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1. What is compulsory conversion of OZON depositary receipts?

Answer: Forced conversion is a special one-time mechanism provided for by Russian legislation, under which foreign depositary receipts (ADRs/GDRs) are exchanged for ordinary shares of the company in the Russian jurisdiction without the participation of a foreign depository. Simply put, if your OZON ADRs are "stuck" in a foreign brokerage account due to sanctions or other restrictions, Russian law allows you to apply in Russia to receive ordinary shares of Ozon ICPAO in return. This procedure is initiated not by the investor himself directly through his broker, but in accordance with the established procedure through the authorized Russian registrar JSC "Register-Proton" in cooperation with the issuer. As a result of the approved conversion, your ADRs are canceled, and instead you become the direct owner of the corresponding OZON shares on the Russian market.

2. Why is forced conversion of ADR OZON important now?

Answer: In 2025, Ozon Holdings PLC completed redomicilation – the transfer of registration from abroad (Cyprus) to Russia, becoming MKPAO Ozon. According to Russian law, after a company is registered in the Russian Federation, all its foreign depositary receipts must be converted into local shares within the prescribed period. Automatic conversion has already been performed for receipts held in Russian depositories (for example, NSD). However, many foreign investors hold OZON's ADR through foreign brokers. It is now almost impossible to exchange receipts for shares voluntarily through such brokers (they refuse to interact with the Russian infrastructure). Therefore, for foreign holders of OZON ADR, it is the forced conversion that is relevant-probably the only available way to get their shares. Without it, foreign ADRs will remain non-tradable and non-dividend-yielding, and may eventually be canceled with a vague prospect of compensation.

3. How does forced conversion differ from automatic and voluntary conversion?

Answer: Automatic conversion is carried out without any actions on the part of the investor: the depositary receipts registered in the Russian contour at the time of redomicilation were automatically exchanged for shares of Ozon MCPAO (coefficient 1:1). Such auto-conversion for OZON was completed by October 2025, and trading in MCPAO shares has already resumed on the Moscow Stock Exchange.

Voluntary conversion involves the exchange of ADR for shares at the investor's initiative through the program's depository bank (usually by agreement with the broker). Under normal circumstances, an investor could instruct their broker to exchange ADRs, but now this path is blocked: due to sanctions, Western brokers and depositories refuse to conduct such operations with Russian securities.

Forced conversion is a process established by Russian regulators just for those cases when voluntary conversion does not work. In other words, forced conversion is an organized period during which foreign holders of "frozen" ADRs can submit documents directly within the Russian infrastructure for exchange for shares. Unlike automatic, it requires active actions from the investor (preparation of documents, applications, etc.), and unlike voluntary – it is carried out according to special rules through Russian structures, bypassing the usual international chains that do not function now.

4. Who has the right to force conversion of OZON ADR?

Answer: Shareholders who hold OZON's depositary receipts as of the date of submission of the application have the right to apply for forced conversion. As a rule, these are ADR holders whose receipts are registered in foreign depositories or with foreign brokers (for example, inEuroclear/Clearstream, DTC, in foreign banks) as of the time of Ozon redomicilation in the Russian Federation. If your ADRs were located outside the Russian contour and your broker/bank is unable to exchange them for shares due to sanctions or technical restrictions, you meet the criteria for forced conversion (this is a typical situation). It is important that you are actually listed as the owner of the relevant ADRs (directly or as a beneficiary through a nominee holder). Please note: investors who are under personal sanctions, or those who are directly prohibited from operating with Russian assets under the laws of their country, can submit documents from the point of view of Russian law, but must independently assess the legal consequences (Russian authorities do not formally restrict their participation, but foreign bans remain their area of responsibility – see the question about sanctions risks are lower).

5. When will the forced conversion period start and how long will it last?

Answer: December 1, 2025. This date is called by all authoritative sources of information, although as of 18.11.2025 it is not yet an official date. The exact start date will become known from the official announcement of the company and the depository. According to the law, the forced conversion period must start no later than one year after the company's redomicilation in the Russian Federation. In the case of OZON, redomicilation ended on September 26, 2025. However, Ozon has already announced that it plans to open a forced conversion window from December 1, 2025. Once the process officially starts, the window duration will be 120 days (approximately 4 months). During this period, investors should have time to submit all the documents.

