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Dmitry Pashkovsky Gazprom biography. Opening Center. The mechanism of regulation of information and telecommunication systems in the banking sector

Dmitry Pashkovsky Gazprom biography.  Opening Center.  The mechanism of regulation of information and telecommunication systems in the banking sector

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Pashkovsky Dmitry Alexandrovich. Regulation of information and telecommunications risks in the operational risk management system of credit institutions: Cand. ... cand. economy Sciences: 08.00.10: St. Petersburg, 2002 172 p. RSL OD, 61:02-8/1823-3

Introduction

Chapter 1. Banking risks, the role and place of the risk of using information and telecommunication systems in credit organizations RF 10

1.1. The concept and essence of risk, risk as a scientific category 9

1.2. Classification of risks in credit institutions of the Russian Federation 23

1.3. The risk of information and telecommunication systems in credit institutions as an integral part of operational risk.. 33

Chapter 2. Risks of using information and telecommunication systems in credit institutions of the Russian Federation: methods of their regulation 54

2.1. Identification of risks of using information and telecommunication systems in credit institutions 54

2.2. Risk assessment of the use of information and telecommunication systems 77

2.3. Regulation of risk, use of information and telecommunication systems of credit institutions 91

Chapter 3. The mechanism for regulating the risk of using information and telecommunication systems in credit institutions of the Russian Federation 101

3.1. The mechanism of regulation of information and telecommunication systems in the banking sector 101

3.2. Methodology for managing risks associated with the use of information and telecommunication systems by credit institutions 116

Conclusion 142

List of references 152

Annex 1. Crimes in the field of information systems 164

Application2. Centralization of data processing in the Central and Eastern Europe 169

Introduction to work

Observed in last years the rapid development of scientific and technological progress in the field of computer and telecommunication systems poses new development challenges for credit institutions information technologies ensuring their reliability and safety. This is due, first of all, to the desire of credit institutions to meet the needs of customers arising from the development of their business, in particular, crossing national borders and requiring a wide range of banking operations using information systems. Carrying out transactions using computer technology allows credit institutions to create the most favorable conditions for attracting new customers and maintaining competitive advantages for an existing customer base. The development of information systems allows credit institutions to conduct operations both in the interests of the bank itself and customers.

Currently, credit institutions of economically developed countries carry out a wide range of banking operations using information technology. The resulting operational risk is one of the new problems faced by the banking system not only of the Russian Federation, but also of developed countries. In today's financial markets, operational risk management is becoming an important element of reliability.

Regulation of the risk of using information and telecommunication systems is becoming one of the most important factors in ensuring the stability of the banking system of the Russian Federation. The main goal of regulating the risk of using information and telecommunication systems is to minimize its negative impact on the performance of a credit institution. At present

At the same time, the development of systems for assessing and monitoring operational risk is at an early stage, which does not allow the supervisory authorities to approve provisions obliging them to comply with specific assessment methods or quantitative limits on the level of risk. Credit institutions of the Russian Federation are only just beginning to apply the tools for managing this risk, which make it possible to build an operational risk management process depending on the strategy adopted by the credit institution.

In economically and industrially developed countries, the theory and practice of determining, maintaining and managing operational risk, regulation by regulatory authorities has a relatively young history. In our country, operational risk management tools have not yet been developed. However, there are recommendations of the Basel Committee on Banking Supervision, which summarize the experience of international banking practice in identifying, managing and controlling operational risk.

The works of prominent economists and banking specialists are devoted to the study of aspects of banking operational risk: Antipova ON .; Gerashchenko V.V., Kotelkina S.V., Krasavina L.N., Lavrushina O.I., Piskulova D.Yu., Rose P.S., Savinskaya N.A., Sevruk V.T., Simanovsky A.Yu., Sokolinskaya M.E., Koha T., Sinki J.F., Tosunyana G.A. and others. At the same time, a comprehensive study of the problems of identification, analysis and regulation of the risk of using information and telecommunication systems in credit institutions, its role in ensuring the stability of the banking system in the conditions of the Russian Federation is still missing.

All of the above indicates the need for theoretical understanding economic essence the risk of using information and telecommunication systems in credit institutions and the factors determining it; generalizations of the existing practical experience and development of methodological recommendations for management and control

5 of this type of risk and determines the relevance of the chosen topic of the dissertation research.

Purpose and objectives of the study.

The purpose of the study is to develop theoretical, methodological and applied aspects of management, identification, assessment of information and telecommunications risks, as well as to develop a methodology for organizing control over the state of this risk at the level of a credit institution.

The implementation of the goals set involves the solution of the following main tasks:

to explore the economic essence of risk, the relationship with related categories ("danger", "safety"), to identify the fundamental importance of security as a goal of risk management from the standpoint of systemic and regulatory approaches;

study the practice of ensuring the security of information and telecommunication systems of credit institutions and determine the directions of its possible application in the Russian Federation;

explore methodological approaches to the identification, definition and control of operational risk, identify shortcomings and give recommendations for further improvement;

determine the main directions of operational risk regulation by the Bank of Russia;

to substantiate the need for regulation of operational risk by the Bank of Russia in order to implement the tasks of maintaining the stability of the banking system;

conduct a detailed analysis of methods and tools for managing information and telecommunications risk in relation to the activities of a credit institution and regulatory authorities, consider their features in the conditions of the Russian Federation;

develop a methodology for organizing control over the state of risk of information and telecommunication systems in a credit institution.

Object and subject of research.

The object of the study is the two-tier banking system of Russia, including credit institutions, as well as the Central Bank of the Russian Federation.

The subject of the study is the economic and organizational relations that arise in the process of regulating the risk of using information and telecommunication systems by Russian credit institutions.

Methodological basis of the study.

The methodological basis of the research is the works of domestic and foreign economists devoted to the theory and practice of banking, as well as general economic problems. The study used monographic and statistical material, individual developments of international financial organizations (including the Basel Committee on Banking Supervision and Regulation), periodicals, legislative acts RF and regulatory documents of the Bank of Russia.

The study is based on the dialectical method, which involves the study of economic phenomena in their constant development and interrelation. Such research methods as comparative, logical and system analysis, comparison, generalization, synthesis and other methods of cognizing the essence of phenomena are also used.

Scientific novelty.

Scientific novelty is determined by the development of theoretical and methodological aspects of identification, assessment and regulation of information and telecommunications risks and methodological approaches to

7 control over this risk at the level of a credit institution and the Bank of Russia, which is expressed in the following most significant results:

systematized and developed theoretical approaches to the problem
regulation of the risk of using information and

telecommunication systems in the system of ensuring the stability of credit institutions;

formulated methodological principles for identifying, assessing and controlling information and telecommunications risks in credit institutions;

a mechanism for regulating information and telecommunications risks by the Central Bank of the Russian Federation was proposed in order to pursue a policy of effective supervision of banking activities, its tools and procedures were considered;

a methodology was developed for organizing control over the state of risk of using information and telecommunication systems at the level of a credit institution.

The dissertation also contains other new scientific results that characterize the personal contribution of the dissertator to the study of the problem.

Theoretical and practical significance.

The theoretical significance lies in the development of theoretical

ideas about the essence of information and telecommunications risks and the methodology for their regulation. The theoretical provisions formulated in the dissertation concerning the management and control of information and telecommunication risks have been brought to the level of working methods.

The practical significance of the work is expressed in the fact that the formulated methodological approaches to identification, analysis, and

8 information and telecommunications risk management can be used in the development and improvement of operational risk management systems in credit institutions. The practical significance of the work is due to the possibility of its use in the process of teaching the courses "Banking", "Banking regulation".

The implementation of the basic provisions, conclusions and proposals will contribute to the effective performance by the Central Bank of the Russian Federation of its functions in the field of banking supervision, rational control over the state of operational risk on the part of credit institutions, as well as generally increasing the efficiency of the activities of credit institutions and the banking system of the Russian Federation.

Approbation of work.

The main provisions of the dissertation research were published in brochures and articles with a total volume of 2.6 printed sheets, in addition, they were reported at the III Interuniversity Conference of Postgraduates and Doctoral Students of the St. Petersburg State University of Engineering and Economics.

Based on the materials of the dissertation research, the author developed Guidelines for managing risks associated with the use of information and telecommunication systems in the activities of credit institutions, which are used in the activities of a number of credit institutions in St. Petersburg, which is confirmed by relevant certificates.

Separate theoretical and practical provisions of the work are used in the educational process of the department "Finance and Taxes" of St. Petersburg State Institute of Economics and Economics, when reading the course "Banking", as well as in the educational process of the St. Petersburg Banking School.

The concept and essence of risk, risk as a scientific category

Despite the common use of the term "risk" in everyday life and science, there is still no universal definition, which does not allow studying phenomena or processes without highlighting the subject of research. This paragraph attempts to systematize the existing interpretations of risk in credit institutions, indicate the relationship with related categories and systematize data for risk classification.

The origin of the term "risk" is currently difficult to determine, in Western Europe it begins to be found in medieval sources, mainly related to navigation. The New Latin "risicum" came into use from the end of the 15th century, while appearing in the literature later: in explanatory dictionaries, examples in the field of risk refer to the middle of the 16th century in England. In modern terminology, the interpretation will sound like the probability of damage, and the understanding of the problem of risk - as finding a way to avoid mistakes when making decisions that involve the genesis of damage. IN this case the concept of "risk" is considered as the possibility of an undesirable event and / or a quantitative measure of such an event, is predominant in science. Risk is calculated by multiplying the probability of an event by the damage. This approach is followed by the majority of domestic specialists in the analysis of natural and man-made risk.

At the same time, the realization that risk is a measure of danger is the most important step in solving the problem of managing a situation in which there are potential factors that can adversely affect a person, society and nature. The American economist F. Knight, for the first time in 1921, proposed to single out the concepts of "uncertainty" and "risk", pointing to the measurability of risk and interpreted it as "measurable uncertainty". The degree of uncertainty, or the likelihood of some adverse event occurring, can be quantified, as opposed to uncertainty itself (or "unmeasurable uncertainty"), which implies the impossibility of measuring future events.

One of the important aspects of the rationalistic tradition of risk definition is related to the problem of the relationship between the objective and subjective aspects of risk. At the same time, it is necessary to distinguish the already classical measure of the objective possibility of the occurrence of any events - probability from the more general, than probability, measure of danger - risk, which has been formed in recent decades. Risk combines the probability of an unfavorable event and the extent of that event (loss, damage, loss). These two measures interconnectedly exist in conditions of uncertainty, in conditions of danger, which involves building a combination of elementary measures that are adequate to the current situation, as well as assessing the level of danger and making decisions on the necessary actions (the latter refers to risk management).

This interpretation of risk is supported by logically consistent judgments about danger. In this case, the following options are possible.

First situation. The probability of a possible event is very high, but the damage associated with this event is zero (or infinitely small). In this situation, for example, the credit institution is not endangered (the risk is zero).

Second situation. The damage from a possible event is great, but the probability of its occurrence is zero. There is no danger (risk is zero).

Third situation. The probability of an event and the damage from it are equal to zero. The situation is characterized as a certain absence of danger (absolute safety).

Risk is one of the most important categories reflecting the degree of danger of situations in which there are potential factors that can adversely affect a person, society and nature. "Risk" in modern science and culture - this is the same broad and general category as "meaning", "value", "justice", etc.

The concept of "risk" is used in many social and natural sciences. Each of them has its own subject, its own focus in the study of risk and uses its own methods for this. This situation allows us to single out the psychological, socio-psychological, economic, legal and other aspects of the “risk” phenomenon. The specificity of the development of modern scientific knowledge makes it not only possible, but also necessary to conduct a socio-philosophical study of risk, which can be considered as a prerequisite for the creation of a general theory of risk.

The logic of such an analysis has several interrelated levels that allow you to detail the problem of risk in different aspects.

First of all, it is necessary to identify the essence, internal inconsistency, features, elements and properties that make up the integrity of risk as a complex and multifaceted phenomenon inherent in the activity as a whole.

Identification of risks of using information and telecommunication systems in credit institutions

Since the formation of the banking system in the Russian Federation and the beginning of operations with funds, operational risk has become an integral part of banking. So far, issues of operational risks (including the risk of using information and telecommunication systems) have not been given due attention.

Due to the poor development of risk management theory, and, as a result, the practically non-existent integral system of banking risk analysis, this chapter summarizes the existing international experience. It should be noted that the most successful attempt to solve the problem of creating an integrated system of banking risk analysis belongs to the Basel Committee, which issued relevant recommendations for assessing banking risks.

