In accordance with the second paragraph of Clause 2.6 of Article 277 of the Tax Code of the Russian Federation Rusagro Group PJSC has resolved to determine the proportion of the book value of shares in Rusagro Group PJSC held hy foreign holding company ROS AGRO PLC in the book value of ROS AGRO PLC’s assets, using the indicators determined on the basis of the valuation report on the market value of the said shares and assets.

At the initiative of Rusagro Group PJSC an independent valuer, acting in accordance with the legislation of the Russian Federation on valuation activities, conducted a valuation of the market value of:

- shares of Rusagro Group PJSC;

- assets of ROS AGRO PLC, list of which had been provided to the independent valuer of Rusagro Group PJSC,

as of the date corresponding to the last day of the period ending 150 days after the date of the Arbitrazh Court’s issuance of the decision to suspend the exercise of ROS AGRO PLC corporate rights in relation to Rusagro Group PJSC in compliance with the Federal Law No. 470-FZ.

Based on the aforementioned report, the proportion of the market value of shares of Rusagro Group PJSC in the market value of ROS AGRO PLC’s assets amounted to 93.62% as at 2 February 2025.

This publication constitutes a revised calculation of the said proportion in accordance with the first paragraph of Clause 2.6 of Article 277 of the Tax Code of the Russian Federation.

In accordance with the said provision, for the purpose of determining the value of Rusagro Group PJSC’s shares, the proportion established on the basis of the valuation report is applied, whereas the calculation of the proportion based on the book value of ROS AGRO PLC’s assets is not applied.

On the 28th of November, 2025, amendments were made to Part 2.6 of Article 277 of the Russian Tax Code. These amendments allow to determine the true share of Rusagro’s business within the assets of ROS AGRO PLC as of date preceding the initiation of the investor entry process into direct ownership of shares of Rusagro Group PJSC in September 2024. Accordingly, rights of the investors who owned ROS AGRO PLC Global Depositary Receipts (GDR) and then entered into direct ownership of shares of Rusagro Group PJSC in the period from December 2024 to January 2025 will be protected with respect to taxation.

Rusagro Group is taking all necessary measures to ensure the timely completion of the independent valuation, enabling the investors to apply the new provisions of the Russian Tax Code and thereby reduce their tax burden when executing transactions with the Company’s shares. Completion of the valuation and its results will be announced thereafter on the official website under sections “Investors” and “News & Events”.

In accordance with Part 20-23 Article 7 of the Russian Federal law No. 470-FZ dated 4th August 2023 “On the specifics of regulating corporate relations in business entities that are economically significant organizations” (the “Law”) holders of ROS AGRO PLC Global Depositary Receipts (the “GDR”) in foreign infrastructure who had not entered into direct ownership of shares of Rusagro Group PJSC within the timeframes established by Part 8 of Article 7 of the Law are obliged to take direct ownership of shares of Rusagro Group PJSC no later than the 31th of December, 2026.

The obligation to enter into ownership of shares of Rusagro Group PJSC no later than the 31^st of December, 2026, applies to investors who:

1.       were holders of the GDR as of 5 September 2024 and continue to own the GDR in foreign depositaries;
2.  did not enter into direct ownership of shares of Rusagro Group PJSC by submitting the special application and the package of documents by the 28th of December, 2024.

The above-mentioned holders of the GDR in the foreign infrastructure will be able to take the ownership of shares of Rusagro Group PJSC by submitting the special application and the package of documents in accordance with the instructions available at the link: Application (Download), Instruction (Download), Consent to PPD (Download). These applications will be accepted no later than the 31th of December, 2026.