So, if the conversion starts on December 1, 2025, then the application deadline is March 30, 2026.

It is very important not to miss this period: after it closes, they will no longer be able to accept your conversion documents, and the courts are quite unambiguous here: although there is a positive practice on investor claims, it does not apply to situations of missed deadlines. (For more information about the consequences of missing the deadline, see question #12.)

6. How does the conversion process work?

Answer: The procedure consists of several stages: first, you prepare a package of necessary documents (see the next question) and send them to the registrar. For OZON, such registrar is JSC "Register-Proton". After receiving your application, your document will be checked for compliance with the Conversion Procedure and Russian legislation. Upon successful verification, your ADRs are subject to cancellation, for which the registrar informs your broker by mail. In Russia, the corresponding number of ordinary shares of MCPAO "Ozon" will be credited to your personal account with the registrar of JSC "Register-Proton". As an applicant, it is important for you to provide a full set of correctly executed papers in a timely manner – then the procedure basically passes without your further participation. Upon completion of the conversion, you will receive a notification confirming that you have become the owner of the shares. The deadline for reviewing a package of documents on the registrar's side is 20 business days. If you submit documents at the beginning of the procedure, then there is a chance to get a response from the registrar within the 120-day period and if there are shortcomings in the application or the documents attached to it, correct them and submit the package again – the main thing is to do this within the general 120-day period.

7. What documents do I need to apply for?

Answer: You need to collect a fairly extensive package of documents confirming your ownership of ADR and meeting the formal requirements.

The most important documents are listed below:

1. Power of attorney for a representative (unless you plan to personally handle the procedure). The power of attorney must be notarized and apostilled, the original must be delivered to Russia, translated into Russian, and the translation must be certified by a Russian notary. You can also apply for a power of attorney at the Russian consulate/Embassy (if you have an organizational opportunity).
2. Application for forced conversion. The form is available on the registrar's website.
3. Application form (questionnaire) the investor.
4. Documents confirming ownership of the ADR. You must prove that you are the holder of a certain amount of OZON ADR. This is usually done using your broker's/bank's account statements. Such statements must contain your name and the amount of ADR as of a specific date. Since foreign statements themselves are not recognized as official evidence in the Russian Federation, they must be notarized and apostilled. If the original statements are not in Russian, a translation will be required (see question #8). Most often, it is impossible to get such statements in the correct form, so you have to perform a notarial inspection of your personal account with a broker through a Russian notary. This is one of the most important and responsible steps in the entire procedure, and its success largely depends on it.
5. Information about the storage chain. Simply put, you need to specify all intermediaries: your broker - > its custodian (if any) - > international depository (for example, Euroclear). Obtaining such information is often a serious problem.
6. A copy of the applicant's passport. You need a notarized copy of your identity document with an apostille (or legalization, if we are talking about countries where the Hague Convention on Apostille does not work, for example, in the United Arab Emirates). A foreign passport must be accompanied by a translation into Russian, certified by a notary in the Russian Federation.
7. Additional documents on request. The Registrar may request other materials as well, depending on the circumstances.

We also provide confirmation that voluntary conversion is not possible (in the form of printouts).

8. Do I need translation, apostille or legalization of documents?

Answer: Yes, almost all documents of foreign origin must be properly certified for their use in Russia. Apostille is required on official documents (for example, notarized copies of extracts) if the issuing country has acceded to the Hague Convention of 1961. Make sure that each notarized copy or signature certificate is apostilled (or consular legalization, if apostille is not used in your country). Without this, the Russian authorities will not accept the document, even if it is notarized abroad. In addition, all materials in a foreign language (including extracts, power of attorney, passport data) must be translated into Russian. Translation must be performed in Russia through a qualified translator and then notarized. This will ensure that it matches the format that the logger expects.