Operational risks for Russian credit institutions are caused not only by changes in banking operations, but also by information technologies used by banks, which affects the volume of risk.

It should be noted that Information Systems credit institutions are subject to various influences leading to a decrease in information security credit institutions, and, as a result, to certain losses in their activities. Risk in this context (in relation to the use of information and telecommunication systems) should be understood as real or potential operations that lead to the acquisition, theft, distortion, alteration or destruction of information in the information system, as well as direct material losses due to the impact on material resources.

The risks of using information and telecommunication systems of credit institutions (an integral part of the banking system of the Russian Federation) may be the following factors:

Illegal collection and use of information from credit institutions;

Violations of information processing technology;

Introduction into hardware and software products of components that implement functions that are not provided for by the documentation for these products;

Development and distribution of programs that disrupt the normal functioning of information and information and telecommunication systems, including information security systems;

Destruction, damage, electronic suppression or destruction of means and systems of information processing, telecommunications and communications;

Impact on password-key protection systems for automated systems for processing and transmitting information;

Compromise of keys and means of cryptographic information protection;

Leakage of information through technical channels;

Implementation electronic devices to intercept information technical means processing, storage and transmission of information through communication channels, as well as to the office premises of public authorities, enterprises, institutions and organizations, regardless of the form of ownership;

Destruction, damage, destruction or theft of machine and other storage media;

Interception of information in data networks and communication lines, decryption of this information and imposition of false information; - the use of certified domestic and foreign information technologies, information security tools, informatization tools, telecommunications and communications in the creation and development of the Russian information infrastructure;

Unauthorized access to information held by banks and databases of credit institutions;

Risk sources of information and telecommunication systems in credit institutions can be divided into external and internal, taking into account globalization financial systems. TO external sources include: the activities of competing credit institutions, organized criminal communities, as well as information structures directed against the interests of the credit institution in the information sphere; the desire of a number of international credit organizations to dominate and infringe on the interests of other credit organizations in the global information space, to oust Russian credit organizations from the external and internal information markets; aggravation of international competition for the possession of information systems, technologies, resources; activities of international terrorist organizations; increasing the technological gap between the leading powers of the world and building up their capabilities to counteract the creation of competitive Russian information technologies and systems.

The mechanism of regulation of information and telecommunication systems in the banking sector

In the previous Chapters, the theoretical and practical features of identifying, assessing and managing the risks of using information and telecommunication systems were considered in detail.

The purpose of this Chapter is to develop a methodology for controlling the risk of using information and telecommunication systems at the level of a credit institution. In the course of the study, we will proceed from the previously obtained conclusions regarding the features of the identification and management of these rices, as well as the principles of the methodological approach to the problems under consideration in Russia.

Regulating the risk of using information and telecommunications systems, which is also associated with the functioning of banking systems for electronic processing and transmission of data, is of priority importance in the context of the globalization of the use of information and telecommunications systems in banking.

Due to the fact that this risk is extremely difficult to quantify and predict, a decisive aspect in management is the development and adequate application of procedures internal control.

This chapter summarizes the existing international experience, as well as domestic developments in this area. The most successful attempt to create a system for identifying, analyzing and managing banking risks, according to the author, belongs to the Basel Committee, which issued relevant recommendations for assessing banking risks. Methodological recommendations of the Basel Committee are considered as not mandatory for all credit institutions, i.е. banks are under no obligation to bring their risk control procedures in line with this methodology, while new editions of these materials are published regularly. So, for example, in the US, the recommendations of the Office of the Control of monetary circulation are also not binding, however, it is assumed that credit institutions are prepared in advance and know how the inspectors will form their conclusions during inspections. This position exists in countries with a long institutional history, and may be justified for some other countries, but, according to the author of the dissertation, it is unsuitable for the conditions of the Russian Federation, which is still at the stage of formation of healthy market forces.

Due to the fact that a universal risk indicator as a certain measurable value has not been developed in the materials of the Basel Committee or the Bank of Russia (risk assessment is not expressed in monetary terms), the assessment is made according to qualitative indicators, or relative estimates of risk exposure as a probabilistic value. The Basel Committee proceeds from the fact that banking risks should be assessed in terms of their significance for a credit institution, i.e. in fact, when summarizing the results of inspections, controlling and supervisory authorities should be in the role of experts, which is unacceptable at the present time for the conditions of the Russian Federation, where the lack of transparency of economic entities is still significant, as well as a low legal culture. In the case of operational risk, there is a situation where there are no regulatory documents of the Bank of Russia regulating the procedure for identifying, analyzing and managing risk. It is necessary to establish control over the procedure for assessing operational risk, which will allow for active and effective banking supervision, concentrating; firstly, on the credit institutions themselves, secondly, on systemic risks, including the banking system and the macroeconomic conditions of its functioning; thirdly, on those areas of banking activity that pose the greatest risk to the system as a whole. In the case of risk assessment of information and telecommunication systems, control is necessary with risk assessment in those areas that are associated with the possibility of an unacceptable level of risk for the banking system. In relation to activities that turn out to be particularly risky, direct influence on credit institutions is necessary through measures of influence (preventive or compulsory), i.e. implementation of regulatory policy. In cases where an individual credit institution does not properly manage risks, it is necessary to apply measures to influence the bank's management to adjust its activities.

According to the ideology of the Basel Committee, one of critical tasks banking supervision consists in the formation of expert opinions on the availability of adequate controls and risk management systems in the audited bank based on the analysis of banking operations, up to individual entries. For those banks or areas of activity that are the most heterogeneous and complex, supervision should focus on the risk management systems and methods used by the management of credit institutions. In the interpretation of the Basel Committee, any reliable risk management system should be based on such fundamental concepts as: identification, assessment, management and monitoring.

These conclusions are confirmed in practice by the results of activities in this area of ​​a number of credit institutions in St. Petersburg. 3.2. Methodology for managing risks associated with the use of information and telecommunication systems by credit institutions.

In accordance with the theory of management of a credit institution, the main form of management is management - a system for making and implementing decisions aimed at achieving the optimal, best possible, option for using material, labor and financial resources.

One of the functions of management in a credit institution is to monitor the compliance of the results actually achieved with the planned ones and make the necessary adjustments. The internal control service of a credit institution should be focused on limiting the risks assumed and on ensuring the procedure for conducting operations, provided that the credit institution achieves business guidelines, complies with the requirements of banking legislation, Bank of Russia regulations, generally accepted standards and business rules.

The Internal Control Service is the main component of the organization of control over the level of risk arising in the activities of a credit institution when using information and telecommunication systems. The purpose of the Internal Control Service for the State of Information and Telecommunication Systems is to increase the efficiency of the credit institution's activities in the field of identification, assessment and control of the risk arising from the use of these systems.

The method of internal control over the state of risk of using information and telecommunication systems, subject to the procedure laid down in them, allows achieving the above goal by: monitoring and ensuring that the departments and specialists of the credit institution comply with the requirements and principles of: a) the current legislation in the field of information protection; b) internal bank documents regulating the procedures and powers in the field of identification, assessment and risk management; c) standards professional activity; control over the reliability, accuracy and adequacy of identification, assessment and management of risks arising from the use of information and telecommunication systems and operational risk; ensuring the minimization of the negative impact of operational risk factors on the performance of a credit institution; the professionalism of the employees of the internal control (audit) service and the completeness of the control methodology; making timely and effective decisions aimed at eliminating the identified shortcomings and violations in the bank's activities.

Suggested guidelines are intended to highlight problems and ensure that the heads of credit institutions, as senior managers, understand the need to manage risks arising from the use of information systems, as well as to develop and implement their own security measures and procedures. 3.2.1. The role of the management of a credit institution in managing the security of information and telecommunication systems. 3.2.1.1. Management control.

Responsibility for the security of information systems against threats various types, is essentially related to the established management process. The management of the bank is responsible for the security of information systems in each particular credit institution.

Ensuring the confidentiality, integrity and availability of data requires the development of appropriate procedures and rules for monitoring their implementation. The management of the credit institution must establish in writing clear rules for the security policy and ensure their implementation and support in the implementation process. First of all, the governing body of the credit institution must establish adequate procedures and requirements regarding security to minimize the likelihood of negative factors. Preventive measures must find expression in a carefully chosen location for the computer center.

For the work and establishment of information security policy rules, it is recommended that the top management of the credit institution establish an appropriate committee. The work of the committee should be managed by a head of appropriate qualification, a member of the Board of Directors.

For a credit institution to carry out successful activities, it needs public trust, which is expressed, among other things, in a significant amount of information, characterized by a high degree of confidentiality provided by customers, while disclosure or loss of information may lead to loss of business reputation and trust. The area of ​​confidentiality should be determined in advance: what information and in what area is subject (regardless of the form of presentation) to an absolute ban on publication (temporary or partial). In this regard, it is necessary to have precise rules for classifying information (data transmission).

The use of information systems in financial institutions may, in some circumstances, require the cooperation of external experts. Establishing the forms, methods and scope of such cooperation lies within the competence of the management of the credit institution, as well as the admission of external experts to the work of the committee that determines the security policy of information systems. 3.2.1.2. Information systems security policy.

The goal of information systems security is to ensure the confidentiality, integrity and availability of resources that allow the processing, transmission and storage of system data to be guaranteed in terms of reliability, reliability and authorized use. Therefore, an appropriate security policy should be established and implemented. The organization's systems security policy regarding organizational planning and operation rules should be of the highest rank and be available to all those responsible for information security.

The security policy should at least contain the following elements: definition of the information system, the goals of the activity, the value of the information stored in the system; a provision that determines the intentions and will of the management of a credit institution to keep information safe; definition of information security and issues of access to information; identification of existing threats, the likely scope of their occurrence; calculation of costs for ensuring guaranteed protection; => definition of policy rules and standards regarding the requirements: harmonization with current legislation and generally accepted terms of contracts, regarding the security of systems; the necessary level of education required to ensure the security of information; testing and prevention (prevention) of viruses; ensuring the continuity of planning and approval of changes, the adoption and use of new information technologies; production and storage of spare and archival copies; => definition of general and private areas of responsibility for all employees for ensuring the safety of information; definition of rules for reporting on all discovered or possible threats regarding the possibility of abuse, the procedure for their elimination and prevention of recurrence. In addition, analytical work should be carried out to identify weaknesses in ensuring the safety of systems, rules for the implementation of critical schemes in emergency situations, catastrophes or natural disasters (emergency plans).

To ensure the security of information processing operations, it is necessary to develop appropriate and properly documented procedures and areas of responsibility in the credit institution. Such procedures should be set out in a clear and understandable language for ordinary users and should relate to: all software operating in a credit institution; rules for creating, testing and operating new software; rules and methods for proper storage of the collected data, archiving and access to them; what to do if errors are found; use of auxiliary (backup) systems in case of technical problems; procedures in case of failures (recovery process).

Of the mandatory procedures that credit institutions are required to perform is the separation of functions, namely: the functions of system administration, network management, data entry, Maintenance computers, system repair and development, should be separated from the administration of computer systems security, as well as the audit of information systems.

The separation and independence of testing from operational functions prevents unexpected and undesirable changes in the working version of the system being used. Testing of a new system and the operation of the current version should be carried out on different computers, in different directories, etc. The system under test should be removed from the operating version (and in the physical sense too). Used in permanent job the software must have an individual, own, frequently changed access password.

Written rules should define the course of action in case of any incidents: system failures, data loss, identification of erroneous and / or incomplete operational data, violation of confidentiality of information. In each of these cases, the identification and analysis of the causes of emergency situations should be ensured. The procedures should pay attention to the rules for analyzing the weaknesses of a functioning system, planning means for restoration, testing and operation.

The procedures should be aimed at preventing and revealing the causes at the stage of occurrence of potential threats affecting the performance of banking operations. The procedures should ensure that it is impossible to perform operations inconsistent with existing legislation, as well as without prior security controls. The possibility of using alternative computer, communication networks in emergency cases, consistent with the procedures for detecting errors and plans for post-accident restoration of the functioning of a system damaged as a result of incidents, should be indicated. Organizational procedures should be closely related to the security policy of information systems against possible losses caused by abuse of employees, destruction of programs, computer equipment, as well as expenses for the restoration of lost data.

The policy of using external organizations to ensure the operation of information systems, as well as Team work with them (suppliers of hardware, software, data processing facilities) can potentially lead to data loss. It is necessary to identify the area of ​​risk, carry out prevention, as well as develop a scenario (risk modeling) in the most unfavorable combination that cannot be excluded. The management of a credit institution should carefully consider the basic requirements for processing strictly confidential information (such a risk must be minimized by system coding, encryption, etc.).

