Regulation on Disciplinary Liability of Employees of the National Securities and Stock Market Commission

NATIONAL SECURITIES AND STOCK MARKET COMMISSION DECISION Kyiv On Approval of the Regulation on Disciplinary Liability of Employees of the National Securities and Stock Market Commission In accordance with Articles 147-152 of the Labor Code of Ukraine, Part 3 of Article 11 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets" The National Securities and Stock Market Commission DECIDES:

1. Approve the Regulation on Disciplinary Liability of Employees of the National Securities and Stock Market Commission, attached hereto.
2. The Human Resources Department is to familiarize Commission employees with this decision under personal signature.
3. Declare invalid the Commission's Decision dated 04.11.2024 No. 18/21/1365/K01 "On Approval of the Disciplinary Code of the National Securities and Stock Market Commission".
4. The Administrative Activity Management Department is to ensure publication of this decision on the Commission's official website and its transmission via the automated electronic document management system ASKOD to the Chairman of the Commission, Commission members and their assistants, the Head of the Commission Office and Deputy Heads of the Commission Office, and heads of independent structural units of the Commission Office.
5. This decision enters into force from the day of its adoption.

2 6. Control over the implementation of this decision is entrusted to the Chairman of the Commission R. Magomedov. Chairman of the Commission Ruslan MAGOMEDOV Protocol of the Commission meeting dated 08.08.2025 No. 80

APPROVED Decision of the National Securities and Stock Market Commission ______________ No. ___________ Regulation on Disciplinary Liability of Employees of the National Securities and Stock Market Commission

1. This Regulation determines the grounds and procedure for holding employees of the National Securities and Stock Market Commission (hereinafter — the Commission) accountable for disciplinary offenses.
2. This Regulation does not apply to issues of holding the Chairman and members of the Commission accountable for disciplinary offenses.
3. With respect to Commission employees, the following disciplinary sanctions may be applied: reprimand and dismissal.
4. Disciplinary sanctions are applied by the appointing subject:

• with respect to the Head of the Commission Office — by the Chairman of the Commission;
• with respect to other Commission employees — by the Head of the Commission Office.

5. Accountability for disciplinary offenses is carried out within the framework of disciplinary proceedings.
6. The procedure for conducting disciplinary proceedings involves:

1. making a decision to initiate disciplinary proceedings;
2. forming the disciplinary commission and its composition;
3. forming and reviewing the disciplinary case;
4. making a decision based on the results of the review of the disciplinary case.

7. Disciplinary proceedings are initiated by an order of the appointing subject for violations of labor discipline. Violations of labor discipline include:

1. violation by the employee of legislation, including acts of the Commission, provisions of the Employee Code of Ethics of the Commission;
2. manifestation of disrespect for the state, state symbols of Ukraine, or the Ukrainian people;
3. actions that harm the authority of the Commission;
4. non-performance or improper performance of official duties, orders (directives), and assignments of managers adopted within their authority;
5. non-compliance with internal labor regulations;
6. exceeding official authority, provided it does not contain the elements of a criminal or administrative offense;
7. use of authority for personal (private) interests or for the unlawful personal interests of other persons;
8. failure to notify the appointing subject about the emergence of direct subordination relationships between an employee and close relatives within 15 days from the date of their emergence;
9. absenteeism (including absence from work for more than three hours during a working day) without valid reasons;
10. appearance at work in a state of intoxication, narcotic, or toxic intoxication;
11. adoption by the employee of an unjustified decision that caused damage to the integrity of state or communal property, or their illegal use;
12. adoption by the employee of a decision that contradicts the law or conclusions regarding the application of the relevant norm of law, as set out in rulings of the Supreme Court, for which a separate ruling has been issued by the court;
13. non-compliance by the employee with requirements of normative legal acts, acts of the Commission, and acts of Commission officials regarding occupational safety, fire safety, and technological safety.

8. The ground for initiating disciplinary proceedings is the receipt by the appointing subject of justified information in the form of an official memo regarding a possible violation of labor discipline.
9. For the purpose of collecting information about the circumstances that became the basis for initiating disciplinary proceedings, for determining the degree of guilt, nature, and severity of the disciplinary offense, a disciplinary commission is formed.
10. The order of the appointing subject specifies the ground for initiating disciplinary proceedings, the surname, first name, and patronymic (if any) of the Commission employee against whom disciplinary proceedings are initiated, the term for conducting disciplinary proceedings, the composition of the disciplinary commission, and the head of the disciplinary commission.
11. The disciplinary commission operates with a composition of no fewer than three members. The composition of the disciplinary commission must include at least one Commission employee with a legal education, as well as a representative of the human resources service. The head and members of the disciplinary commission exercise their powers on a voluntary basis.
12. Disciplinary proceedings begin from the date of issuance of the order on initiating disciplinary proceedings and end with the issuance of an order imposing a disciplinary sanction on the Commission employee against whom disciplinary proceedings are being conducted (hereinafter — the employee) or closing the disciplinary proceedings.