For example, your broker's statement in English must be (a) certified by a foreign notary, (b) apostille stamped, and (c) translated into Russian and signed by an interpreter with a Russian notary. Similarly, for a power of attorney, passport, etc., the only exception may be the conversion application form itself and the application form – you can fill them out immediately in Russian. As a result, the final package submitted to the registrar must be completely in Russian or contain notarized translations, and all signatures and seals from abroad must be legalized (through an apostille or the consulate of the Russian Federation). Our lawyers, of course, will help you find out where the apostille is needed and where the translation is sufficient, and will arrange a notarized translation of your documents in Moscow.

9. Do I need a power of attorney for my representative and how do I get it?

Answer: If you plan to act through a representative in Russia (which is practically necessary, given the complexity of the procedure), you will need to issue a power of attorney for him. A trusted person (for example, a MAGENTA Legal specialist) will be able to submit documents on your behalf, communicate with the depository, receive statements, and perform other legally significant actions related to conversion. To issue a power of attorney, you must contact a local notary when you are abroad. In the text of the power of attorney, you must clearly specify the powers: submitting an application for forced conversion of ADR OZON, providing/signing the necessary documents, obtaining certificates, etc. We will provide you with a sample of the wording in Russian and English. After signing with a notary, the power of attorney must be apostilled (or legalized through the consulate of the Russian Federation, if your country does not recognize the apostille). Then the original power of attorney should be sent to us in Russia. Upon receipt, we will translate it into Russian and notarize the translation.

Please note that without a properly executed power of attorney, your representative will not be able to officially introduce you – Russian organizations will not accept documents from a third party if the power of attorney is incorrectly issued. Therefore, this stage is extremely important. As a result, the power of attorney (with apostille and translation) is included in the package of documents for conversion. We always check the draft power of attorney in advance so that it meets the requirements of Russian notaries and depositories.

We can offer to include in the power of attorney and authority for subsequent actions (collecting dividends, repatriating them to your country, selling shares and repatriating funds from their sale, etc.) – if you want to save time and money in the future.

10. Where and how to apply for conversion?

Answer: An application with a set of documents is submitted to the Russian depository responsible for conducting forced conversion of OZON – JSC "Register-Proton".

You will need to send the original paper documents directly to this depository.

At the moment (18.11.2025), the Conversion Procedure does not provide for preliminary approval of a package of documents (including by e-mail), as, for example, it happened when converting TCS Group receipts or allocating EVRAZ shares.

We recommend that you entrust the submission to us – our employees in Moscow will be able to quickly submit documents directly, receive incoming marks, and interact with the registrar's employees on the spot if necessary. It is important to note that the documents must be received by the registrar no later than the last date of the conversion window. Therefore, you need to send them in advance, taking into account the delivery time and possible delays.

11. How long will it take for shares to be reviewed and credited?

Answer: The Registrar reviews the application and the attached documents within 20 business days (i.e. about a month). After that, the registrar either informs that the shares can be credited to the personal account opened by the registrar for this purpose, or refuses to do so, indicating the reasons, including the possibility of re-submitting the application and documents within the general 120-day period.

The registrar has 30 business days to transfer shares, which are counted from the end of the deadline for submitting applications (presumably from March 30, 2026). And then, within another 10 business days, the registrar must notify the shareholders of this.

However, there have often been delays in the past.

12. What if you miss the application deadline?

Answer: If you do not submit your application within the established 120-day period, this period will not be restored. As of today, none of the announced forced conversion procedures have been resumed (or repeated). Our experience shows that sometimes investors come to us after the period closes, but we can't help them. Therefore, it is better to prepare in advance and submit your application as early as possible after the window opens.

13. Can I convert receipts voluntarily or in any other way?

Answer: In the current reality, most likely not. Voluntary conversion is virtually unavailable: Western brokers usually refuse to follow instructions. We do not know of any other parallel exchange mechanism.