Security policy rules should take into account the above-mentioned internal and external conditions, as well as protect against incorrect selection of software, prevent the installation of technically incompatible programs that allow unauthorized access and damage to information (for example, network viruses, Trojan horses, logic bombs) ). In addition, you should carefully consider and provide for the compatibility of your own software with the supplied software for the safe functioning of information systems.

When developing policy rules, a classification of information security levels should be carried out, for the purposes of own security, as well as establishing rules for interaction between users. Security policy rules should be periodically reviewed and updated in accordance with changes in organizational conditions. 3.2.1.3. Planning the scale of information systems.

When planning the development or development of an information system, attention should be paid to the issue of future user needs, in this regard, it is necessary to provide for the possibility of upgrading information equipment. In order to eliminate restrictions and potential threats associated with the functional inability of the information system to modernize and develop, it is recommended to predict future needs for equipment, as well as information services, by monitoring current trends in the development of new technologies.

Forecasts and plans should take into account marketing strategy credit institution (development of new products), competitiveness in the financial market (further integration of the Russian Federation into international economy), risk analysis, modernization of existing instructions and controlling rules, implementation of requirements set by external bodies (for example, the Bank of Russia). Particular attention must be paid to the appropriate selection of hardware, software and their configurability. Important parameters of the system are: compliance with accepted standards, performance, speed, ability to function in cases of detection of errors and post-accident recovery procedures (speed of repair). Planned changes in systems require an assessment of their impact on existing accounting, documentation operations, the ability to identify changes and control them.

Selection of new technical solutions, procedure for acceptance and testing before acceptance final decision on procurement, must be consistent with the existing procedures established in the credit institution. Attention should be paid to the fact that the launch of new systems does not stop the work of previously adopted ones - the uninterrupted functioning of the credit institution is ensured. Appropriate training for users needs to be planned.

When planning the scale of an information system, one should take into account the need to maintain security in the event of an equipment failure or force majeure (fire, flood, etc.), as well as to perform mandatory data archiving. In this connection, it is necessary to establish: the frequency and area of ​​information copying (backup) on external media, for recovery purposes in case of failures; keeping a log in the system (log); frequency and method of archiving information. An insufficiently thought-out choice of inefficient technical solutions, in the event of an increase in the scale of processed information, can lead to significant costs associated with the need for replacement. It is especially undesirable to have a system that is not generally accepted, since there is a potential possibility of a legal act regulating the use of only a certain standard in an information system.

Contracts concluded with external suppliers of equipment, software and information services should specifically stipulate the rights and obligations of the parties in terms of liability, including material liability.

3.2.2.2. Infrastructure for ensuring control and management of information security.

3.2.2.2.1. Analysis of existing threats and security methods.

Implementation is provided through the tools contained in operating systems(network and / or computer), special software, the use of ready-made technical solutions provided for equipment, audit, configuration management, organizational measures taken for preventive purposes in cases of violation of security in emergency and force majeure circumstances.

In the process of security planning, the value of information system resources should be determined, their classification should be carried out, inventory rules, employees and their area of ​​​​responsibility should be established, with differentiation of access to modification of the security system, factors affecting the likelihood of threats should be taken into account. Threats must be identified in advance: the type of risk has been determined, its analysis has been carried out, risk management procedures have been established through the selection, testing and application of new or already adopted security mechanisms - minimizing the risk to a level acceptable to the credit institution.

The choice of a method for ensuring the security of information systems should be adequate to their type, type of risk and the results of the analysis of the payback of the selected tools carried out by the credit institution, for example: erection of a fire wall; use of cryptography; control of premises; user verification (setting single and multi-part passwords, often changed); use of multi-level access control and own information resources; functional separation of the system (classification of users to determine the limit of the amount of money within which transactions can be carried out, etc.). Regardless of the provision used in information systems, it is necessary to create physical security (backup center, archive on optical disks), as well as organizational measures (separation of the software development process into separate phases: design, testing, simulation, experimental and industrial operation).

It is mandatory to use backup copies (backup), as well as current registration (log), which will allow you to restore resources in case of data loss in the information system.

A set of backup copies (backup) should be stored separately, at an appropriate distance from the information system, with reliable physical security. Minimum set copies should provide system recovery after a disaster, depending on the type of system used. A rule should be established, depending on the frequency of changes and the value of the data, to copy information for the last 14 days, at least once in the last three business days. These data must be regularly checked for the possibility of their use (state assessment) in cases of failures in the systems.

Logs created in the system should contain a list of all necessary factors: time (from the moment the work started to completion); detected errors; corrections made; confirmation of receipt of the necessary data. In addition, it should be possible to print the data.

It is necessary to establish an understanding of the fact that both the owner of the property and the user of the system are responsible for the security of information systems in each case. The definition of liability should be sufficiently precise and personalized. There should be a division of responsibility for the security of information systems from the perspective official duties and related areas of responsibility. Delegation of authority does not remove responsibility for the security of information systems from the owner. At the level of the management of a credit institution, the following requirements should be established: authorization of users in terms of achieving the goals and objectives of the credit institution (goals and operating conditions); technical approval (installation rules, networking, interaction between users). 3.2.2.2.2. Security of system documentation.

Information systems documentation may include, for example, a description of work processes, specifications software products, procedures, data structures, authorization processes, etc. It should be provided: a list of installed software for the purposes of accounting; list of programs with written confirmation of admission to industrial operation (each new program, or modified); description of the purpose of each program, the order of its functioning (rules for calculations, accounting, control and printing of data), as well as its use during data processing; rules for maintaining data safety, creating backup copies; methods to ensure proper handling of programs; rules for accounting for data processing processes.

A credit institution must have a developed and written strategy for access to information and information systems. All software must contain a precise definition of procedures and access rules that define the access rights of individual users/groups, methods for authorizing and updating the list of users, as well as passwords.

Documentation must be stored in a safe in compliance with the rule: documentation generated by the system must be located separately from the place where the data was received. In each case, it is necessary to establish the required level of security and differentiation of access rights: compiling a list of authorized persons, simultaneously with a list of the access level (full or limited), implemented through the use of appropriate software applications.

If documentation is available to external users (in connection with the services offered by the credit institution), careful selection of such materials is necessary. Each replacement of data and software must include security measures to prevent data loss, uncontrolled modifications, unauthorized access, and loss of control. The use of software must follow from formalized rules. Their due diligence requirements limit legal and organizational risk: data loss, uncontrolled modifications, unauthorized access. Requirements should be proportional to the confidentiality (importance) of banking information. Copyright protection must be provided. The exchange of information with other users can only take place subject to copyright in the field of information exchange.

In the event of a violation of the confidentiality, integrity and availability of information, a credit institution is obliged to implement emergency action plans that must take into account banking specifics (type and form, for example, electronic money transfer, foreign exchange transactions, letters of credit, etc.) and the cost of transactions. This documentation must be stored in specially allocated premises and constantly updated in accordance with ongoing changes in the information systems of the credit institution.

Procedures for creating, storing and accessing up-to-date access passwords should be established.

3.2.2.2.3. Hardware, software and network control

Data processing in a credit institution must take place in accordance with accepted procedures and compliance with the rule of division of responsibility. Activities to ensure the smooth operation of the system and the implementation of repair work, in each case should consist of formalized procedures, and their implementation should be carried out under close supervision. Repair work can only be carried out by specially designated personnel. In each case, accurate documentation of the repair work being carried out must be drawn up, as well as a report sent to the management of the credit institution.

Control over network resources aims to minimize threats to the security of information available through the network. Controls established to maintain the confidentiality and integrity of data must be effective and prevent information from being leaked or changed illegally. Activities related to network and computer control should be carefully coordinated in order to optimize services, as well as ensure an appropriate level of security within the information infrastructure of a credit institution. The handling of media of any kind (discs, tapes, floppy disks, CD-ROMs, etc.) must be such as to prevent possible damage to equipment and system failures. Control over single storage media (discs, tapes, floppy disks, CD-ROMs, etc.) and in particular: identification of such media, storage and transfer of information to them, place and method of secure storage, method and form of authorization of changes and use data, determining the procedure for eliminating unnecessary data - should be carried out with the security procedures adopted in the credit institution. The ordering of all media, the establishment of a formalized list of authorized users, ensuring the completeness of incoming data, an accurate record of all copies of data made by authorized users, the application of validation of all transmitted data, the systematic review and authorization of lists of users of data and services is intended to protect information from unauthorized access, unauthorized and improper use.

To properly ensure the security of interbank transactions (transactions, operations), it is necessary to cooperate with other credit institutions in the field of exchanging experience and proposals arising from the analysis of identified cases of fraud. The exchange of information should be limited so that neither banking nor official secrets available in a credit institution are violated. Mutual agreements should define the scope of information to be transferred.

The management of the credit institution is responsible for the transmitted information: its confirmation, enforcement technical standards in transmission and identification standards. Liability should extend not only to the possibility of loss of data, but also to the lender's exposure to unauthorized access by third parties to information during transmission or transmission to external funds processing.

Ensuring the confidentiality of data should be carried out by the credit institution itself: the choice of reliable means of transmission (for example, couriers), the use of cryptographic means, the physical protection of information carriers (for example, the use of various kinds of closed means), the transfer of data against signature, etc. Information subject to risk of loss, unauthorized access to it (reasons that can lead a credit institution to serious expenses and material and moral losses, for example, loss of business reputation of a reliable partner), should, to the extent possible, be transmitted through several communication channels and in parts, so that in case unauthorized decryption and attempt to use it was as difficult as possible.

Appropriate selection of telecommunication media should be made in order to minimize risk. E-mail differs from the traditional data transfer rate, as well as the structure of information. When using e-mail, it is necessary to develop a clear policy of the credit institution regarding the status of e-mail, its use, and the development of an effective mechanism for monitoring it. Users when working with e-mail must be guaranteed against unauthorized changes in message channels and the risk of errors (for example, the recipient's address is incorrectly specified). It should be recognized that there are legal restrictions, such as the potential need to document the origin of information and the means of its transmission, which do not protect the lender from the risk of unauthorized use.

Cases of violation of the access rules adopted in the credit institution, identified in the course of the ongoing control, should be brought to the attention of the management.

3.2.2.2.4. Security of information systems, activities of personnel and authorized third parties.

Close attention should be paid to the statistics of a high percentage of internal users violating security rules. Therefore, a very careful selection is recommended, in terms of vocational training and personal qualities, employees involved in positions that give access to special important information. A comprehensive check of the entire package of documents provided by a candidate for a position is required, starting from an identity card and ending with a check for criminal liability. Employment contract or a special agreement must contain a clause on the need to maintain official secrets, as well as the period of validity of such obligations. A potential employee should familiarize himself with the contents of this document already at the stage of hiring. It should be a rule that before joining a job, a newly hired employee confirms in writing in the relevant agreement the fact of exact acquaintance with his rights and obligations in the field of use computer system. A certificate of familiarization with the rules for storing confidential information is also signed. In addition, official secrecy must be established in the field of equipment and information systems, as well as data processing technologies used in a credit institution, including after dismissal, for an appropriate period of time.

To reduce the risk of personnel errors and unauthorized use of equipment and information, a number of measures are required on the part of the management of the credit institution. Leaders labor collective tasks should be divided among individual employees, specifying instructions regarding their implementation, determining the boundaries of authority, obtaining appropriate written evidence, transferring passwords or any other means of access control, keeping records of all activities performed by users of the system and the passwords they used. The risk of inaccurate, incomplete or repeated entry of data must be eliminated by an appropriate control procedure (for example, checking and correcting the correctness of data, control using databases, balancing, transactions carried out, registering a position until clarified and supervising further actions, etc. .). After completion of the work, the storage media (if such is provided technically) must be dismantled and their safety ensured from access by persons not authorized to do so.

The risk is based on the fact that unauthorized persons can find access to the data processing function in user programs, apply procedures for initiating, confirming and registering business transactions and access the data. The risk should be minimized by establishing access controls that guarantee user identification and authentication, recognizing appropriate access rights, and maintaining password confidentiality. During the absence of a permanent user of the computer, access by other unauthorized persons should be impossible. The terminal user must be responsible for all actions performed from his computer. The delegation of authority must be carried out exactly as directed by management and must be documented.

Persons responsible for the security of information systems should not perform those functions that are associated with the work of their maintenance. Access is the responsibility of the person who is responsible for the system. Responsibility for the security of a large network occupying a large area may be assigned to the appropriate group, appointed in accordance with the procedures adopted by the credit institution.