3 13. The term for conducting disciplinary proceedings is determined by the appointing subject and may not exceed 25 calendar days. 14. A disciplinary sanction may be applied no later than one month from the day of detection of the violation of labor discipline, excluding the time of the employee's temporary disability or leave. A disciplinary sanction may not be imposed later than six months from the day the violation of labor discipline was committed. 15. The head and members of the disciplinary commission bear personal responsibility for the completeness and objectivity of the conclusions of the disciplinary proceedings and for the disclosure of information about the disciplinary proceedings. 16. In cases where disciplinary proceedings involve information with restricted access, such proceedings are conducted in accordance with the provisions of the Laws of Ukraine "On Capital Markets and Organized Commodity Markets", "On State Secrecy", "On Information", "On Protection of Personal Data", and "On Access to Public Information". 17. The head of the disciplinary commission organizes its work, appoints the place and date of the disciplinary commission meeting and chairs it, facilitates the exercise of rights and obligations by participants in the disciplinary proceedings, ensures objective and complete clarification of the circumstances of the case, takes necessary measures to ensure proper order at the meeting, and exercises other powers related to ensuring the activities of the disciplinary commission. 18. Organizational and material-technical support of the disciplinary commission's work, keeping, forming, and storing minutes of disciplinary commission meetings, forming materials of the disciplinary case, their storage, and familiarization of the head and members of the disciplinary commission and the employee with the materials of the disciplinary case is ensured by the human resources service. 19. Members of the disciplinary commission have the right to familiarize themselves with materials belonging to the powers of the disciplinary commission, express their position during the disciplinary commission meeting, and participate in decision-making by voting, initiate the convening of a disciplinary commission meeting if necessary, and exercise other powers related to ensuring the activities of the disciplinary commission. 20. Members of the disciplinary commission have the right to obtain explanations from the employee and other persons regarding the circumstances of the case, obtain from structural subdivisions of the Commission necessary documents or their copies and attach them to the materials of the disciplinary case, and obtain consultations from relevant specialists on issues related to disciplinary proceedings. 21. The form of work of the disciplinary commission is a meeting.

4 A meeting of the disciplinary commission is quorate if no fewer than two-thirds of its composition, approved in accordance with paragraph 11 of this Regulation, participate in it. 22. Members of the disciplinary commission, the employee, and other persons who are participants in the disciplinary proceedings may participate in the meeting remotely via video conference, having notified the head of the disciplinary commission of such reasons by means of electronic communication no later than one day before the meeting. The disciplinary commission may also make a decision to hold a meeting remotely via video conference using appropriate technical means, which is noted in the minutes of its meeting. Before the start of the disciplinary commission meeting, all persons participating remotely in the meeting in the cases defined by the first and second paragraphs of this point present a passport of a citizen of Ukraine or another document certifying identity. During the remote meeting of the disciplinary commission via video conference, adequate quality of image and sound is ensured, and the consideration of issues is carried out in compliance with legislation in the field of information protection. In the event of the impossibility of holding a disciplinary commission meeting remotely via video conference due to technical problems, such technical problems are recorded by drawing up a corresponding act, which is attached to the minutes of the disciplinary commission meeting. 23. Recording the holding of a meeting using technical means may be carried out by decision of the disciplinary commission. 24. The disciplinary commission, within the scope of its granted powers, makes decisions by a majority vote of its members present at the meeting. Members of the disciplinary commission have one vote each and may vote "for" or "against". During voting, any doubts regarding the presence of a disciplinary offense in the employee's actions are interpreted in his favor. In the event of an equal distribution of votes, the vote of the head of the disciplinary commission is decisive. 25. Decisions of the disciplinary commission are documented in minutes. In the event of a disciplinary commission meeting held remotely via video conference, the minutes may be prepared in electronic form and signed by the members of the disciplinary commission present at the meeting with a qualified electronic signature in compliance with legislation in the field of information protection. The minutes specify the first name and surname of the head of the disciplinary commission, members of the disciplinary commission present at the meeting, experts (specialists) in the relevant field and/or on relevant issues, other representatives of state bodies (if involved), the place, date, and method of holding the meeting, the agenda, the results of the consideration of the agenda, the results of voting on each item of the agenda, and the decisions made.

5 26. The employee is obliged to provide the disciplinary commission with explanations regarding the circumstances that became the basis for initiating disciplinary proceedings in written form. Explanations are provided in paper or electronic form personally or by sending them to the official electronic address of the Commission with a qualified electronic signature. 27. The disciplinary case is formed by the human resources service jointly with the head of the disciplinary commission. 28. The disciplinary case must contain:

1. the date and place of its formation;
2. grounds for opening disciplinary proceedings;
3. explanations of the employee regarding the circumstances that became the basis for initiating disciplinary proceedings, and/or an act on refusal to provide such explanations;
4. explanations of other persons who are aware of the circumstances that became the basis for initiating disciplinary proceedings (if any);
5. duly certified copies of documents and materials confirming and/or refuting the fact of committing a disciplinary offense;
6. a description of the materials contained in the disciplinary case.