14. What should I do if the broker does not issue the necessary documents?

Answer: This is a common problem. Many foreign brokers and banks, especially in the EU/USA, are not ready to prepare special certificates or notarize statements for Russian purposes. If your broker has refused to issue an official letter of ownership of ADR or does not have a procedure for notarizing the statement, there are alternative ways to collect evidence:

You can use standard broker statements (for example, a monthly report from your merchant profile), even without the broker's signature. Their authenticity will have to be confirmed in Russia through the mechanisms of a notary. For example, a Russian notary can perform a notarial inspection of your account's web page (the so-called notarial inspection). The notary will go to the broker's website, verify that you have a certain amount of ADR OZON on your account, and issue a sealed inspection report. Such a report, together with a printed statement, will be proof of ownership. Our team organizes such notarial inspections – this is the solution if foreign documents cannot be obtained (and this is most often the case).

15. What happens if the total amount of depositary receipts applied for conversion exceeds the amount issued under the depository program?

Answer: If the (approved) conversion applications are submitted by applicants with a number of receipts exceeding the entries under the depository program, the forced conversion will not be carried out at all. Unfortunately, fraudulent and/ orrroneous actions of applicants have been reported in the past, which may have resulted in incorrect crediting of shares. This condition is the minimum guarantee that the shares will be received by the holders of receipts, and not by fraudsters.

16. How many OZON shares will I receive for my receipts (conversion rate)?

Answer: As of today, one deposit receipt of Ozon Holdings PLC corresponds to one ordinary share of Ozon MCPAO. The conversion rate is 1:1. This was the initial condition of the ADR OZON program, and when converting (automatic or forced) it is saved. For example, if you have 100 ADRs, you will receive 100 shares after conversion. There are no additional coefficients or losses during the exchange as of 18.11.2025 (unlike, for example, the forced conversion of LUKOIL receipts, where the coefficient was 0.89).

17. Will I be able to sell the received shares on the stock exchange?

Answer: It depends on the country of citizenship ("friendly" or "unfriendly" – EU, USA, England, Canada, etc. – from the point of view of Russian sanctions). There are no restrictions for citizens of China or India, for example. Unfortunately, for citizens from "unfriendly" countries, it is impossible to sell shares – at least as long as the current restrictions apply. The fact is that for foreign shareholders from "unfriendly" countries, Russian legislation establishes a special regime for storing securities: the received shares are placed in a special "C" type account. This means that you become the owner of the shares, but your rights to dispose of them are limited. Type C provides for a ban on alienation: you cannot freely sell, donate or withdraw these shares from the Russian accounting system without a separate permission from the government commission. Simply put, as long as financial sanctions remain in place at the bilateral level, your shares remain illiquid – you own them, but you can't turn them into cash in Russia or abroad. It is also impossible to sell on the Moscow Exchange, because brokers and depositories will not perform such an operation for a non-resident from an unfriendly jurisdiction (securities are blocked in the "C" account). So, you need to be prepared that after the conversion, your investment will be frozen. For certain cases, this is still better than ADRs blocked abroad, since (1) the future fate of foreign receipts is not clear – whether they will give the right to Russian shares, probably not, (2) Russian shares are at least accounted for in your account, (3) accumulate possible dividends and wait in the wings. If the geopolitical situation improves and restrictions are lifted, you will have the opportunity to dispose of shares. But at the time of conversion and immediately after it, you cannot sell them, dispose of dividends. We try to convey this to all our clients so that there are no false expectations. Conversion is about restoring your rights as a shareholder, not about instant liquidity.

If you have the citizenship of a" friendly" (for example, Israel) and simultaneously "unfriendly" jurisdiction (for example, Germany), then the restrictions apply to you in full.

If you have Russian citizenship and citizenship of an "unfriendly" jurisdiction, then the restrictions do not apply to you.

Finally, if you have citizenship only in a "friendly" jurisdiction (for example, India), then, as a general rule, there are no special restrictions.

18. Will I receive dividends on my shares after conversion?

Answer: Yes, the right to dividends is restored after you become the owner of ordinary Russian shares. How it works: after the conversion, you can open a ruble account (for "unfriendly" countries-a "C" account) in a bank (if you don't have one yet). All dividends paid by Ozon on your shares will be transferred to this account.

For "unfriendly" investors, the money in the "C" account is also blocked for withdrawal abroad, but it remains your property and accumulates. You can only use them within Russia for certain payments (for example, tax payments) or expect currency restrictions to be relaxed. For example, if Ozon decides to pay a dividend in 2025, the amount due to you (in rubles at the official exchange rate on the payment date) will be credited to your "C" account. You will not lose this money, although you will not be able to withdraw it.