In the case of a preventive inspection of the equipment or its repair, it is necessary to make sure that it does not contain information. The agreement between the credit institution and the organization providing the service should determine the procedures for action in the event of any pre-foreseeable situations, primarily security procedures for possible data loss. In addition, the contract must contain guarantees for the credit institution to receive all information about changes made to computers and their logical functions, as well as the obligation to maintain secrecy by the service organization. A credit institution is obliged to keep records of repair work and stored equipment, containing personal data of the persons who performed it, the dates of the work and the type of malfunction.

3.2.2.2.5. Interaction with clients.

Attention should be paid to a special area of ​​activity of a credit institution that is at risk of data storage security breaches - this is cooperation with bank customers, implemented with the help of computer and telecommunication organizations (for example, a home banking system). Access by third parties to the organization and computer equipment must be tightly controlled and risk analyzed before it occurs. Make access possible after preliminary work by signing a formal document specifically defining the conditions of access. It is necessary to clearly indicate in the contract the problems associated with various kinds of risks, namely: general rules protection and disclosure of information; allowed access control methods (codes, passwords, identifiers); dates and times of access; list of authorized persons (specification); access channels; areas of responsibility of the parties; scope of duties regulated by legal acts, including those related to the need to protect data; the rights of the owner to monitor the access system by third parties; responsibility in the field of installation, as well as maintenance of equipment and software; the right to audit the compliance of contracts; rights in the field of copying and disclosure of information; physical security of information; reporting and supervision of cases of fraud.

The relevant part of the agreement between the client and the credit institution obliges to protect the funds deposited with the credit institution, maintain banking secrecy, receive services, good quality stipulated by the contract and regulatory documents, as well as mutual obligations of the parties.

Monitoring compliance with contractual terms (in particular the analysis of customers who have access to information systems) should be approved as a mandatory procedure in this area.

Clients of a credit institution, before gaining access to a terminal (modem, etc.), must sign a certificate of confidentiality of information.

3.2.2.2.6. User training.

Users should be trained in the knowledge of security procedures and the proper use of equipment and information systems. The scope of the thematic sessions should provide an in-depth knowledge of the procedures for using hardware and software, as well as the procedures adopted in the field of system security, ensuring confidentiality, integrity and availability.

During the training period, users should familiarize themselves with examples of situations that may have an impact on the security of systems, gain knowledge in the field of formal legal procedures for acting in cases of actual (or suspicious nature) threats to the security of the system, as well as the rules for immediately reporting incidents to the management of a credit institution . The procedure for filing service reports applies to all cases of systems operating in a way that is not in accordance with their purpose.

The staff of the credit organization should be trained in the field of preventive measures to avoid viruses in information systems, with an emphasis on learning new media used in the work and carefully monitoring all messages and information that appears on monitor screens. In case of detection of viruses, internal procedures should provide for the termination of use of the system, the isolation of funds that are suspected of having a virus, and, immediately, informing the technical service for computer maintenance and management.

To maintain the security of the system, the institution should develop a formalized disciplinary process for those who do not comply with the procedures and familiarize users with them during the training period.

3.2.2.2.7. Physical security of information systems.

The provision of physical security in a financial institution must be adequate to the scale and type of information systems, as well as the services provided to customers. Significant business organizations, such as multi-branch credit institutions that have a geographically developed network, have their own data processing center, may require the provision of the highest degree of physical and information security.

The level of physical security, as well as fire safety procedures, should be determined in proportion to the cost of the equipment and the magnitude of the potential losses that may occur if the equipment is damaged.

For computer equipment and storage media, security must be ensured by defining a heavily guarded area. The data center must have physical security, as well as against natural disasters (fire, flood, explosion, etc.), and malicious acts. It is recommended that information service centers and the organization systems center be located in physically designated areas to prevent unauthorized persons from entering them. The placement of the information center should ensure the impossibility of wide access by unauthorized persons in the form, namely: a separate entrance, a dedicated part of the building (without access by an unauthorized person), a special, closed room, physical barriers that make it impossible to access computer equipment, etc. .

Attention should be paid to the appropriate level of security of adjacent premises. It is recommended to abandon identifying door plates, signs, information messages etc., as well as indications of telephone numbers in telephone directories, that is, everything that easily allows you to locate the internal and external premises in which data processing takes place. The goal is to limit the dissemination of information among the personnel of the credit institution, not related to the operation of information systems, about the places of processing of information data.

Appropriate equipment of premises with heat and smoke detectors, installation of alarms, fire fighting equipment, emergency exits, etc. is required. Emergency procedures should be developed in writing and periodically reviewed for compliance with threat conditions, and employees trained in fire protection rules . Unsafe and flammable materials should be kept at a safe distance from computer equipment. Flammable materials should be stored in compliance with fire safety regulations. In cases of temporary absence of employees in the premises, windows and doors must be closed and alarm systems turned on.

Control over physical access to the premises of the information center should be regulated by the relevant procedures and parameters of access, specified situations and persons admitted to stay in specially allocated premises. The method of establishing, registering and controlling should be determined: access rights and their updating (for example, exclusion of access for employees dismissed from work); personnel identification; entry and exit times.

A credit institution must have procedures for dealing with persons identified in areas excluded from access by outsiders.

When employees leave the allocated premises, physical security (appropriate type of blocking) and control must be ensured. Support personnel and persons in need of repairs may only have access to the designated information center, if necessary, after obtaining appropriate authorization for their access and under close supervision. responsible persons. Conduct procedures in information center should not allow taking photographs, playing tapes, video cassettes, etc., except by persons authorized and authorized to do so.

Analyzing the provision of confidentiality and availability of data in the data center, one should keep in mind the use of such tools as: printers, scanners and faxes. To protect data from unauthorized copying, it is necessary to create conditions for controlling the use of the above tools.

3.2.3. Internal control and supervision. 3.2.3.3.1. Internal control

The management of the credit institution is responsible for creating a sector within the internal control service responsible for organizing control over the security of information systems. The duties of the internal control service should include: assessment of the level of data protection; assessment of the quality and efficiency of the equipment and software used in the credit institution; risk monitoring and control.

Must be installed special control by the internal control service, if the credit institution has: written rules of security policy and procedure, as well as information systems security management (if they exist, how accurately they are implemented); the list of data presented in the accounting books of what exists on magnetic media; documentation for the electronic data processing system, for compliance with accepted rules; and also, to what extent it is ensured: the correctness of the assessment of assets and liabilities; completeness and reliability of the implementation of current control programs; speed of access to data for operational purposes; the adequacy of the information received by the management of the credit institution; the correctness and urgency of reporting to external agencies; archiving and protection of data in accordance with accepted rules. Inspectors, auditors or specialists should systematically conduct independent testing of the security system and control procedures. The frequency and depth of examination of test parameters is related to the existing field of activity and should be appropriately adapted to the level of risk, assurance and reliability of existing control procedures.

Most of the software products of a credit organization contain control tools, as well as create reports that serve to ensure and protect information. Internal controls should be capable of identifying security weaknesses in the systems used by the firm and instances where there are deviations from incoming control requirements, especially high-risk transactions. The collected data and software must be strictly kept from unauthorized changes. Attention should be paid to the fact that the personnel involved in the decision-making on the security of the entire system are mentally and morally stable, appropriately trained, and duties should be distributed so that the work carried out is not monopolized in terms of current control. for their legitimacy.

The board of a credit institution may recommend to external auditors during the period of analysis financial condition credit institution (or in the form of a separate audit) to assess weaknesses information systems. Planning, preparation and conduct of control by a special sector of the internal control service, as well as recommendations from independent specialists and professional external organizations, which analyzes the proper implementation of standards in the field of data protection, is one of the factors for enhancing the security of information systems.

3.2.3.3.2. Supervisory requirements.

From the point of view of supervisory authorities aimed at ensuring the stability of the banking system, protecting the interests of depositors and creditors (in particular, the safety of funds placed in bank accounts, maintaining bank secrecy, etc.), it is necessary to assess information systems for security, which includes: confidentiality, reliability and availability. Also, the supervisory authorities are interested in: whether the credit institution has and how it implements the existing security policy rules, user identification procedures, unambiguous confirmation and registration of the use of system resources; how and to what extent the established methods are carried out, as well as procedures for ensuring appropriate risk assessment and management. It is also important to evaluate the performance of the sector of the internal control service responsible for the security of information systems. The area of ​​study should also include the ability of the electronic data processing software to reliably implement the statutory provisions of the credit institution, as well as the impact of the development of the bank, the accepted division of competence, user access, etc. on the subject of system security.

In each specific case, a necessary condition for the implementation of supervisory functions is the use of expert data from external auditors.

In the course of inspections of a credit institution carried out by specialists of the Bank of Russia (comprehensive inspections or thematic inspections), an assessment is made regarding the construction of the system, software and control functions. For all questions that arise during the audit, comprehensive information should be provided on the subject of procedures, system architecture, security, as well as a set of parameters contained in software credit institution (for example, established risk limits and valuation methods for transactions, etc.).

The inspection report of a credit institution may include records, protocols, reports of external auditors, illustrating the level of understanding by the credit institution of the problems of ensuring the security, confidentiality, integrity and availability of information systems used.

The presented method of intrabank control over the level of risk of using information and telecommunication systems is the first development in our country in the field of organizing control over the state of information and telecommunication systems at the level of a credit institution. The effectiveness of this model of the organization of control over the state of information and telecommunication systems is confirmed by the use of the approaches proposed by the author in the activities of a number of credit institutions in St. Petersburg, namely: LLC CB "Invest-Ecobank".

The introduction of the proposed model into the practical activities of Russian credit institutions will increase the efficiency of their activities in the field of identification, assessment and control of operational risk, which will affect the overall level of performance and stability of Russian credit institutions.

Conclusion

1. The risk of using information and telecommunication systems is a complex concept that expresses a complex of operations of credit institutions. The rapid development of scientific and technological progress in the field of computer and telecommunication systems poses new challenges for credit institutions in the field of ensuring the reliability and security of the use of information and telecommunication systems.

This is due, first of all, to the desire of credit institutions to meet the needs of customers arising from the development of their business, in particular, crossing national borders and requiring a wide range of banking operations using information systems. Conducting transactions using computer technology allows credit institutions to create the most favorable conditions for attracting new customers and maintain competitive advantages for the existing customer base.

Currently, credit institutions of economically developed countries carry out a wide range of banking operations using new information technologies. The resulting operational risk is a problem faced by the banking system and the Russian Federation. In the context of the globalization of financial markets, operational risk management is becoming an important element of the stability of the banking system of the Russian Federation.

Regulation of the risk of using information and telecommunication systems is one of the most important factors in ensuring the stability of the banking system. The main goal of regulating the risk of using information and telecommunication systems is to minimize its negative impact on the performance of a credit institution. Currently, the development of systems for assessing and monitoring operational risk is at an early stage, which does not give the supervisory authorities the opportunity to approve provisions obliging them to comply with specific assessment methods or quantitative limits on the level of risk. Credit institutions of the Russian Federation are only just beginning to apply the tools for managing this risk, which make it possible to build an operational risk management process depending on the strategy adopted by the credit institution.

Regulatory authorities do not currently exercise control over operational risk as part of banking regulation.

At present, a comprehensive study of the problems of identification, analysis and regulation of the risk of using information and telecommunication systems in credit institutions, its role in ensuring the stability of the banking system in the conditions of the Russian Federation is still missing.

All of the above indicates the relevance and necessity of theoretical understanding of the economic essence of the risk of using information and telecommunication systems in credit institutions and the factors that determine it; summarizing the existing practical experience and developing methodological recommendations for the management and control of this type of risk and determines the relevance of the chosen topic of the dissertation research.

The importance of the concept of the risk of using information and telecommunication systems for the theory and practice of banking is due to the fact that this risk means exposure to operational risk for a credit institution and is its concentrated expression. Knowing this risk makes it possible to:

A credit institution - to assess the level of operational risk to which it is exposed at a certain point in time, but also to manage this type of banking risk;

Supervisory authorities - to assess and control the level of operational risk to which credit institutions and the banking system are exposed, as well as to implement a policy aimed at limiting and controlling intra-bank risks in order to ensure the stability of the banking system.

This paper defines the place of operational risk in the system of banking risks and clarifies its definition as a special type of banking risk. The generally accepted concept of operational risk does not currently exist, however, in the practice of banks, operational risk, on the one hand, includes the risk of possible monetary losses as a result of technical problems, and on the other hand, possible losses in banking operations from the human factor. Thus, the peculiarity of operational risk is that it has the properties of both external and internal banking risks.

