Trade Secret

Procedure for granting access to information constituting the Company’s trade secret to members of collegiate management bodies and shareholders, as well as the procedure for disclosing such information to said persons

1.1. In accordance with Articles 89 and 91 of Federal Law No. 208-FZ of December 26, 1995, "On Joint-Stock Companies," and taking into account Directive No. 3388-U of the Central Bank of the Russian Federation dated September 22, 2014, as well as the Company’s Charter and the Regulation on the Board of Directors of JSC "BSK" (approved by the General Meeting of Shareholders on January 22, 2014; Minutes No. 51), the Company shall provide shareholders and members of the collective management body (the Board of Directors) with access to the Company’s documents, including those classified as the Company’s trade secrets.

1.2. Company documents containing information that constitutes a trade secret shall be provided to an authorized person only upon receipt of a written statement (receipt) from said person. This statement must confirm that the individual has been informed of the confidential nature of the information being provided and of their obligation to maintain such confidentiality. Furthermore, the statement must include an acknowledgment by the authorized person—who has signed the request for information—that they are aware that the requested information constitutes a trade secret of JSC "BSK." By signing, the individual undertakes to: comply with the trade secret protection regime established within the Company; refrain from disclosing such information without the prior written consent of JSC "BSK"; refrain from using such information for personal purposes; and indemnify JSC "BSK" for any losses incurred should the information be disclosed. If such a written statement (undertaking) was not attached to the request for the provision of documents submitted by an authorized person (hereinafter referred to as the "Request"), the Company shall, within seven business days from the date the Request is submitted, send a follow-up inquiry to the authorized person who signed the Request to obtain said statement, noting that the requested Company documents contain information that constitutes a trade secret. In such a case, the time period specified in Clause 1.7 of this Procedure shall commence from the moment the Company receives the aforementioned statement (the date of receipt shall be determined in accordance with Clause 1.6 of this Procedure).

If the Request specifies that the documents are to be provided in the form of an on-site review (inspection) of the Company’s documents, the required statement may be provided to the Company by the authorized person on the day of such review.

1.3. The responsibility for receiving such statements and maintaining a register of the statements received is assigned to the Corporate and Property Relations Department.

1.4. Company documents that constitute the Company’s trade secrets shall be provided upon submission of a formal Request, prepared in simple written form. The Request must contain:

1.4.1. The full name (surname, first name, and patronymic, if applicable) of an individual, or the full corporate name and Primary State Registration Number (OGRN) — or an equivalent identification number if the Request is submitted by a foreign legal entity — of a shareholder that is a legal entity, or other information identifying any other authorized persons. If the Request is signed by a representative of an authorized person acting under a power of attorney, the Request must be accompanied by the power of attorney (executed in accordance with the requirements of the legislation of the Russian Federation) or a duly certified copy thereof.

1.4.2. The postal address, email address, and contact telephone number for communicating with the authorized person on whose behalf the Request is submitted.

1.4.3. A list of the Company’s documents to be provided, specified by type and period of creation.

1.4.4. The format for the provision of the Company’s documents and the method of receipt: in person at the premises of the Company’s executive body, via postal service, or via email. Furthermore, if the chosen format for the provision of the Company’s documents is the receipt of copies, the specific method of receipt shall be: in person at the Company’s registered office, via postal service, or via email.

1.4.5. If a Request does not contain the mandatory information or if the documents stipulated in Clause 1.4.1 are missing, the Company shall, within seven business days from the date the Request is submitted, send a letter to the authorized person specifying the missing information or documents required. In such a case, the period for providing the documents shall commence from the date the complete information or all required documents are received (the date of receipt shall be determined in accordance with the procedure set forth in Clause 1.5).

1.5. A Request may be submitted to the Company via the following methods:

1.5.1. By postal service or courier service to the Company’s registered office: 32 Tekhnicheskaya St., Sterlitamak, 453110.

1.5.2. By email, using an electronic digital signature, sent to the Company’s email addresses (e-mail: Info.bsc@ruschem.ru, info@kaus.ru, sodastr@soda.ru).

1.5.3. By hand-delivery, against a signature, to the Company’s documentation department at the Company’s registered office: 32 Tekhnicheskaya St., Sterlitamak, 453110.

1.6. The date of submission of a Request shall be:

1.6.1. If the Demand is sent by regular mail, the date of receipt by the addressee; if sent by registered mail, the date of delivery against a signature.

1.6.2. If the Demand is sent via a courier service, the date of delivery by the courier.

1.6.3. If the Demand is sent by email, the date of receipt by the Company.

1.6.4. If a Request is submitted to the Company’s documentation support department, the date of delivery shall be the date of receipt, confirmed by a signature.

1.7. Company documents shall be provided within the timeframe specified in the Request, which may not be less than seven business days from the date the Request is submitted. In the event that a Request involves a large volume of documents (more than 5 documents and/or more than 200 pages), the timeframe specified in Clause 1.6 of this Procedure may be extended to facilitate the fulfillment of such a Request, provided that the extension does not exceed twenty business days. In such a case, the Company shall notify the authorized person of the extension and the reasons for it no later than seven business days from the date the Request is submitted. This notification shall be sent to the postal address provided in the Request.

1.8. Company documents may be provided in the following forms:

- Review of documents: making documents available for review on the premises of the Company’s executive body (at the location of the Company’s executive body) in accordance with the procedures and terms established by Article 91 of the Federal Law "On Joint-Stock Companies," the Company’s Charter, and this Regulation. Such review shall take place between 14:00 and 16:00 (local time) at the offices of the Corporate and Property Relations Department (7 Babushkina St., Sterlitamak) on a date mutually agreed upon by the authorized person and the Company.

- Provision of copies of documents: supplying copies of documents in accordance with the procedures and terms established by Article 91 of the Federal Law "On Joint-Stock Companies," the Company’s Charter, and this Regulation. 1.9. The Company may reject a request from an eligible person for the provision of documents that would only need to be created as a result of such a request, provided that the Company is not under a statutory obligation to retain or provide such documents.

1.10. The Company shall deny a request if any of the following circumstances exist:

1.10.1. The nature and volume of the requested documents are disproportionate to the extent of the shareholder’s actual participation in the management of the Company’s affairs, as determined by the number of shares they hold.

1.10.2. The requested documents are not in the Company’s possession—for example, because they have been destroyed following the expiration of their mandatory retention period.

Within seven business days of receiving the request, the Company shall notify the eligible person who submitted it—in writing—that the document is unavailable. Where such information is known, the Company shall also provide the reason for its absence, its current location, and the anticipated date by which it might be returned to the Company or reconstructed (if such reconstruction is possible).

1.10.3. The requested documents contain information that constitutes the Company’s trade secret; the eligible person was informed of this but failed to provide a signed confidentiality undertaking, as required by the Directive of the Central Bank of the Russian Federation No. 3388-U dated September 22, 2014.

1.11. A reasoned refusal by the Company to grant an eligible person access to documents and/or to provide copies thereof shall be set out in writing and delivered (or sent by mail) to the eligible person who submitted the request.

1.12. The Chairman of the Board of Directors, members of the Board of Directors, and shareholders are not permitted to disclose information constituting the Company’s commercial secrets that has become available to them in the course of performing their official duties. They may provide official commentary or clarification regarding decisions made by the Board of Directors, and may articulate the Board’s position on matters discussed during its meetings, provided that they act in a reasonable and responsible manner and remain mindful of restrictions concerning the disclosure of information that constitutes a commercial, state, or other legally protected secret.