As for past periods: Ozon, being a growing company, has not previously paid dividends, so you probably don't have any "historical" payments (although they are allowed by Russian law). In other redomiciled companies (Tinkoff, MD Medical Group, etc.), dividends for previous years were actually paid to shareholders after conversion. Thus, in the case of OZON, the main potential is future dividends. By converting the receipts, you will regain the right to participate in the company's profits, while holders of undeclared ADRs will not receive any payments.

On November 07, 2025, the Board of Directors of Ozon recommended that the General Meeting of Shareholders pay dividends for 9 months of 2025 in the amount of RUB 143.55 per share. Previously, Ozon did not pay any dividends. The final decision will be made at an extraordinary general meeting of shareholders to be held on December 10.

19. Are there any sanctions or legal risks associated with the conversion?

Answer: From the point of view of Russian legislation, as a foreign investor, you are not prohibited from applying for conversion – this procedure is specifically introduced for investors from "unfriendly" countries and is allowed by Russian authorities.

However, it is important to consider the laws of your own jurisdiction. For example, a resident of the EU or the UK may find that holding or increasing a stake in Russian assets (especially through accounts with NSD, which is subject to EU sanctions) potentially violates local sanctions rules. Similarly, US citizens need to monitor compliance with OFAC sanctions. In each case, these risks are individual. The Russian side does not check your compliance with foreign law – this is your responsibility. MAGENTA Legal does not provide advice on the sanctions legislation of other countries or on issues of foreign jurisdictions. We focus exclusively on the legal framework of the Russian Federation (the process of conversion within the framework of decrees and instructions of the Central Bank of the Russian Federation). If in doubt, we strongly recommend that you consult a lawyer in your country. Ultimately, the decision to participate in the conversion is up to you.

20. What are the conversion costs (tariffs)?

Answer: When planning a conversion, you need to take into account two types of expenses: deposit fees and related costs for processing documents.

First, the registrar performing the conversion sets its own rate for the service. As of 18.11.2025, the rates for converting OZON have not yet been announced, we are in contact with JSC "Register-Proton" and are awaiting publication. When the tariff is published, investors will most likely have to pay for it in rubles to the registrar's bank details.

Secondly, there are notarial and organizational expenses: payment for notary services (certification of copies, translations, notarial inspection of the account), payment for apostille in the investor's country, courier sending of documents. These costs depend on your source documents and country, and may average several hundred dollars/euro. Finally, if you involve us in support, our fee for services is stipulated – it is fixed in the contract. We try to offer transparent conditions: the initial consultation is free, then the cost of services depends on the amount of work and complexity of the case (preparation of documents, correspondence, individual difficulties). Now we do not give specific figures here, since each case is different.

21. What experience does MAGENTA Legal have in converting depositary receipts?

Answer: Our company has been specializing in such tasks for several years. Back in 2022, when forced conversion was introduced for the first time for a number of Russian companies, our team successfully accompanied many foreign investors through this complex process. We participated in both forced and standard (voluntary) conversion under the programs of such issuers as Gazprom, Lukoil, Sberbank, Tatneft, Gazpromneft, VK, HH, TCSGroup (Tinkoff), etc. Since then, we have been keeping our finger on the pulse of all legislative changes.

22. How can MAGENTA Legal help you with this process?

Answer: We provide comprehensive support for the procedure. Specifically, our services include: preliminary consultation (analyzing your situation, checking whether you meet the criteria), issuing a detailed checklist of documents that need to be collected. Next – help with collecting documents: we prepare draft applications and questionnaires; provide samples of power of attorney; and provide instructions for obtaining statements from a broker. Then our employees deal with notarial formalities: they translate your documents into Russian and certify them with a notary, conduct notarial inspections of your accounts if necessary, and interact with translators. We carefully check the finished package for compliance with the requirements (we have an internal checklist based on our experience working with registrars). After that, we act as your representative: we submit documents to the depository in person, receive a note of acceptance. During the review process, we communicate with the depository or registrar: if additional information or clarifications are needed, we provide them promptly and keep in touch. We can also interact with your broker or a foreign depository if confirmation from them is required. Our goal is to complete the task, that is, to transfer shares to the account. We will receive a final extract from the register or a confirmation from the depository and send it to you. In general, MAGENTALegal takes care of all the paperwork and legal work, minimizing your efforts. You don't have to understand the subtleties of the Russian rules – we have studied them for you and applied them in practice many times. You will be informed about the progress of the process at every stage: we regularly inform you about the status and important news. Thus, our help is your peace of mind during the conversion period and maximum chances of success.

