Regulatory Document on Information Disclosure by Authorized Rating Agencies

NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET DECISION Kyiv On Approval of the Regulation on Information Disclosure by Authorized Rating Agencies In accordance with paragraph 1 of part 3 of Article 2, paragraph 1 of part 1 of Article 7, Article 29, part 5 of Article 30 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets", paragraphs 10, 11, 12 of part 3 of Article 36 of the Law of Ukraine "On Rating" The National Commission for Securities and Stock Market D E C I D E D:

1. Approve the Regulation on Information Disclosure by Authorized Rating Agencies, attached hereto.
2. Approve the Amendments to the Regulation on Information Disclosure by Issuers of Securities, as well as Persons Providing Security for Such Securities, approved by the Decision of the National Commission for Securities and Stock Market dated June 06, 2023 No. 608, registered in the Ministry of Justice of Ukraine on August 02, 2023 under No. 1307/40363, attached hereto.
3. The Department of Methodology shall ensure the submission of this decision for state registration to the Ministry of Justice of Ukraine.
4. The Administration of Administrative Activities shall ensure the publication of this decision on the official website of the National Commission for Securities and Stock Market.

2 5. The Department of Legal Development, after state registration of the decision by the Ministry of Justice of Ukraine, shall ensure the publication of this decision on the official website of the National Commission for Securities and Stock Market. 6. This decision enters into force on January 01, 2026, but not earlier than the day following the day of its official publication. 7. Control over the execution of this decision shall be vested in a member of the National Commission for Securities and Stock Market Ya. Shliakhov. Chairman of the Commission Ruslan MAGOMEDOV Protocol of the Commission meeting dated 19.12.2025 No. 117

APPROVED Decision of the National Commission for Securities and Stock Market ..2025 No._______ Regulation on Information Disclosure by Authorized Rating Agencies I. General Provisions

1. This Regulation determines the procedure, deadlines and requirements for disclosure of regular information about an authorized rating agency (hereinafter – ARA) and additional details contained in such information, as well as information about the rating activities of the ARA.
2. In this Regulation, terms and concepts are used in the following meanings:

1. geographic region – Autonomous Republic of Crimea, 24 regions defined by the Constitution of Ukraine and two cities with special status (Kyiv and Sevastopol);
2. EDR – Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations;
3. Law on Joint Stock Companies – Law of Ukraine "On Joint Stock Companies";
4. Law on Accounting – Law of Ukraine "On Accounting and Financial Reporting in Ukraine";
5. Law on Rating – Law of Ukraine "On Rating";
6. Law on Capital Markets – Law of Ukraine "On Capital Markets and Organized Commodity Markets";
7. name – name (within the meaning of the Civil Code of Ukraine) or full name of a physical person – a non-resident according to the document certifying such person;

2 8) foreign rating agency – a rating agency created in accordance with the legislation of a foreign state; 9) foreign states of the risk zone – countries that fall under the criteria defined in Appendix 1; 10) information subject to disclosure by the ARA – regular information (annual reporting information (hereinafter – annual information) and semi-annual reporting information (hereinafter – semi-annual information)) and additional details contained in it, information about the rating activities of the ARA, information about owners of voting shares (stakes) above the threshold values of share packages (stakes), other information that is subject to placement in the database of the person who carries out activities to publish regulated information on behalf of participants of capital markets and professional participants of organized commodity markets, as well as disclosed in accordance with the requirements of legislation; 11) head – chairman of the collegial executive body, sole executive body, chief executive director (in a one-tier management structure of the ARA); 12) corporate governance code approved by the NCSPFM – Corporate Governance Code: Key Requirements and Recommendations, approved by the Decision of the National Commission for Securities and Stock Market dated March 12, 2020 No. 118; 13) person publishing regulated information – a person who carries out activities to publish regulated information on behalf of participants of capital markets and professional participants of organized commodity markets; 14) full name – full name (within the meaning of the Civil Code of Ukraine) or full name of a legal entity – a non-resident according to the constituent documents; 15) Regulation on Submission of Regulated Data – Regulation on Submission of Administrative Data and Information in the Form of Electronic Documents to the National Commission for Securities and Stock Market, approved by the Decision of the State Commission for Securities and Stock Market dated May 13, 2011 No. 492, registered in the Ministry of Justice of Ukraine on June 25, 2011 under No. 789/19527; 16) Regulation on Ownership Structure – Regulation on the Ownership Structure of Legal Entities, Procedure and Conditions for Obtaining Approval of the National Commission for Securities and Stock Market for Significant Participation in Professional Participants of Capital Markets and Organized Commodity Markets,