2. Global trends in the development of the economy, including the banking sector of the Russian Federation, require a fundamental and multifactorial approach to the issues of determining, controlling and managing the risk of using information and telecommunications systems, and, in turn, the operational risk to which credit institutions and the banking system of Russia are exposed generally. Credit institutions are faced with the task of identifying the most significant factors influencing the risk of using information and telecommunication systems, as well as developing effective ways to regulate its value. The analysis carried out in this paper showed that the main factors affecting the risk of using information and telecommunication systems of credit institutions are: fraud, i.e. illegal use of information with which the system operates for purposes contrary to the interests of the credit institution; making a mistake; risk of failures in the operation of software and hardware of information and telecommunication systems; inefficient planning (the efficiency and quality of banking services currently largely depend on information and telecommunication systems, and therefore any miscalculation in the planning or development of new systems can have serious consequences for a credit institution); inadequate performance of duties.

3. The main objective of managing the risk of using information and telecommunications systems is to minimize bad influence operational risk to which the credit institution is exposed, the results of its activities. Two components should be singled out: 1) creating conditions for credit institutions that promote understanding of the importance and necessity of managing banking operational risk; 2) regulating the risk of using information and telecommunication systems in order to prevent violations of operational risk requirements established by regulatory authorities. The peculiarity of operational risk management is related to the fact that it can bring to the bank not only losses, but also income.

Using risk management tools for the use of information and telecommunications systems, a credit institution can organize the process of managing operational risk. The author of the dissertation research identified five sections of operational risk management: managerial supervision; risk assessment, monitoring; rules and procedures; internal control; supervisory authorities.

Management supervision is the main condition for the effectiveness of risk management in a credit institution and the participation of the top management of the bank. High-quality oversight of operational risk should be carried out by the Board of Directors or a management committee. The role of the Internal Control Service is also important.

The primary responsibility for managing operational risk should lie with the operating units. It should be the responsibility of the heads of the relevant departments to ensure the necessary systems for controlling operational risk. Strengthening control is possible by allocating risk and responsibility, as well as operating losses, to the relevant linear or functional units.

Risk assessment. Many credit institutions are currently only beginning to carry out work on the assessment of operational risk. Few have formalized scoring systems or have actively begun to develop them: the methodologies are experimental in nature, mainly developed on the basis of the analysis of previous mistakes. For credit institutions, it is necessary to measure operational risk and assess the probability of operating loss and its potential size in order to use data to identify units and areas of activity that are most exposed to it. The approach to accounting for risk factors that serve as indicators of the likelihood of an operating loss should be quantified, and qualitative and subjective assessments should be used, expressed in points on a certain scale.

Risk monitoring. In accordance with the regulatory documents of the Bank of Russia, all credit institutions are required to have an Internal Control Service, which must, by virtue of its official duties, - monitor operational risk. The most appropriate approach to monitoring operating losses is to analyze each case, describe its nature and causes of losses, and send the results of the analysis to the top management of the credit institution.

Controlling the risk of using information and telecommunication systems. Various methods can be used to control this risk. The main and most effective means of controlling this risk is the activities of internal control and internal audit services.

Rules and procedures. In the context of the expansion of the risk of using information and telecommunication systems, it is necessary to constantly update and develop adequate rules and control procedures. These rules and procedures should be based on principles common to all types of risk.

Internal control. Most cases of risk in the use of information and telecommunications systems are associated with deficiencies in internal control or inconsistency with existing internal control procedures.

Considering the concept and place of information risk in the system of banking risks, it should be noted that little attention is paid to the problem of the emergence and implementation of this risk. present stage in the works of domestic and foreign economists there is no single approach (position) regarding this issue, in normative documents Bank of Russia there is a certain gap in the field of regulation of this risk arising in the activities of a credit institution.

Risk management tools for the use of information and telecommunication systems are an important factor in interbank financial integration at the national and international levels, as they meet the needs of managing the operational risk of credit institutions in most countries of the world.

4. In market economy credit institutions are simultaneously assigned the role of leading economic agents and the most important channels for influencing macroeconomic processes. Therefore, in all economically developed countries, the regulation of the banking system is a priority. The analysis of the role of control over the risk of using information and telecommunication systems in the system of banking regulation showed that in economically developed countries of the world, the risk of using information and telecommunication systems is a subject of regulation. The main task, from the point of view of banking regulation, is the establishment and limitation of the maximum level of operational risk to which the banking system may be exposed.

In many economically developed countries of the world, operational risk is an object of regulation, which is carried out both in the interests of maintaining the stability of the banking system and in order to prevent losses and bankruptcy of credit institutions, which can undermine confidence in the country's credit system as a whole. Thus, risk management of the use of information and telecommunication systems of credit institutions is an essential factor in the stability of the banking system and an indicator of its effectiveness.

5. Since the formation of the market-type banking system in the Russian Federation and the development of banking competition, operational risk has become an integral part of banking. So far, issues of operational risks (including the risk of using information and telecommunication systems) have not been given due attention.

Due to the poor development of risk management theory, and, as a result, the practically non-existent integral system of banking risk analysis, this thesis summarizes the existing international experience. The analysis of methodological approaches to identifying, assessing and managing the risk of using information and telecommunication systems, carried out in the work, showed that currently there is a lack of methodological development, isolation from the realities of banking practice. It should be noted that the most successful attempt to solve the problem of creating an integrated system of banking risk analysis belongs to the Basel Committee, which issued relevant recommendations for assessing banking risks.

Operational risks for Russian credit institutions are caused not only by changes in banking operations, but also by information technologies used by banks, which affects the volume of risk.

It should be noted that the information systems of credit institutions are subject to various influences, leading to a decrease in the information security of credit institutions, and, as a result, to certain losses. The method of identification, evaluation and management developed by the author reflects: a) the ever-increasing level of general banking management, including the management of branches and operations, as well as the complication of operations of credit institutions; b) increasing attention to the problem of banking operational risks on the part of credit institutions, as well as, in the future, regulatory authorities (primarily the Bank of Russia).

The developed methodological recommendations ensure the continuity of theoretical provisions in the practical activities of credit institutions and make it possible to manage the risk of using information and telecommunication systems, taking into account the experience accumulated in this area by banks of the leading economically developed countries of the world.

6. The analysis carried out by the author of the dissertation research indicates the need to introduce into the daily practice of the activities of credit institutions guidelines on identifying, assessing and managing the risk of using information and telecommunication systems of credit institutions in order to increase efficiency: managing this risk at the level of credit institutions, controlling the state of operational risk by the Bank of Russia, as well as supervising banking activities, using information about this risk to monitor operations carried out by credit institutions in general.

In this dissertation work, methodological approaches are proposed, formulated and justified, the implementation of which will help increase the effectiveness of the regulatory impact of the Central Bank of the Russian Federation on the operational risk to which the country's banking system is exposed.

7. The internal banking system for identifying, assessing and managing the risk of using information and telecommunications systems is one of the significant factors influencing both the state of this risk and the process of managing operational risk in credit institutions.

The thesis proposes a methodology for organizing control over the risk of using information and telecommunications systems in credit institutions, consisting of a system for identifying, assessing and monitoring the risk of using information and telecommunications systems, as well as measures for internal control of this risk. The introduction of the proposed methodology into the practical activities of Russian credit institutions will help improve the efficiency of their activities in the field of identification, assessment and management of operational risk, which may have a significant impact on the overall level of performance and stability of Russian credit institutions.

The effectiveness and operability of the method of organizing control over the risk of using information and telecommunication systems in credit institutions is confirmed by the use of the approaches proposed by the author in the activities of CB Invest-Ecobank LLC.

In conclusion, I would like to assume that the implementation of the conclusions and recommendations of this dissertation research in practice will help specialists involved in the identification, assessment and control of operational risks, and will also present the problem of regulating the risk of using information and telecommunication systems from the standpoint of an integrated economic approach, which involves deep knowledge of the theory and practice of banking and determines their further development.

Message
on a material fact on decisions taken by the Issuer's Board of Directors
1. General information
1.1. Full company name of the issuer (for non-profit organization– name) Gazprombank (Joint Stock Company)
1.2. Abbreviated corporate name of the issuer Bank GPB (JSC)
1.3. Location of the issuer Moscow
1.4. OGRN of the issuer 1027700167110
1.5. TIN of the issuer 7744001497
1.6. Unique issuer code assigned by the registration authority 00354В
1.7. Address of the Internet page used by the issuer to disclose information http://www.gazprombank.ru
http://www.site

2. Message content
2.1. Date of the meeting of the Board of Directors of Bank GPB (JSC), at which the relevant decisions were made: 05.03.2015.
2.2. Date of compilation and number of the minutes of the meeting of the Board of Directors of Bank GPB (JSC), at which the relevant decisions were made: March 10, 2015, No. 07.
2.3. There was a quorum for all items on the agenda. Decisions on all issues on the agenda were adopted unanimously.
2.4. Content of the decisions adopted by the Board of Directors of Bank GPB (JSC):
2.4.1. Include the following candidates in the list of candidates for voting at the annual General Meeting of Shareholders of Gazprombank (Joint Stock Company) in 2015 for elections to the Board of Directors of Gazprombank (Joint Stock Company):
Akimov Andrey Igorevich – Chairman of the Management Board of Gazprombank (Joint Stock Company);
Vasilyeva Elena Alexandrovna - Deputy Chairman of the Board - Chief Accountant Gazprom";
Gavrilenko Anatoly Anatolyevich - General Director of CJSC "Leader";
Dmitriev Kirill Alexandrovich - General Director of the Limited Liability Company " Management Company RDIF";
Eliseev Ilya Vladimirovich - Deputy Chairman of the Management Board of Gazprombank (Joint Stock Company);
Ivanov Sergey Sergeevich – Chairman of the Management Board of OAO SOGAZ;
Yulia Stanislavovna Karpova - Deputy Chairman - Member of the Management Board of Vnesheconombank;
Kruglov Andrey Vyacheslavovich - Deputy Chairman of the Management Board - Head of the Department of OAO Gazprom;
Miller Alexey Borisovich – Chairman of the Management Board of OAO Gazprom;
Seleznev Kirill Gennadyevich – Member of the Management Board, Head of the Department of OAO Gazprom;
Sereda Mikhail Leonidovich - Deputy Chairman of the Management Board - Head of the Office of the Management Board of OAO Gazprom;
Chernyshenko Dmitry Nikolaevich – Chairman of the Management Board of OAO Gazprom-Media Holding.
Shamalov Yury Nikolaevich - President of NPF "GAZFOND".
2.4.2. Recommend to the Annual General Meeting of Shareholders of Gazprombank (Joint Stock Company) in 2015 to determine the quantitative composition of the Board of Directors of Gazprombank (Joint Stock Company) - 12 people.
2.4.3. Include the following candidates in the list of candidates for voting at the annual General Meeting of Shareholders of Gazprombank (Joint Stock Company) in 2015 for elections to the Audit Commission of Gazprombank (Joint Stock Company):
Bakaev Petr Gennadievich - Head of the Department of Gazprom OJSC;
Zhirnyakova Irina Vladimirovna - Deputy Head of the Accounting and Reporting Department - Deputy Chief Accountant of CJSC "Leader";
Margarita Ivanovna Mironova – First Deputy Head of the Management Board Staff – Head of the Department of the Management Board Staff of OAO Gazprom;
Pashkovsky Dmitry Alexandrovich – Deputy Head of the Management Board Staff – Head of the Management Board Staff Department of OAO Gazprom.
Petrenko Elena Vladimirovna – General Director of LLC “Consulting and Auditing Firm “Business Perspektiva”.

3. Signature
3.1. Deputy Chairman A.I. Sable
Management Board of Bank GPB (JSC)
(signature)
3.2. Date “12” March 2015 M.P.