Additionally, if necessary, we are ready to help with tax and legal issues in Russia related to accounting for securities, provide services for collecting dividends, legal support for the sale of securities (when possible), help with the repatriation of funds received to your jurisdiction (when possible), and so on.

23. Why should you contact MAGENTA Legal?

Answer: By choosing us, you get a reliable partner with proven expertise. Here are a few reasons:

1. Successful experience. As already mentioned, we conducted ADR conversion in 2022-2025 for several large issuers and achieved a positive result for hundreds of clients (individuals and legal entities). The accumulated practice allows you to anticipate pitfalls and effectively avoid them.
2. Current knowledge. We thoroughly follow all changes in legislation and new explanations of regulators. Your situation will be reviewed in accordance with the latest rules – you will not have to study government regulations or instructions of the Central Bank yourself, we have already done it for you.
3. Team work. A team of 10 lawyers (including experienced specialists in capital markets, finance, and taxes), full-time translators (Russian, German, and Chinese), back-office staff, and trusted partners (translators, notaries, couriers, etc.) are at your disposal. We exchange experience and expertise with each other, know all the stages of the process, solve complex cases in brainstorming mode, insure each other and provide 24/7 work in several time zones and several jurisdictions when the project is urgent.
4. Individual approach. We understand that each client has a different situation: different country of residence, different brokers, different difficulties. We do not work in a standard way – our team carefully analyzes your circumstances (citizenship, tax residency, availability of documents, logistics) and suggests the best action plan. If unique difficulties arise, we will make every effort to resolve them, advising you on the best options.
5. Transparency and trust. We value our customers and build long-term relationships. All financial conditions are negotiated in advance, no hidden fees. We regularly inform you about the progress of the case, answer questions, and provide a report upon completion.
6. Informational support. MAGENTA Legal actively shares its knowledge: we publish articles and shoot videos (including on the topic of OZON) so that you can understand the essence of the process (see question #28). This is part of our service – the client should always understand what is happening with their assets.
7. Exchange of experience. We interact with other law firms in the market and exchange experience with them. MAGENTA Legal is also a member of EAHCISS – the European Association of securities holders of the CIS countries.

Our goal is to relieve you of stress and red tape by ensuring the smoothest possible conversion. You will be able to make sure that MAGENTA Legal justifies the trust with its competence and responsible attitude.

24. Do I need a Russian brokerage account to receive shares?

Answer: No, you do not need to open an account yourself if you do not have one. In case of forced conversion, the accounting mechanisms are arranged so that the shares will be credited to a personal account in the register of shareholders, which is maintained by JSC "Register-Proton". In any case, this will happen automatically as part of the procedure.

In general, you do not need to go to Russia and try to open a brokerage account. In the future, if the restrictions are lifted and you want to sell shares, then you may need to open an account with a Russian broker for the sale. But this is not relevant at the conversion stage. You will receive proof of ownership documents. Thus, the absence of an account in the Russian Federation is not a hindrance to conversion – the process is designed specifically for foreign holders who previously did not have an account in the Russian infrastructure.

25. Can I do the conversion myself, without lawyers?

Answer: Yes, you have the right to personally prepare and submit all documents (including by mail or courier service). However, it may be very difficult to implement this procedure independently from abroad. We will not try to convince you of the need to contact our company, this is your personal choice.

26. Why are my OZON ADRs no longer traded on the exchange?

Answer: Because the Ozon depositary receipt program Ozonis effectively closed.

