principles for Moscow Exchange as a securities issuer;
• groups of disclosed information, including a list of information that Moscow Exchange may disclose voluntarily, and the disclosure procedure;
• the procedure for Moscow Exchange's interaction with stakeholders, including with individuals who are authorised to communicate on behalf of Moscow Exchange; and
• the procedure for granting access to information and documents belonging to Moscow Exchange.

In 2016, the Information Policy was amended to clarify the Exchange’s approaches to determining the information that can materially affect the value of shares in Moscow Exchange, as well as to establish procedures that ensure timely disclosure of such information.

The Information Policy is aimed at providing stakeholders with additional opportunities to exercise their rights and to improve the efficiency of information exchange between Moscow Exchange and all stakeholders.

Methodology Used by Moscow Exchange to Assess the Principles of Corporate Governance Set Out in the Bank of Russia Corporate Governance Code

The recommendations set out in Letter No. IN-06-52/8 issued by the Bank of Russia on 17 February 2016 on Disclosure, in a Public Joint-Stock Company Annual Report, of a Report on Compliance with the Principles and Recommendations of the Corporate Governance Code were used by Moscow Exchange as the methodology for its assessment of the principles of corporate governance set out in the Bank of Russia Corporate Governance Code.

As part of this assessment, an analysis was undertaken to determine whether the contents of the Charter and internal documents, as well as of Moscow Exchange’s corporate governance practices and internal procedures, were aligned with the principles and recommendations of the Bank of Russia Corporate Governance Code. An analysis of the 2015 results-based assessment showed that Moscow Exchange complied with the majority of the principles and recommendations of the Corporate Governance Code in the first fiscal year after the adoption by the Bank of Russia of the Corporate Governance Code (2015).

The Exchange was ranked among the top 5 companies with good corporate governance disclosure according to the Bank of Russia.

The results of the reviews of compliance with the requirements of the Listing Rules and the Bank of Russia Corporate Governance Code undertaken by Moscow Exchange’s Internal Audit Service and Legal Department in 2016 were used for assessment purposes. Another thing taken into account in the course of the assessment was the implementation of activities aimed at the improvement of corporate governance practices in respect of unmet or partly met recommendations from the Bank of Russia Corporate Governance Code indicated in the 2015 annual report. It should be noted that an analysis of the quality of disclosure of information on compliance with the principles of corporate governance undertaken by the Bank of Russia in 2016 placed Moscow Exchange among the five companies, characterised, in the Bank’s opinion, by the high quality of corporate governance level disclosure.

In 2016, the Supervisory Board’s Audit Committee developed recommendations regarding methods of implementing those principles of the Bank of Russia Corporate Governance Code that were named in the 2015 annual report as unmet or partly met. Some of those recommendations were taken into account by Moscow Exchange in the 2016 reporting year, in particular through the approval of new or revision of existing internal documents. As a result, there were more principles and recommendations that were complied with in 2016.

Some of the recommendations scheduled to be implemented in 2017 and beyond are listed in the Report on Compliance with the Principles and Recommendations of the Corporate Governance Code (hereinafter, “the Report”, for the purposes of this section), which is part of this annual report.