Anti-corruption policy

Development and introduction of standards and procedures to ensure good practice

• An anti-corruption plan for 2025 was developed and approved (all measures of the plan were fully completed on time);
• Changes were made to:
• • the procedure for receiving and reviewing applicants’ complaints about possible corruption in PJSC Rosseti South received through the hotline,
  • the regulations on conflict of interest settlement,
  • the regulations on the notification of the receipt of a business gift by the Company’s employees,
  • an anti-corruption clause included in the Company’s contracts.

Documents adopted for prevention of and counteraction to corruption are communicated to employees on a mandatory basis

Establishment of the inner control and risk management process to prevent and combat corruption

Reports on the results of anti-corruption monitoring for 2024 and the first six months of 2025 were prepared and forwarded to the Management Board, the Audit Committee and further to the Board of Directors of the Company for review. The reports were reviewed and taken under advisement by the Audit Committee and the Board of Directors of the Company unconditionally.

During 2025, financial and economic activities in the branches of PJSC Rosseti South were revised, and PJSC Rosseti South, Interregional Energy Institute of the South, Southern Interregional Qualification Centre for Electric Power Industry were subject to audit inspections. In order to address the identified issues and deficiencies, we developed corrective action plans. We also established deadlines for their implementation and identified responsible individuals for each plan’s execution and monitoring.

The annual report on the second line of defence for 2024, as well as the results of the self-assessment of the effectiveness of control procedures and quarterly updated functional and business process risk reports were prepared and directed to the Company’s management. A progress report on the risk management action plan within the framework of the anti-corruption subprocess was presented.

During the year, the risk of committing a corruption-related crime by employees of the Company was assessed and monitored, and the risk description was updated

Prevention and settlement of conflicts of interest

A total of 2,243 employees of the Company and 2,580 employees of JSC Rosseti Kuban were subject to annual declaration of employee conflicts of interest for 2024. The 2024 declaration campaign identified no cases of conflict of interest or pre-conflict situations.

The Corporate Ethics Compliance and Conflict of Interest Commission had one meeting.

The materials provided by substituting candidates were reviewed, 755 conclusions were prepared on the presence/absence of a conflict of interest between candidates for vacant positions (when applying for a job/transfer) at the Company. There are no cases of rejection of candidates based on negative opinions in 2025. Based on facts of possible conflicts of interest and pre-conflict situations involving Company employees, 20 additional reviews were conducted in preparation of conclusions on the presence/absence of conflicts of interest among candidates for vacant positions, and additional information was requested regarding candidates and persons closely related to them. There are no situations requiring settlement.

Consideration and resolution of information on possible instances of corruption and other abusive practice

In 2025, there was one report of possible corruption. The report was reviewed in due time under the current procedure in place. As a result, no signs of corrupt practices on the part of the Company’s employees were confirmed, and no signs of conflict of interest were identified.

In the fourth quarter of 2025, three criminal cases were initiated against the Company’s employees under art. 290 of the Criminal Code of the Russian Federation (bribe-taking). Two criminal cases under part 2 of art. 290 of the Criminal Code of the Russian Federation were against the former chief engineer of the Pravoberezhny power grid region of the Astrakhanenergo branch, and one criminal case under part 5 of art. 290 was against the former engineer of the electricity metering and services sale group in the Aksai power grid region of the Rostovenergo branch of PJSC Rosseti South.

Currently, no court decisions have been taken on these offences.

Anti-corruption measures in interaction with partners and subcontractors

Data on concluded contracts, additional agreements and subcontractors of the Company’s counterparties were entered into the automated system for analysing and gathering information about beneficiaries on a daily basis. In 2025, 18,600 contracts and additional agreements were uploaded to this system.

The anti-corruption clause and obligations of the counterparty to provide information about beneficiaries are included in 2,486 contracts submitted for procurement procedures, 2,329 beneficiaries are accounted for.

The procurement documentation underwent the approval procedure.

Verified:

• 796 technical assignments, 69 of which were returned to the initiators for further revision. All comments were eliminated by the originators;
• 1,442 assessment reports and analytical notes, 115 of which were returned to the originator for further revision and re-submitted thereafter.

As a result of the work done in 2025, the initial (maximum) price for procurement procedures was reduced by RUB 166.817 million, including rebidding and pre-contract negotiations.

Legal education and laying the groundwork of law-abiding behaviour of employees, consulting and training of employees

The Company continuously updates its legal framework and takes all the necessary measures and anti-corruption procedures to instil zero tolerance to corruption in its employees.

During 2025, 19 employees of the Company’s Department of Security and Anti-Corruption Policy underwent relevant professional retraining, including:

• 3 employees under the Anti-Corruption Compliance programme;
• 11 employees under the Economic Security programme;
• 5 employees under the Digital Sovereignty Model, Energy Development Strategy programme.

In order to improve the effectiveness of awareness-raising, educational and other corruption prevention activities, the Company regularly updates the regulatory and legal framework, counselling and training of employees.

The Company’s corporate website has the Anti-Corruption section that contains up-to-date information on anti-corruption activities, hotline numbers and other ways to report possible instances of corruption.

A total of 85 Information stands titled “Territory without Corruption” containing up-to-date information on the requirements of anti-corruption legislation, general principles of the Anti-Corruption Policy, hotlines, and other available ways to report corruption are placed in the reception areas of subdivisions and power grid regions, as well as in the Customer Service Centres of PJSC Rosseti South’s branches.

Individual staff consultations on the application of anti-corruption standards and procedures are constantly conducted.

In 2025, verification measures were conducted at the Kalmenergo, Astrakhanenergo and Rostovenergo branches of PJSC Rosseti South, including offsite visiting. Working meetings were held with security teams and human resources offices, and information was shared on the organisation of a unified approach to implementing measures outlined in the Anti-Corruption Policy.

As part of our ongoing efforts to create a culture of zero tolerance for corruption within our Company, we developed a set of slides that were sent to our branches. These slides contain principles and requirements for preventing conflict situations within PJSC Rosseti South. They were created taking into account recent changes in Russian anti-corruption legislation.

Also, on the eve of the declaration campaign, an awareness-raising handout was developed and distributed to each employee