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1 APPROVED by Order of PJSC Gazprom dated November 16, 2016 715 Composition of the Bureau, Council for Sustainable Development under the Chairman of the Scientific and Technical Council and sections of the Scientific and Technical Council of PJSC Gazprom 1. Alexey Borisovich Miller 2. Vitaly Anatolyevich Markelov 3. Oleg Evgenievich Aksyutin 4. Afanasiev Igor Pavlovich 5. Borisenko Natalya Yuryevna 6. Ishkov Alexander Gavrilovich 7. Kalinkin Alexander Vyacheslavovich 8. Kislenko Nikolay Anatolievich 9. Livin Alexey Alexandrovich 10. Mikhalenko Vyacheslav Alexandrovich 11. Nosov Yury Stanislavovich STC Bureau Chairman of the Board of PJSC Gazprom, Candidate economic sciences, Chairman of the Scientific and Technical Council; Deputy Chairman of the Management Board of PJSC Gazprom, Candidate of Technical Sciences, Deputy Chairman of the Scientific and Technical Council; Member of the Management Board, Head of Department of PJSC Gazprom, Doctor of Technical Sciences, Deputy Chairman of the Scientific and Technical Council, Section Chairman; Directorate of PJSC Gazprom, Candidate of Technical Sciences, Section Chairman; economics, section chairman; Directorate of PJSC Gazprom, Doctor of Chemical Sciences, Section Chairman; Deputy Head of the Department of Gazprom PJSC, Section Chairman; Deputy Head of the Department of PJSC Gazprom, General Director of OOO NIIgazekonomika, Candidate of Technical Sciences, Section Chairman; Directorate of PJSC Gazprom, Section Chairman; Member of the Management Board, Head of Department of PJSC Gazprom, Candidate of Technical Sciences, Section Chairman; Deputy Head of the Administration of the Management Committee, Head of Department of PJSC Gazprom, Executive Secretary of the Management Committee, Section Chairman;

2 2 12. Pankratov Sergey Nikolaevich 13. Pashkovsky Dmitry Alexandrovich 14. Petrenko Vadim Evgenievich 15. Sirotkin Mikhail Vladimirovich 16. Skrynnikov Sergey Vladimirovich 17. Cherepanov Vsevolod Vladimirovich 18. Filatov Alexander Anatolievich 19. Filippov Andrey Gennadievich 20. Shapovalo Anatoly Antonovich 21. Shapovalov Oleg Igorevich 22. Nedzvetsky Maxim Yurievich of Economic Sciences, Chairman of the Section; Deputy Head of the Office of the Board of Economic Sciences, Section Chairman; technical sciences, section chairman; Legal Deputy Head of the Department of PJSC Gazprom, Section Chairman; Member of the Management Board, Head of Department of PJSC Gazprom, Candidate of Geology and Mineralogy, Section Chairman; technical sciences, section chairman; First Deputy Head of the Department of PJSC Gazprom, Candidate of Technical Sciences, Section Chairman; technical sciences, section chairman; Head of the Directorate of Gazprom PJSC, Section Chairman; Sciences, Scientific Secretary of the Scientific and Technical Council. Council for Sustainable Development under the Chairman of the Scientific and Technical Council 1. Akimov Valery Alexandrovich 2. Aleshin Nikolai Pavlovich Head of the Federal State budget institution"All-Russian Research Institute for Civil Defense and Emergency Situations of the Ministry of Emergency Situations of Russia" (Federal Center for Science and high technology), doctor of technical sciences, professor (as agreed); Director of the Research and Development Center "Welding and Control" at the Moscow State Technical University named after N.E. Bauman, Academician of the Russian Academy of Sciences

3 3 3. Alfimov Mikhail Vladimirovich 4. Aseev Alexander Leonidovich 5. Bugaev Alexander Stepanovich 6. Budzulyak Bogdan Vladimirovich 7. Bushuev Vitaly Vasilievich 8. Gokhberg Leonid Markovich 9. Grachev Vladimir Alexandrovich 10. Dmitrievsky Anatoly Nikolaevich 11. Kalendzhyan Sergey Oganovich 12. Kapustin Vladimir Mikhailovich 13. Kasimov Nikolai Sergeevich 14. Kontorovich Alexey Emilevich Chairman of the Scientific and Technical Council under the Board of Directors of JSC RUSNANO, Academician of the Russian Academy of Sciences Academician of the Russian Academy of Sciences, Vice President of the Russian Academy of Sciences, Chairman of the Siberian Branch of the Russian Academy of Sciences, Doctor of Physical and Mathematical Sciences, Head of the Department of Vacuum Electronics of the Moscow Institute of Physics and Technology, Deputy Director of the Institute of Radio Engineering and Electronics. V.A. Kotelnikova RAS, Doctor of Physical and Mathematical Sciences, Academician of the Russian Academy of Sciences President of the Non-Profit Partnership "Self-Regulatory Organization Association of Builders of Gas and Oil Complexes" ("SRO OSGiNK"), Doctor of Technical Sciences, Professor General Director of the Energy Strategy Institute, Doctor of Technical Sciences, Professor First Vice-Rector, Director Institute for Statistical Research and Economics of Knowledge, National Research University Higher School of Economics, Doctor of Economics, Professor Advisor CEO State Corporation Rosatom, Corresponding Member of the Russian Academy of Sciences, Doctor of Technical Sciences Director of the Institute of Oil and Gas Problems of the Russian Academy of Sciences, Academician of the Russian Academy of Sciences Dean of the Faculty of Higher Education corporate governance» Russian Academy national economy and public service under the President of the Russian Federation, Doctor of Economics General Director of OAO VNIPIneft, Doctor of Technical Sciences, Professor First Vice President of the Russian Geographical Society, Academician of the Russian Academy of Sciences Deputy General Director of the A.A. Trofimuk of the Siberian Branch of the Russian Academy of Sciences, Member of the Presidium of the Siberian Branch of the Russian Academy of Sciences, Academician of the Russian Academy of Sciences, Doctor of Geology and Mineralogy

4 4 15. Leonov Yuri Georgievich 16. Martynov Victor Georgievich 17. May Vladimir Alexandrovich 18. Makhutov Nikolay Andreevich 19. Nikitin Boris Alexandrovich 20. Osipov Viktor Ivanovich 21. Parmon Valentin Nikolaevich 22. Porfiriev Boris Nikolaevich 23. Posyagin Boris Sergeevich 24. Salygin Valery Ivanovich 25. Safonov Maxim Sergeevich Academician of the Russian Academy of Sciences, Advisor to the Russian Academy of Sciences of the Department of Geosciences Member of the Board of Directors of PJSC Gazprom, Rector of the Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Doctor of Economics, PhD in Geology and Mineralogy, Professor Member of the Board of Directors of PJSC Gazprom, Rector of the Russian Academy of National Economy and Public Administration under the President of the Russian Federation, Doctor of Economics, Professor Chairman working group under the President of the Russian Academy of Sciences on risk analysis and security problems, chief Researcher Institute of Mechanical Engineering. A.A. Blagonravova RAS, Corresponding Member of the RAS, Doctor of Technical Sciences, Professor, President of the Academy of Technological Sciences of the Russian Federation, Head of the Department of Offshore Oil and Gas Field Development, Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Doctor of Technical Sciences, Professor, Scientific Director of the Institute of Geoecology. EAT. Sergeev RAS, academician of the RAS, scientific director of the Institute of Catalysis. G.K. Boreskova SB RAS, Academician of the Russian Academy of Sciences, Doctor of Chemistry, Candidate of Physical and Mathematical Sciences, Professor Deputy Director for Research at the Institute of Economic Forecasting of the Russian Academy of Sciences, Corresponding Member of the Russian Academy of Sciences, Doctor of Economics, Professor, retired PJSC Gazprom, Candidate of Technical Sciences Director of the International Energy Policy Institute and Diplomacy at MGIMO, Vice President of the International Academy of the Fuel and Energy Complex, Corresponding Member of the Russian Academy of Sciences Deputy President of the Russian Academy of Sciences, Doctor of Economics

5 5 26. Favorsky Oleg Nikolaevich 27. Filippov Sergey Petrovich 28. Khadzhiev Salambek Naibovich 29. Kharionovskiy Vladimir Vasilievich 30. Epov Mikhail Ivanovich Deputy Academician-Secretary of the Department of Energy, Mechanical Engineering, Mechanics and Control Processes of the Russian Academy of Sciences, Academician of the Russian Academy of Sciences Director of the Institute of Energy Research of the Russian Academy of Sciences, Corresponding Member of the Russian Academy of Sciences Director of the Institute of Petrochemical Synthesis named after V.I. A.V. Topchieva of the Russian Academy of Sciences, Academician of the Russian Academy of Sciences, Deputy General Director for Science of ZAO Aerospace Monitoring and Technologies, Chairman of the Dissertation Council of OOO Gazprom VNIIGAZ, Doctor of Technical Sciences, Professor, Deputy Chairman of the Siberian Branch of the Russian Academy of Sciences, Director of the Institute of Petroleum Geology and Geophysics named after V.I. A.A. Trofimuk of the Siberian Branch of the Russian Academy of Sciences, Academician of the Russian Academy of Sciences (as agreed). NTS sections 1. Strategic Development and efficiency of the gas industry 1. Aksyutin Oleg Evgenievich 2. Kislenko Nikolay Anatolyevich 3. Borisenko Natalya Yurievna 4. Ivannikov Alexander Sergeevich 5. Mavlyudov Rinat Ravilievich 6. Polous Kiril Yuryevich 7. Komlev Sergey Lvovich Member of the Management Board, Head of Department of PJSC Gazprom, Doctor of Technical Sciences, Deputy Chairman of the Scientific and Technical Council, Chairman of the Section; Deputy Head of the Department of PJSC Gazprom, General Director of OOO NIIgazekonomika, Candidate of Technical Sciences, Deputy Economic Department of PJSC Gazprom, Candidate economic chief Contract Structuring and Pricing Department of Gazprom Export LLC, Candidate of Economics

6 6 8. Romanov Sergey Mikhailovich 9. Adilova Maria Dmitrievna Deputy Director of the Department of State Energy Policy of the Ministry of Energy of Russia, Doctor of Economic Sciences Deputy Head of the Department of PJSC Gazprom, Candidate of Technical Sciences, Scientific Secretary of the Section. 2. Management of innovative development 1. Kislenko Nikolay Anatolyevich 2. Lubkova Inna Vadimovna 3. Alekseev Alexander Olegovich 4. Gokhberg Leonid Markovich 5. Klementovichus Yana Yazzepovna 6. Tokareva Tatyana Vladimirovna 7. Storonsky Nikolai Mironovich 8. Yarygin Yury Nikolaevich 9. Sharafutdinov Alexander Viktorovich Deputy Head of the Department of PJSC Gazprom, General Director of OOO NIIgazekonomika, Candidate of Technical Sciences, Section Chairman; (Engineering), Deputy Director of the Center for Corporate Governance Methodology of NIIgazekonomika LLC; First Vice-Rector, Director of the Institute for Statistical Research and Economics of Knowledge of the National Research University Higher School of Economics, Doctor of Economics, Professor Director of the Higher School of Economics of St. Petersburg State University of Economics, Doctor of Economics, Associate Professor, Head of Department of PJSC Gazprom; First Deputy General Director for Science of Gazprom Promgaz JSC, Candidate of Physics and Mathematics Head of the Engineering and Technical Center Branch of Gazprom Transgaz Moscow LLC, Candidate technical chief department of Gazprom PJSC, scientific secretary of the section. 3. Development of the mineral resource base 1. Cherepanov Vsevolod Vladimirovich Member of the Management Board, Head of Department of PJSC Gazprom, Candidate of Geological and Mineralogical Sciences, Section Chairman;

7 2. Akhmedsafin Sergey Kasnulovich 3. Kirsanov Sergey Alexandrovich 4. Merkulov Anatoly Vasilievich 5. Ogibenin Valery Vladimirovich 6. Rybalchenko Vadim Viktorovich 7. Sharafutdinov Ruslan Farkhatovich 8. Shchekalev Roman Viktorovich 9. Spirin Andrey Alexandrovich 7 Deputy Head of the Department of Gazprom PJSC, Deputy Deputy Head of the Directorate of Gazprom PJSC, Candidate Deputy General Director Chief Geologist of Gazprom Dobycha Yamburg LLC; Head of the Engineering and Technical Center of Gazprom Geologorazvedka LLC, Ph.D. Biological Deputy Head of the Department of Gazprom PJSC, Scientific Secretary of the Section. 4. Construction of wells 1. Filippov Andrey Gennadievich 2. Belsky Dmitry Gennadievich 3. Varyagov Sergey Anatolyevich 4. Kuznetsov Roman Yuryevich 5. Mnatsakanov Vadim Alexandrovich 6. Oganov Alexander Sergeevich First Deputy Head of the Department of Gazprom PJSC, Candidate of Technical Sciences, Chairman of the Section; Head of Department of Gazprom PJSC, Deputy Deputy General Director Chief Geologist of Gazprom Dobycha Nadym LLC, Doctor of Geology and Mineralogy Deputy Director Head of the Production Department of the Branch private company Limited Liability Company Gazprom EP International Services B.V. in St. Petersburg, Doctor Deputy General Director of Gazprom Burenie LLC, Candidate Head of the Well Drilling Department of the Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Doctor of Technical Sciences, Professor

8 8 7. Polyakov Igor Genrikhovich 8. Shtol Vladimir Filippovich 9. Kuligin Andrey Vitalievich Deputy Head of the SKIR Service of the GPU of Gazprom dobycha Astrakhan LLC, Candidate technical deputy Head of Department of Gazprom PJSC, Candidate of Technical Sciences, Scientific Secretary of the Section. 5. Production of gas and gas condensate 1. Kalinkin Alexander Vyacheslavovich 2. Minlikaev Valery Ziryakovich 3. Gafarov Nail Anatolievich 4. Kononov Alexey Viktorovich 5. Mikhailov Nikolai Nilovich 6. Mokshaev Alexander Nikolaevich 7. Nikolaev Oleg Alexandrovich 8. Stolyarov Vladimir Evgenievich 9. Petropavlov Vladislav Evgenievich Deputy Head of Department of PJSC Gazprom, Section Chairman; (Engineering), Deputy Vice-President for Research and Innovation, Non-Profit Organization Association of Oil and Gas Field and Drilling Equipment Enterprises, Doctor of Technical Sciences Chief Engineer First Deputy General Director of OOO Gazprom Dobycha Noyabrsk, Candidate Chief Researcher at the Institute of Oil and Gas Problems of the Russian Academy of Sciences, Doctor of Technical Sciences (as agreed); Chief Engineer, First Deputy General Director of Gazprom Dobycha Orenburg, Candidate Chief Engineer, First Deputy General Director of Gazprom Dobycha Yamburg, Candidate Head of Department, PJSC Gazprom; chief technologist of the department of Gazprom PJSC, scientific secretary of the section.