29. Documents and materials attached to the disciplinary case must comply with requirements for documenting management information and organizing work with documents in the Commission (except for documents provided to the disciplinary commission or the Commission by other bodies or persons who are not employees of the Commission).
30. After the completion of the formation of the disciplinary case, the head of the disciplinary commission ensures that members of the disciplinary commission and the employee are familiarized with the materials of the disciplinary case.
31. The employee has the right:

1. to be present at the disciplinary commission meeting to provide explanations regarding the circumstances that became the basis for initiating disciplinary proceedings;

6 2) to familiarize themselves with the materials of the disciplinary case, including requesting and receiving relevant documents and their copies; 3) to provide explanations, as well as relevant documents and materials regarding the circumstances being investigated; 4) to file a petition for the necessity of obtaining and attaching new documents to the materials of the disciplinary case, obtaining additional explanations from persons who may be aware of the circumstances of the case; 5) to receive legal assistance; 6) to exercise other rights established by the Constitution and laws of Ukraine. 32. The employee is notified of the date, time, place, and method of holding the disciplinary commission meeting by handing over information or documents or sending them to his email address, or using other telecommunications means based on contact data available in the personal file. Such handing over or sending is carried out no less than three calendar days before the day of the disciplinary commission meeting. In the event of the disciplinary commission making a decision to hold a meeting remotely via video conference, the disciplinary commission notifies the employee in accordance with the first and second paragraphs of this point. If the employee does not arrive at the meeting or does not connect to the meeting remotely according to the method of holding the disciplinary commission meeting defined in the first paragraph of this point, and does not notify of valid reasons for his absence, nor provide written explanations regarding the circumstances that became the basis for initiating disciplinary proceedings, the disciplinary commission draws up an act on refusal to provide explanations. The absence of the employee does not prevent the conduct of disciplinary proceedings. 33. The disciplinary commission reviews the properly formed disciplinary case and, based on the results of such review, makes a decision on the presence or absence of a disciplinary offense in the employee's actions and grounds for holding him accountable for disciplinary offenses, which is noted in the minutes of the meeting. 34. The disciplinary commission must establish:

1. whether the circumstances on the basis of which disciplinary proceedings were initiated existed;
2. whether the employee's actions contain signs of a disciplinary offense;
3. what characterizes the disciplinary offense, the circumstances under which it was committed, circumstances mitigating or aggravating responsibility;
4. whether the employee is subject to disciplinary accountability;

7 5) what type of disciplinary sanction may be applied to the employee. 35. The result of the review of the disciplinary case is the conclusion of the disciplinary commission, which is submitted for approval to the appointing subject. The conclusion is prepared by the disciplinary commission after making a decision based on the results of the review of the disciplinary case and is signed by all its members who participated in the voting. In the event of a disciplinary commission meeting held remotely via video conference, the conclusion of the disciplinary commission may be prepared in electronic form and signed by all its members who participated in the voting with a qualified electronic signature in compliance with legislation in the field of information protection. 36. Members of the disciplinary commission have the right to express their separate opinion, which is attached to the conclusion. 37. The conclusion consists of an introductory, motivational, and operative part and must contain:

1. the date of preparation;
2. information regarding the grounds for initiating disciplinary proceedings;
3. surname, first name, patronymic (if any) of the employee, his position, other information significant for conducting disciplinary proceedings;
4. in the event of the absence of a disciplinary offense in the employee's actions: facts confirming the absence of commission of a disciplinary offense with appropriate justification; statements, petitions, explanations of the employee, and decisions made by the disciplinary commission based on their review; conclusion on the absence of a disciplinary offense in the employee's actions;
5. in the event of the presence of a disciplinary offense in the employee's actions: facts confirming the commission of a disciplinary offense by the employee, with reference to the provisions of relevant normative legal acts, acts of the Commission; circumstances that led to the commission of the disciplinary offense; degree of guilt; nature of the disciplinary offense, degree of its severity, occurrence of severe consequences; circumstances mitigating or aggravating disciplinary responsibility; statements, petitions, explanations of the employee, and decisions made by the disciplinary commission based on their review; conclusion on the presence of a disciplinary offense in the employee's actions and grounds for holding him accountable for disciplinary offenses; type of disciplinary sanction recommended for application, or circumstances excluding the possibility of imposing a disciplinary sanction.

8 38. The disciplinary commission submits the conclusion for approval to the appointing subject together with the materials of the disciplinary case no later than the next working day after its signing. 39. The appointing subject, within five calendar days from the date of receipt of the conclusion of the disciplinary commission, makes a decision on imposing a disciplinary sanction on the employee or closing the disciplinary proceedings, which is documented by an order of the appointing subject. 40. The human resources service ensures that the employee is familiarized with the decision of the appointing subject under personal signature. In the event of the employee's refusal to sign for familiarization, the human resources service draws up an act on refusal. 41. After the decision is made, the appointing subject transfers the disciplinary case to the human resources service for its attachment to the employee's personal file. Director of the Legal Support and Internal Compliance Control Department Stepan ZOLotar