3 approved by the Decision of the National Commission for Securities and Stock Market dated November 14, 2025 No. 09/21/3187/K03, registered in the Ministry of Justice of Ukraine on November 28, 2025 under No. 1785/45191; 17) interim report – a document in which the ARA discloses semi-annual information in accordance with the requirements of this Regulation; 18) council – supervisory board or board of directors (in a one-tier management structure of the ARA); 19) rating agency – a legal entity whose predominant type of activity is the determination of ratings on a professional basis. A rating agency intending to determine public credit ratings in Ukraine is obliged to undergo authorization and carry out activities in accordance with the requirements of the Law of Ukraine "On Rating"; 20) annual report – a document in which the ARA discloses annual information in accordance with the requirements of this Regulation; 21) stakeholder – persons and/or groups of persons whose interests are directly related to or intersect with the interests of the ARA (for example: participants, employees, creditors, suppliers of services and financial instruments, clients or counterparties, associations or unions of the aforementioned persons, local communities, the state); 22) statement regarding semi-annual information – an official position of persons performing management functions that, to the best of their knowledge, the interim financial statements prepared in accordance with international standards of financial reporting and in accordance with the Law on Accounting, contain reliable and objective information about the assets, liabilities, financial position, profits and losses of the ARA and legal entities under its control (if any) within the consolidated financial statements (if consolidated financial statements are prepared), as well as that the management interim report contains reliable and objective information; 23) statement regarding annual information – an official position of persons performing management functions and signing the annual information of the ARA that, to the best of their knowledge, the annual financial statements prepared in accordance with international standards of financial reporting and in accordance with the Law on Accounting, contain reliable and objective information about the assets, liabilities, financial position, profits and losses of the ARA and legal entities under its control (if any) within the consolidated financial statements (if consolidated financial statements are prepared), as well as that the management report contains reliable and objective information about the development and conduct of business activities and the state of the ARA and

4 legal entities under its control, within consolidated reporting, together with a description of the main risks and uncertainties they face in their business activities; 24) URL-address (Universal Resource Locator) – a universal locator of a certain resource (for example, a file) on the Internet. Other terms used in this Regulation are used in the meanings defined by the Law on Rating, the Law on Capital Markets, the Law on Joint Stock Companies. 3. This Regulation applies to ARAs, including foreign ones, included in the Register of Authorized Rating Agencies. 4. The body ensuring compliance with the requirements for disclosure of information by the ARA subject to publication in accordance with legislation is the council or, if the creation of a council is not provided for in the charter, another management body of the ARA. 5. Information subject to disclosure by the ARA, in accordance with the requirements of this Regulation, includes:

1. regular information;
2. information about the rating activities of the ARA;
3. other information provided for in Section V of this Regulation.

6. Disclosure of information by the ARA is carried out in compliance with the principles:

1. legality;
2. timeliness;
3. reliability;
4. balance;
5. completeness.

7. The principle of legality implies that information disclosure is carried out exclusively by persons authorized by the disclosing entity to carry out disclosure of the corresponding information.

5 8. The principle of timeliness implies that information disclosure will take place as soon as possible, but in any case – no later than the deadlines provided for in this Regulation. 9. The principle of reliability implies that information subject to disclosure is properly verified and corresponds to reality. 10. The principle of balance implies that information disclosure covers both positive and negative information. 11. The principle of completeness implies that information disclosure will take place in full volume, in particular, all information that has a significant impact on decision-making by interested persons must be disclosed, even if disclosure of such information is not required by legislation. 12. In the event that the ARA is an issuer of securities or a person providing security for such securities, or a corporate rights advisor, such ARA is obliged to additionally disclose regulated information in accordance with the Law of Ukraine "On Capital Markets and Organized Commodity Markets" and the Regulation on Information Disclosure by Issuers of Securities, as well as Persons Providing Security for Such Securities, approved by the Decision of the National Commission for Securities and Stock Market dated June 06, 2023 No. 608, registered in the Ministry of Justice of Ukraine on August 02, 2023 under No. 1307/40363. II. Procedure for Disclosure of Information by the ARA

1. Features of the Procedure for Disclosure of Information by the ARA
2. The ARA discloses information provided for by this Regulation by:

1. placement on the ARA website;
2. placement in the database of the person who publishes regulated information;
3. submission to the NCSPFM.

14. Information is disclosed:

1. in the state language, and additionally, at the request, in any other language of EU member countries – for ARAs;
2. in the state language and/or in English – for foreign ARAs.