9 9 6. Technique and technology for the development of offshore fields 1. Vadim Evgenievich Petrenko 2. Alexey Ivanovich Novikov 3. Alexander Alexandrovich Aliseichik 4. Vladimir Stepanovich Vovk 5. Sergei Vyacheslavovich Grekov 6. Mirzoev Dilizhan Allahverdy Ogly 7. Alexander Dziublo 8. Sergey Chigai Evgenievich 9. Grechko Alexander Georgievich of technical sciences, chairman of the section; Deputy Head of the Directorate of PJSC Gazprom, Deputy Chairman of the Section Chief Designer of the Central Design Bureau Korall, Candidate of Technical Sciences Advisor to the Managing Director of Gazprom International, Doctor of Geology and Mineralogy Head of the Engineering Support Department offshore projects Center for the Development of Offshore Oil and Gas Resources of Gazprom VNIIGAZ LLC, Candidate Head of the Department of Engineering and Technology for the Development of Offshore Hydrocarbon Fields of the Center for the Development of Offshore Oil and Gas Resources of Gazprom VNIIGAZ LLC, Doctor of Engineering, Professor Professor of the Department of Development of Offshore Oil and Gas Fields of the Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Doctor of Geological and Mineralogical Sciences, Head of the Offshore Production Department of the Offshore Projects Development Unit of Gazprom Neft PJSC; chief technologist of the department of Gazprom PJSC, doctor of technical sciences, scientific secretary of the section. 7. Transportation of gas, gas condensate and underground gas storage 1. Mikhalenko Vyacheslav Aleksandrovich 2. Khan Sergei Aleksandrovich 3. Borodin Vladislav Ivanovich Member of the Management Board, Head of Department of Gazprom PJSC, Candidate of Technical Sciences, Section Chairman; Directorate of PJSC Gazprom, Candidate of Technical Sciences, Deputy Deputy Head of the Department of PJSC Gazprom;

10 10 4. Gubanok Ivan Ivanovich 5. Karaev Pasha Tapdyg ogly 6. Nikitin Vasily Gennadievich 7. Prokopets Alexey Olegovich 8. Salnikov Sergey Yuryevich 9. Zyuzkov Viktor Viktorovich Deputy General Director for Repair of Pipelines and Structures of Gazprom Tsentrremont LLC, Candidate Deputy Head Directorate of Gazprom PJSC, Candidate Deputy General Director for the operation of compressor stations of Gazprom Transgaz Nizhny Novgorod LLC; Deputy General Director for Operation of Compressor Stations of Gazprom Transgaz Yugorsk LLC, Candidate Director of the Center for Gas Transportation Systems and Technologies of Gazprom VNIIGAZ LLC, Candidate Chief Technologist of the Department of Gazprom PJSC, Candidate of Technical Sciences, Scientific Secretary of the Section. 1. Skrynnikov Sergey Vladimirovich 2. Distanov Ruslan Yuryevich 8. Gas supply and integrated use of gas 3. Babakov Alexander Vladimirovich 4. Vlasichev Sergey Vladimirovich 5. Zavgorodniy Evgeny Alexandrovich Deputy Head of the Department of Gazprom PJSC, Section Chairman; Head of the Directorate of Gazprom PJSC, Deputy General Director of Gazprom Transgaz Moscow LLC; Deputy General Director for Gas Transportation of OOO Gazprom Mezhregiongaz; Deputy Head of the Production and Technical Department of Gazprom Gas Engine Fuel LLC; 6. Lyugay Director of the Gas Utilization Center of Gazprom Stanislav Vladimirovich VNIIGAZ LLC, Candidate 7. Artem Aleksandrovich Rodin 8. Yury Iosifovich Spektor 9. Mikhail Petrovich Posmak Chief Technologist of the Gazprom PJSC Department, Candidate First Deputy General Director of Gazprom Promgaz JSC, director of the Moscow branch of Gazprom design LLC, doctor of technical sciences, professor; Head of Department, PJSC Gazprom, Candidate of Technical Sciences, Scientific Secretary of the Section.

11 11 9. Complex processing of gas and gas condensate 1. Igor Pavlovich Afanasiev 2. Danis Khasanovich Fairuzov 3. Firdavez Gaptelfartovich Zhagfarov 4. Airat Vilsurovich Ishmurzin 5. Andrey Vladimirovich Kleimenov 6. Anton Lvovich Maksimov 7. Anatoly Vladimirovich Mamaev 8. Mikhail Mikhailovich Morozov 9. Artemina Ekaterina Olegovna of the Department of PJSC Gazprom, Candidate of Technical Sciences, Section Chairman; Head of the Directorate of PJSC Gazprom, Deputy Deputy Head of the Department of the Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Doctor of Technical Sciences Chief Engineer First Deputy General Director of OOO Gazprom Pererabotka; head of technical policy department and innovation activities Gazprom Neft PJSC, Doctor Deputy General Director of the Institute of Petrochemical Synthesis named after V.I. A.V. Topchieva RAS, Doctor of Chemical Sciences, Professor Deputy General Director for Science of Gazprom VNIIGAZ LLC, Candidate of Technical Deputy General Director for Production of Gazprom Dobycha Orenburg LLC; chief technologist of the department of Gazprom PJSC, scientific secretary of the section. 10. Welding, diagnostics, corrosion protection and repair technologies 1. Filatov Alexander Anatolyevich 2. Nasteka Vadim Viktorovich 3. Arabey Andrey Borisovich 4. Artemenkov Valery Yurievich 5. Vyshemirsky Evgeniy Mstislavovich of technical sciences, chairman of the section; Directorate of PJSC Gazprom, Deputy Head of Department of PJSC Gazprom, Candidate Deputy Head of Department, Head of Department of PJSC Gazprom; Head of Division, PJSC Gazprom, Candidate

12 12 6. Karpenko Sergey Petrovich 7. Melekhin Oleg Nikolaevich 8. Olekseychuk Viktor Romanovich 9. Shipilov Alexander Valentinovich Deputy Head of Department Head of Department of PJSC Gazprom; Head of the Directorate of PJSC Gazprom; Head of Division, PJSC Gazprom; Deputy Head of Department, Head of Department of PJSC Gazprom, Candidate of Technical Sciences, Scientific Secretary of the Section. 11. Informatization and automation technological processes 1. Borisenko Natalya Yurievna 2. Semenov Pavel Viktorovich 3. Dzitiev Georgy Muratovich 4. Krokhin Viktor Vasilievich 5. Latyshev Mikhail Vladimirovich 6. Novikova Irina Alexandrovna 7. Semenov Ruslan Nikolaevich 8. Chukichev Vladimir Filippovich 9. Nikitin Oleg Alexandrovich of Economic Sciences, Chairman of the Section ; Head of the Directorate of PJSC Gazprom, Deputy Deputy Head of the Directorate of PJSC Gazprom, Candidate of Economics Head of the Directorate of the Business Process Repository of Gazprom Inform LLC, Candidate Head of the Directorate of the Corporate Data Bank of Regulatory and Reference Information of LLC Gazprom Inform, Doctor Head of the VIR Directorate production support of OOO Gazprom inform; First Deputy General Director for capital construction and reconstruction of Gazprom Tsentrremont LLC; Deputy General Director for IMS P DOOO and dispatch control systems of Gazprom Inform LLC; Chief Economist of the Department of PJSC Gazprom, Candidate of Economic Sciences, Scientific Secretary of the Section. 12. Dispatch control and metrology 1. Pankratov Sergey Nikolaevich 2. Kireev Alexander Yurievich of economic sciences, chairman of the section; Head of Department, PJSC Gazprom, Deputy

13 13 3. Donskikh Boris Dmitrievich 4. Maramygin Yuri Alexandrovich 5. Sardanashvili Sergey Alexandrovich 6. Sverchkov Dmitry Vladimirovich 7. Kostikov Sergey Leonidovich 8. Khristoforov Denis Viktorovich 9. Knyazev Oleg Viktorovich Head of the Natural Gas Quality Control Laboratory of the Metrological Support Center of Gazprom VNIIGAZ LLC ”, Candidate General Director of Gazprom Transgaz Volgograd, Candidate Head of the Department of Design and Operation of Gas and Oil Pipelines of the Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Candidate of Technical Sciences, Head of the Directorate of PJSC Gazprom; Deputy Head of Department, Head of Department, PJSC Gazprom; Director of the UGSS Modeling Center of NIIgazekonomika LLC, Candidate of Physics and Mathematics, Head of the Department of PJSC Gazprom, Scientific Secretary of the Section. 13. Energy 1. Shapovalo Anatoly Antonovich 2. Shkitov Denis Aleksandrovich 3. Asoskov Sergey Mikhailovich 4. Volodko Andrey Anatolyevich 5. Ershov Mikhail Sergeevich 6. Zhitomirsky Boris Leonidovich 7. Konoplev Timur Fedorovich of technical sciences, chairman of the section; Chief Technologist of the Department of PJSC Gazprom, Ph.D. professor of the department theoretical electrical engineering and electrification of the oil and gas industry Russian State University of Oil and Gas (NRU) named after I.M. Gubkina, Doctor of Technical Sciences, General Director of OAO Orgenergogaz, Candidate of Technical Sciences, Professor, Deputy General Director of OOO Gazprom Gaznadzor, Head of the Energy Inspectorate of PJSC Gazprom;

14 14 8. Favorsky Oleg Nikolaevich 9. Leznov Vladimir Borisovich Deputy Academician-Secretary of the Department of Energy, Mechanical Engineering, Mechanics and Control Processes of the Russian Academy of Sciences, Academician of the Russian Academy of Sciences Deputy Head of the Department of Gazprom PJSC, Scientific Secretary of the Section. 1. Livin Alexey Alexandrovich 2. Bondarenko Vitaly Alekseevich 3. Aginey Ruslan Viktorovich 4. Volkov Dmitry Sergeevich 5. Zhmulin Vladimir Vladimirovich 6. Mayants Yuri Anatolyevich 7. Pesin Alexander Semenovich 8. Shamis Lev Veniaminovich 9. Yushmanov Valery Nikolaevich 1. Pashkovsky Dmitry Alexandrovich 14. Construction and transport support of the Directorate of PJSC Gazprom, section chairman; Deputy Head of Department Head of Department of Gazprom PJSC, Deputy Section Chairman; Deputy Director for Research of the Nizhny Novgorod Branch of OOO Gazprom Proektirovanie, Doctor of Technical Sciences, Professor; Deputy General Director for general issues OOO Gazprom transgaz Ukhta; Deputy General Director for Production of PJSC VNIPIgazdobycha; Deputy Director of the Center for Construction, Repair and Corrosion Protection Technologies of Gazprom VNIIGAZ LLC, Candidate of Technical Deputy General Director for Repair and Capital Construction of Gazprom Transgaz Surgut LLC, Candidate Deputy Director of the Financial Analysis Center production assets OOO NIIgazekonomika, Candidate of Economics, Head of the Department of PJSC Gazprom, Candidate of Technical Sciences, Academic Secretary of the Section. 15. Risk Management Deputy Head of the Office of the Board of Economic Sciences, Chairman of the Section;