27. What should I consider from the financial side when converting? Is it profitable?

Answer: Each investor must independently assess the financial implications. MAGENTA Legal does not provide investment recommendations or forecast stock prices. Our goal is to legally secure your rights. However, there are a few things you should pay attention to: the conversion itself does not increase or decrease your capital – you get an equivalent number of shares, just the jurisdiction and mode of their circulation change.

The current share price on the Moscow Exchange (MOEX) as of 18.11.2025 is 3,791 rubles, which is about 40.5 euros per share.

Thus, the profitability of the conversion is measured more by the preservation of your investment than by the instant financial return. We strongly recommend that you consult a financial advisor if you are in doubt. It will help you take into account your risk profile, diversification, and prospects of the Russian market and make an informed decision. For our part, we repeat that our information is general in nature, and this is not financial advice. We simply give you a tool to save your assets; whether to use it or not is your decision as an investor.

28. Is the result of converting my receipts guaranteed?

Answer: Unfortunately, there are no 100% guarantees – neither we nor anyonecan promise that the conversion will be successful in each specific case. The procedure is related to the actions of third parties: depositories, registrar, and OZON, and we cannot influence their decisions. Our goal is to do everything as correctly as possible, and thereby maximize the chances of success. If the documents are submitted in full and on time, there are usually no grounds for refusal. Russian depositories, as a rule, approve correctly executed applications. At the same time, we should note that almost every case has its own "rough edges", so there are always risks. Nevertheless, we are proud that none of the cases of forced conversion of redomiciled companies were rejected.

MAGENTA Legal does not guarantee a successful conversion and is not responsible for losses if the conversion is refused, except in cases of intentional violation. At the same time, we always try to make reasonable efforts to increase your chances of conversion.

However, there are cases of force majeure: sudden changes to the rules, additional requirements, or suspension of the process by the regulator. If your application is suddenly rejected for formal reasons, we will make every effort to correct the situation, if there is still time. However, if the conversion window is closed and you did not have time or were rejected, you cannot re-submit your documents. That is why we insist on thorough preliminary preparation and efficiency.

29. Where can I find additional materials from MAGENTA Legal on this topic?

Answer: We try to inform investors: on our special page dedicated to depositary receipts, you can find a lot of information about forced conversion. We regularly conduct webinars and record videos, posting them on YouTube. Stay tuned for our latest updates.

30. What should an investor do now to prepare for the conversion?

Answer: Start preparing in advance. If you've read this FAQ, you're already on the right track. We recommend: first, collect the basic documents – contact your broker and request an account statement with your OZON ADRs. If the broker can issue an official email – fine, if not, save the standard report/screenshot.

Secondly, check your passport – it must be valid; if it expires, it may be worth updating, because the power of attorney and application will be based on the passport.

Third, contact us (or another consultant of your choice) for a preliminary consultation, start preparing the power of attorney, it takes a lot of time.

In our experience, the main problem is that customers apply too late. Do not repeat this mistake: the earlier you prepare the documents (even before the start of accepting applications), the calmer you will be later. We can now start checking your materials, making translations, and issuing a power of attorney.

For further information, please contact us via the form on our website or via our Telegram bot.

Disclaimer: The above information is for general information purposes only and does not constitute legal or investment advice. Despite careful preparation, no guarantee can be given for its accuracy or completeness. In particular, legal conditions may change or have different effects in individual cases. The responsibility for decisions and actions in connection with the conversion lies with the investor. It is recommended that professional advice be sought in case of doubt. In addition, investors must ensure that they comply with the regulations of their country of residence (including sanctions regulations). We accept no liability for any losses or disadvantages arising from the use of the above information. Any participation in the procedure described is at your own risk.

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This note is for informational purposes only and does not constitute a legal or investment recommendation. Be sure to consult a lawyer for your case. The information is correct as of 18.11.2025 COB. MAGENTA Legal does not advise on sanctions and foreign legislation issues. The client independently evaluates its legal and compliance risks and, if necessary, turns to lawyers at its location. MAGENTA Legal services can only be provided after signing a contract and paying for them. We do not guarantee the result of reviewing the application and are not responsible for the actions of third parties.