6 15. In the event of disclosure by the ARA of information in a language other than the state language, such ARA ensures the reliability and completeness of disclosure of information, as well as bears responsibility for the identity of content and correctness of translation of such information. In the event of discrepancies and/or inconsistencies between information subject to disclosure by the ARA, which was simultaneously disclosed in the state language and additionally in another language of EU member countries, priority is given to the information disclosed in the state language. Requirements for submission of information and documents for placement in the database of the person who publishes regulated information in accordance with subparagraph 2 of paragraph 13 of this Regulation, as well as regarding confirmation of the fact of such submission, are defined in Appendix 2. If the person who publishes regulated information also provides the ARA with information services on capital markets and organized commodity markets with submission of reporting and/or administrative data to the NCSPFM, such person independently submits the corresponding information to the NCSPFM and carries out confirmation of such submission, notifying the ARA in the manner established by the contract, regulation, or other document concluded with the ARA. In such a case, the ARA does not need to separately submit information to the NCSPFM, as defined in subparagraph 3 of paragraph 13 of this Regulation. 16. The ARA submits information and documents to the NCSPFM in accordance with subparagraph 3 of paragraph 13 of this Regulation in the manner established by the Regulation on Submission of Regulated Data:

1. through a person who provides information services on capital markets and organized commodity markets with submission of reporting and/or reporting data to the NCSPFM;
2. independently. For the purposes of interaction with the software and technical complex (PTK) of the NCSPFM, the information and communication system of the ARA must ensure connection to the PTK of the NCSPFM and operation in accordance with the interaction protocol defined by a separate normative and technical act of the NCSPFM regarding connection and interaction protocol of external software and technical complexes with the PTK of the NCSPFM for submission to the NCSPFM of reporting data and information in the form of electronic documents.

17. The ARA is obliged to place information subject to disclosure by the ARA on its own website in accordance with subparagraph 1 of paragraph 13 of this Regulation. The ARA ensures free access to information on its own website and cannot restrict access or charge a fee for access to information subject to mandatory disclosure on such website.

7 Information of the ARA must be placed on the website in a manner that ensures its easy and understandable search. All information disclosed in accordance with the requirements of this Regulation is placed in a section titled "Information Subject to Disclosure by the ARA". A link to the page for transitioning to this section is placed on the main (home) page of the ARA website. Information disclosed in accordance with the requirements of this Regulation and placed on the own website of the ARA in a section titled "Information Subject to Disclosure by the ARA" is divided into three types:

1. regular information;
2. information about the rating activities of the ARA;
3. other information. Information is subject to publication by the ARA on its own website in the form of an electronic document based on a qualified open key certificate of an authorized person of the ARA and suitable for:
4. human perception;
5. printing on A4 paper;
6. contextual search and copying of any information placed on it (in DOC (DOCX) or PDF format);
7. downloading;
8. reading the qualified open key certificate of an authorized person of the ARA. Information is also placed in a machine-readable format (XML or iXBRL) with the imposition of an electronic signature of an authorized person of the ARA based on a qualified open key certificate. In the event of placement on the own website of financial statements subject to disclosure by the ARA in accordance with the requirements defined in paragraph 23 of this Regulation, in iXBRL format, placement of such information in another format provided for in paragraph 5 of this clause is not mandatory. Information subject to disclosure by the ARA remains publicly available on the own website of the ARA for at least 10 years after its disclosure. In the event of a change of the own website, the ARA is obliged to place on the new own website all information that was placed earlier and whose storage period has not expired – from the day of commencement of operation of the new own website.

8 18. Information is submitted to the NCSPFM in the form of electronic documents in accordance with the normative legal act of the NCSPFM regulating the procedure for submission of reporting data and information in the form of electronic documents. Information in electronic form is compiled in accordance with the description of sections and XML file schemes defined by a separate act of normative and technical character of the NCSPFM. Information is compiled by the ARA using the Directory and Classifier System of the National Commission for Securities and Stock Market, approved by the Decision of the National Commission for Securities and Stock Market dated May 08, 2012 No. 646, registered in the Ministry of Justice of Ukraine on May 25, 2012 under No. 831/21143. 19. Upon written request of an authorized person of the NCSPFM, the ARA is obliged to submit to the NCSPFM within the deadline provided for in the request, the corresponding information by sending through the personal cabinet of the ARA in the Complex Information System of the NCSPFM, taking into account the requirements of legislation on electronic documents and electronic document flow, in accordance with the requirements and means defined by a separate document of normative and technical character, information about which is published on the official website of the NCSPFM. 20. During disclosure of information, the ARA has the right not to provide copies of documents in its composition, if such documents are available in the NCSPFM and/or in public access in visual form that allows human perception of their content, in machine-readable format and freely downloadable. In such a case, the ARA provides requisites to ensure the possibility of automatic downloading of copies of these documents from the Internet, containing the full address of the file, by which free and direct downloading of its copies is carried out by automation tools (without the need for prior registration, entering codes, other additional actions to ensure downloading), in the format of a URL-address, file name (including the extension in the file name, which must correspond to its type/format), exact file size and checksum to ensure the possibility of automatic control of the accuracy of content copying. 21. The ARA notifies the NCSPFM, shareholders (participants) and other stakeholders about cases of untimely disclosure and possible untimely disclosure of information no later than 10:00 on the next working day after:

1. expiration of the deadline for disclosure of information by the ARA;
2. the day when the ARA became aware of possible untimely disclosure of information.