15 15 2. Bykov Andrey Alexandrovich 3. Golembiovsky Dmitry Yuryevich 4. Demkin Igor Vyacheslavovich 5. Krivoruchko Svetlana Vitalievna 6. Leonov Denis Anatolyevich 7. Ovcharov Sergey Viktorovich 8. Shevchenko Andrey Vladimirovich 9. Turko Sergey Ivanovich Head of Department of Gazprom PJSC, Doctor in Physics and Mathematics, Professor, Deputy Deputy Head of the Risk Department, Head of the Department of Market Risks and Liquidity Risks of PJSC Bank ZENIT, Professor of the Department of Operations Research and Actuarial Mathematics, Faculty of Computational Mathematics, Lomonosov Moscow State University. M.V. Lomonosov, Doctor of Technical Sciences, Deputy Director of the Risk Analysis Center of NIIgazekonomika LLC, Doctor of Economics, Associate Professor; Director of the Center for Monetary Policy of the Institute for Financial and Economic Research, Professor of the Department of Monetary Relations and Monetary Policy, FGOBU HPE "Financial University under the Government of the Russian Federation", Doctor of Economics in Economics and Industrial Safety of Gazprom VNIIGAZ LLC, Candidate Chief Researcher of the Risk Management and Insurance Laboratory of the Center for Risk Management, Improving Operational Sustainability and Industrial Safety of Gazprom VNIIGAZ LLC, Doctor of Technical Sciences, Professor; Chief Expert of the Department of PJSC Gazprom, Doctor of Technical Sciences, Scientific Secretary of the Section. 16. System of Civil Protection and Industrial Safety 1. Shapovalov Oleg Igorevich 2. Ponomarenko Dmitry Vladimirovich Head of Department of PJSC Gazprom, Section Chairman; Directorate of Gazprom PJSC, Deputy

16 16 3. Boldin Anatoly Viktorovich 4. Dolgov Sergey Ivanovich 5. Dontsov Vladimir Ivanovich 6. Dymov Igor Georgievich 7. Sosunov Igor Vladimirovich 8. Stepanov Igor Vladimirovich 9. Gorshkov Igor Borisovich Head of Department of PJSC Gazprom; Director of the Center for Risk Management, Improving the Sustainability of Functioning and Industrial Safety of Gazprom VNIIGAZ LLC, Candidate Head of the Department of Gazprom PJSC; Deputy Head of the Directorate of PJSC Gazprom; Deputy Head of the Federal State Budgetary Institution "All-Russian Research Institute for Civil Defense and Emergencies" of the Ministry of Emergency Situations of Russia (Federal Center for Science and High Technologies), Ph.D. section secretary. 17. Security environment and energy saving 1. Ishkov Alexander Gavrilovich 2. Yatsenko Igor Anatolievich 3. Varfolomeev Evgeniy Viktorovich 4. Grachev Vladimir Alexandrovich 5. Melkov Alexander Sergeevich 6. Pystina Natalya Borisovna Management of PJSC "Gazprom", Doctor of Chemical Sciences, Chairman of the Section; Deputy Head of Department Head of Department of PJSC Gazprom, Candidate of Technical Sciences, Deputy Director of the Center for Economics, Energy Saving, Ecology and Implementation new technology NIIgazekonomika LLC, Candidate of Economic Advisor to the General Director of Rosatom State Corporation, Corresponding Member of the Russian Academy of Sciences, Doctor of Technical Sciences, Deputy Head of Department of PJSC Gazprom; Director of the Center for Environmental Safety, Energy Efficiency and Labor Protection of Gazprom VNIIGAZ LLC, Candidate

17 17 7. Savchenko Oleg Andreevich 8. Shaikhutdinov Alexander Zainetdinovich 9. Konyaev Sergey Vladimirovich Deputy Head of Department of Gazprom PJSC, Candidate of Pedagogics Deputy General Director for Science of Gazprom VNIIGAZ LLC, Candidate of Technical Deputy Head of Department Head of Department of PJSC Gazprom, candidate of technical sciences, scientific secretary of the section. 18. Document circulation and organization of management 1. Nosov Yury Stanislavovich 2. Ivantsov Igor Vitalievich 3. Zakharov Alexander Borisovich 4. Isaev Maxim Alexandrovich 5. Nedorezova Irina Sergeevna 6. Rusakova Svetlana Vladimirovna 7. Saltykov Alexander Alekseevich 8. Safarov Azamat Akmalovich 9. Mitchenko Olga Yuryevna Deputy Head of the Management Board Staff Head of Department, Executive Secretary of the Management Board of PJSC Gazprom, Section Chairman; Assistant to the Deputy Head of the Administration of the Management Board, Head of Department, Executive Secretary of the Management Board of PJSC Gazprom, Deputy Head of the Department for Documentation Support of the Directorate of Gazprom Transgaz Moscow; first deputy general Director of PJSC"Gazprom automation"; Head of Division, PJSC Gazprom; Deputy Head of Department, Head of Department, PJSC Gazprom, Candidate of Historical Deputy Head of Department, PJSC Gazprom; Head of the Directorate of PJSC Gazprom; Head of Department, PJSC Gazprom, Candidate of Historical Sciences, Academic Secretary of the Section.


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JSC "Gazprom space systems" - Decisions of general meetings of participants (shareholders)

Material Facts Concerning the Issuer's Events

Decisions of general meetings of participants (shareholders)

1. General information

1.1. Full corporate name of the issuer (for a non-profit organization - name): Open Joint Stock Company "Gazprom Space Systems"

1.2. Abbreviated corporate name of the issuer: OAO Gazprom Space Systems

1.3. Location of the issuer: 141112, Russian Federation, Moscow region, the city of Schelkovo, Moskovskaya street, 77B

1.4. OGRN of the issuer: 1025002045177

1.5. Issuer's TIN: 5018035691

1.6. Unique issuer code assigned by the registration authority: 03851-A

1.7. Address of the Internet page used by the issuer to disclose information: http://disclosure.1prime.ru/portal/default.aspx?emId=5018035691

2.1. Type of general meeting (annual, extraordinary): annual.

2.2. Form of the general meeting: meeting (joint presence of shareholders to discuss agenda items and make decisions on issues put to vote).

2.3. Date, time and place of the general meeting: June 27, 2016, from 14.00 to 15.00, 141112, Russian Federation, Moscow region, city of Schelkovo, Moskovskaya street, 77B.

on issues 1-7, 9 of the agenda - 656,834 votes;

on item 8 of the agenda - 7,225,174 cumulative votes.

In accordance with Art. 58 of the Federal Law "On joint-stock companies"There was a quorum, the General Meeting of Shareholders of OAO Gazprom Space Systems was competent.

2.5. Agenda of the General Meeting of Shareholders:

1) On the procedure for holding the annual General Meeting of Shareholders of OAO Gazprom Space Systems.

2) About counting commission the annual General Meeting of Shareholders of the Company.

3) On approval of the Annual Report, annual accounting (financial) statements

OAO Gazprom Space Systems for 2015.

4) Distribution of profits (losses) of OAO Gazprom Space Systems based on the results of 2015.

5) On approval of the Company's auditor for 2016.

6) On approval of the amount of remuneration paid to members of the Board of Directors and the Audit Commission of OAO Gazprom Space Systems for the performance of their duties in 2015.

7) On determining the number of members of the Board of Directors of OAO Gazprom Space Systems.

8) On the election of members of the Board of Directors of the Company.

9) On the election of members of the Audit Commission of the Company.

On the first item on the agenda:

1. To elect Sergey Vladimirovich Rubanov, a representative of PJSC Gazprom, as the Chairman of the annual General Shareholders' Meeting.

2. Approve the rules of procedure for the annual General Meeting of Shareholders

OAO Gazprom Space Systems:

Report on the Company's Annual Report - 10 minutes;

annual report financial statements- 10 minutes;

Report on other agenda items - 5 minutes;

Questions from representatives of the shareholders of the Company - 5 minutes.

On the second item on the agenda:

The wording of the decision:

Approve ZAO "SR-DRAGa" as the counting committee of the annual General Meeting of Shareholders of OAO "Gazprom Space Systems".

On the third item on the agenda:

The wording of the decision:

Approve the Annual report, annual accounting (financial) statements of OAO Gazprom Space Systems for 2015.

On the fourth item on the agenda:

The wording of the decision:

1. Not to distribute profit in connection with the loss incurred as a result of operations in 2015, due to the impact of negative exchange rate differences accrued on credit obligations in foreign currency.

2. Not to pay dividends on the shares of OAO "Gazprom space systems" due to the lack of net profit.

On the fifth item on the agenda:

The wording of the decision:

Approve LLC PRIMA Audit. PRAUD Group as the auditor of OAO Gazprom Space Systems for auditing the financial and economic activities of OAO Gazprom Space Systems in 2016.

On the sixth item on the agenda:

The wording of the decision:

Pay remuneration to members of the Board of Directors and the Audit Commission for the performance of their duties in 2015 in the amount recommended by the Company's Board of Directors.

On the seventh item on the agenda:

The wording of the decision:

Determine the number of members of the Board of Directors of OAO "Gazprom Space Systems" - 11 people.

On the eighth agenda item

1Golenishchev Igor Anatolyevich 606,000 8.3873%

2Ivannikov Alexander Sergeevich 606,000 8.3873%

3Markelov Vitaly Anatolyevich 606,000 8.3873%

4Mikhalenko Vyacheslav Aleksandrovich 606,000 8.3873%

5Nosov Yury Stanislavovich 606,000 8.3873%

6Rubanov Sergey Vladimirovich 606,000 8.3873%

7Sevastyanov Dmitry Nikolaevich 606,000 8.3873%

8Sereda Mikhail Leonidovich 606,000 8.3873%

9Khomyakov Sergey Fedorovich 606,000 8.3873%

10Osmolovsky Vladimir Efimovich 0 0.00%

11Oleynik Dmitry Nikolaevich 1,167,705 16.1616%

12Sobol Aleksandr Ivanovich 603,469 8.3523%

AGAINST ALL CANDIDATES 0 0.0000%

ABSTAINED FOR ALL CANDIDATES 0 0.0000%

The wording of the decision:

Elect as members of the Board of Directors of OAO Gazprom Space Systems:

Golenishchev Igor Anatolievich;

Ivannikov Alexander Sergeevich;

Markelov Vitaly Anatolievich;

Mikhalenko Vyacheslav Alexandrovich;

Nosov Yuri Stanislavovich;

Rubanov Sergey Vladimirovich;

Sevastyanov Dmitry Nikolaevich;

Sereda Mikhail Leonidovich;

Khomyakov Sergey Fedorovich;

Oleinik Dmitry Nikolaevich;

Sobol Alexander Ivanovich.

On the ninth item on the agenda:

1. Ladygina Irina Leonidovna 550,679 83.84%; 0; 106 155

2.Pashkovsky Dmitry

Aleksandrovich 550,679 83.84%; 0; 106 155

3. Salekhov Marat Khasanovich 524,140 79.79%; 0; 132 694

4. Knyazeva Olga Viktorovna 106,155 16.16%; 524 140; 26 539

5. Kosenko Alexander Borisovich 0 0.00%; 524 140; 132 694

6. Gorbacheva Elena Anatolyevna 26,539 4.04%; 524 140; 106 155

The wording of the decision:

To elect members of the Auditing Commission of OAO Gazprom Space Systems:

Ladygina Irina Leonidovna;

Pashkovsky Dmitry Alexandrovich;

Salekhov Marat Khasanovich.

2016 No. 49.

2.8. Identification features shares, the holders of which are entitled to participate in general meeting issuer's shareholders: ordinary registered non-documentary shares; identification number of the securities issue and the date of its assignment: 1-01-03851-A dated 11/17/2003.

3. Signature

3.1. Job title, I.O. Name of the authorized person of the issuer: Deputy General Director for Administrative and Legal Affairs, acting on the basis of power of attorney No. ДС-09/310/49 dated December 31, 2015 V.N. Panasov

3.2. Date: 06/27/2016

This notice was provided by the Distributor or directly by the Subject of Information Disclosure and published in accordance with the Regulation on Information Disclosure by Issuers of Equity Securities, approved by Order of the Federal Financial Markets Service of Russia dated 04.10.2011 No. 11-46/pz-n, or the Regulation on the requirements for the procedure and timing of information disclosure related to the activities of joint-stock investment funds and management companies of mutual investment funds, as well as to the content of the information disclosed, approved by Order of the Federal Financial Markets Service of Russia dated June 22, 2005 No. No. 05-23/pz-n.