9 The ARA notifies the NCSPFM – by submitting a notification of untimely disclosure of information subject to disclosure by the ARA, in the form according to Appendix 3, signed by an authorized person of the ARA with justification of the reasons that led or may lead to untimely disclosure of information and a new date of publication of information subject to disclosure by the ARA. The ARA notifies shareholders (participants) and other stakeholders – by publishing on its own website a notification in the form according to Appendix 3 with justification of the reasons that led or may lead to untimely disclosure of information and a new date of publication of information subject to disclosure by the ARA. 22. The ARA notifies the NCSPFM, shareholders (participants) and other stakeholders about cases of disclosure of unreliable information by it no later than 10:00 on the next working day after the day when the ARA became aware of disclosure of unreliable information. The ARA refutes such information and discloses corrected information in the same manner as the unreliable information was disclosed. The ARA notifies the NCSPFM – by submitting a notification of disclosure of unreliable information subject to disclosure by the ARA in the form according to Appendix 4, signed by an authorized person of the ARA, about the fact of publication of unreliable information and with justification of the reasons for publication of unreliable information, with mandatory indication of what exactly was corrected in the information. The ARA notifies shareholders (participants) and other stakeholders – by publishing on its own website a new file with corrected information with mandatory indication of what exactly was corrected in it, as well as saving the file with unreliable information with an indication in the file name about its unreliability, as well as a notification according to Appendix 4. 23. The ARA discloses financial statements prepared in accordance with the Law on Accounting, international standards of financial reporting. In the event that, in accordance with legislation, the ARA is obliged to prepare consolidated (sub-consolidated) financial statements, the financial statements must contain consolidated (sub-consolidated) financial statements together with the audit report and separately its own financial statements together with the audit report. The ARA, for the preparation of financial statements (annual, interim), applies international standards of financial reporting, and prepares financial statements and management report / consolidated (sub-consolidated) financial statements and consolidated management report in the event of preparation of consolidated financial statements, based on the taxonomy of financial reporting under international standards of financial reporting in a single electronic format (XBRL format), defined by the central executive body that ensures

10 formation and implementation of state policy in the field of accounting, and submits it to the Center for Collection of Financial Reporting, operational management of which is carried out by the NCSPFM (hereinafter – Center for Collection of Financial Reporting), taking into account the requirements of normative legal acts of the NCSPFM. In such a case, disclosure of financial statements is carried out in accordance with paragraph 20 of this Regulation. The electronic file with financial statements in XBRL format must also contain: audit report submitted together with annual financial statements / annual consolidated (sub-consolidated) financial statements (in the event of preparation of consolidated financial statements); interim financial statements review report / interim consolidated financial statements review report (in the event of preparation of consolidated financial statements), in cases provided for by law and normative legal acts of the Commission. The audit report on annual financial statements (annual consolidated financial statements) and the review report on interim financial statements (interim consolidated financial statements) must comply with International Standards on Quality Management (Quality Management), Auditing, Review, Other Assurance Services and Related Services, the Law of Ukraine "On Audit of Financial Reporting and Audit Activity" and the Requirements for Information Regarding Audit or Review of Financial Reporting of Participants of Capital Markets and Organized Commodity Markets, oversight of which is carried out by the National Commission for Securities and Stock Market, approved by the Decision of the National Commission for Securities and Stock Market dated July 22, 2021 No. 555, registered in the Ministry of Justice of Ukraine on September 07, 2021 under No. 1176/36798. For the preparation of the audit report on annual financial statements (annual consolidated financial statements) and the review report on interim financial statements (interim consolidated financial statements), the ARA must use the services of audit activity subjects registered in the section "Audit Activity Subjects Who Have the Right to Conduct Mandatory Audit of Financial Reporting" or the section "Audit Activity Subjects Who Have the Right to Conduct Mandatory Audit of Financial Reporting of Enterprises of Public Interest" of the Register of Auditors and Audit Activity Subjects. Audit activity subjects must be registered in the corresponding section of the Register of Auditors and Audit Activity Subjects, including, during the period of conducting audit and review of financial statements. 24. The ARA has the right to provide additional information necessary for full and comprehensive disclosure of information. The ARA has the right to additionally place in the database of the person who publishes regulated information and on its own website notifications about significant events (other than those provided for by this Regulation) that may be material to stakeholders or may affect the financial and economic state of the ARA. Notifications about significant events are disclosed in the form according to Appendix 5. 25. Foreign rating agencies

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