with assistance of CORPORATE GOVERNANCE PROFESSIONAL ASSOCIATION

COMPANY TRANSPARENCY INDEX 2019 – TABLE OF CONTENTS

FOREWORD 4 DISCLOSURE LEVEL IN CORPORATE 12 GOVERNANCE COMPONENT

TRANSPARENCY INDEX DISCLOSURE 6 CONCLUSIONS LEVEL 18

DISCLOSURE LEVEL BY CATEGORY 8 24 COMPANY Company Transparency Index 2019 – Ukraine TRANSPARENCY INDEX 2019 RESULTS The Corporate Governance Professional Association (CGPA) and the Centre for CSR Development Ukraine (CSR Ukraine), supported by the Center for International Private Enterprise (CIPE), present the Company Transparency Index 2019, an assessment of Ukraine’s 100 largest taxpaying companies in 2019, as per the State Tax Service Data. The assessment analyzes the companies’ level of transparency in corporate governance and corporate social responsibility (hereinafter referred to as CSR) in 2019, before the pandemic caused by COVID-19. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 3 FOREWORD

The Center for International Private Enterprise (CIPE) is I am really grateful to the partners of the Project – CSR Ukraine and The CSR Development Center has been implementing the Trans- proud to support this initiative which aims to encourage CIPE. Our cooperation made this study possible. We are pleased to find parency Index for eighth year in a row. But this year is special – companies to increase transparency and engagement out that there is a whole group of companies (banks) in Ukraine which this Transparency Index is conducted in partnership with two with the broader Ukrainian business ecosystem. not only follow popular trends but truly practice what they preach, well-known organizations – the Corporate Governance Profes- The companies on this list represent some excellent they promote specific values. These are the companies of the future. sional Association of and CIPE. I am grateful to the partners for best practices in Ukraine and can serve as leaders in They can be attractive to investors, partners and employees. this opportunity, support, and expertise. the country - creating a more inclusive, transparent It is also essential for companies to promote themselves system- The site is a tool for communication with stakeholders. That is atically and professionally, to establish a culture of openness and business operating environment that offers more why we evaluate not only general information about the company develop their unique style of “communication” with the business opportunities for more Ukrainians. The bright future of but also the results of the company’s work in many areas – hu- environment in the broadest sense of the word. Ukraine relies on more companies “doing the right thing” man rights, gender equality, corporate governance. That is im- and the leading companies highlighted in this report For the first time, we decided to pay attention to the personal lead- portant for investors, potential employees, NGOs, and the media. represent a strong foundation for the Ukrainian business ership style of senior executives, because we believe that if the The Transparency Index 2019 has updated components – cor- community to build on. company supports environmental projects, for example, the CEO should share these ideas and be personally involved in such types of porate governance, gender equality, and leadership. The Index Eric Hontz, projects not only as a manager but also as a citizen. results show interesting results: the overall level of transparency CIPE Deputy Regional Director, It was our first experience of conducting this particular type of such remains low, although state-owned companies perform better in Europe & Eurasia a comprehensive study; we are planning to continue in the future the Transparency Index than private ones. improving our methodology. Constructive criticism and any sugges- I hope the Transparency Index 2019 will help companies improve tions are welcome! We are open to cooperation. their sites and be inspired by the TOP-10 Index leaders’ example.

Oleksandr Okuniev, Maryna Saprykina, Chairman of the Management Board of the Corporate Head of the Board for CSR Ukraine Governance Professional Association

COMPANY TRANSPARENCY INDEX 2019 UKRAINE 5 TRANSPARENCY

INDEX Average 25 disclosure level, DISCLOSURE 22,0 by Transparency 20,0 LEVEL Index 2019 category 20

15

A General information about the company and its CSR policy

B Corporate governance 12.3 11.0 C Human rights 10.7 10 10.0 D Employment relationships 9.0 E Environmental protection

CONTENT F CSR integration in the supply chain

G Responsible consumption 6.0 5.2 5 5.5 5.3 H Community relations 4.8 4.4 The companies analyzed in this report disclose infor- 4.0 4.0 4.0 4.0 3.9 I Management and company leadership mation regarding their corporate governance policies, 3.0 2.5 3.4 3.0 employee relationships, environmental protection ini- 2.3 2.8 J Reporting 2.2 1.4 1.3 2.7 tiatives, and community relations the most frequently 1.5 1.1 1.4 on their respective websites. K Navigation 0.8 0.8 0.3 0.7 0.4 Human rights policies, level of CSR integration in sup- L Accessibility ply chains, and corporate leadership information are A B C D E F G H I J K L disclosed on companies’ websites the least. Maximum score The ten companies with the highest levels of transpar- ency in the Company Transparency Index 2019 disclose Average level of Transparency Index 2019 twice as much information in the Index Content and Re- porting categories than the other companies analyzed. Top 10 COMPANY TRANSPARENCY INDEX 2019 UKRAINE 7 DISCLOSURE LEVEL

BY CATEGORY 24 companies placed 13 companies included 33 companies information about information about placed their mission, values, mission, values, and codes of and vision on their vision in their non- ethics on their websites financial reports websites

GENERAL INFORMATION ABOUT THE COMPANY AND ITS CSR POLICY

7companies 26 companies, most of 20 companies mentioned the them were state- reported CSR existence of ethical owned, placed strategies or codes in their their development CSR goals on nonfinancial reports strategies on their their websites websites The largest Ukrainian companies typically place their company’s general information, profile, and, quite often, the company’s history and awards on their corporate websites. The practice of placing mission, goals, and strategy is not yet commonplace in the Ukrainian business environment. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 9 GENERAL INFORMATION Notably, only two companies, PJSC “ArcelorMittal Kryvyi 2 ABOUT THE COMPANY Rih,” and JSC “Ukrgasvydobuvannya,” contain Sustainable AND ITS CSR POLICY Score, max Development Policies as approved documents. PrJSC Carlsberg Ukraine and JSC “Ukrgasvydobuvannya” created their CSR strategies and CSR goals in line with the UN’s Sustainable Development Goals.

PrJSC Carlsberg Ukraine announced its Together Towards ZERO program in 2017, 1 a new sustainable development strategy of Carlsberg Group global company that Companies with highest contains four strategic goals: ZERO carbon footprint, ZERO water waste, ZERO irre- levels of general information 0.7 sponsible drinking, and ZERO accidents culture. In April 2020, JSC “Ukrgasvydobu- about the organizations and vannya” approved the Corporate Social Responsibility Policy of JSC “Ukrgasvy- their CSR policies 0.4 dobuvannya” in Relations with Commu- nities, Charitable and Non-governmental 0.3 Organizations. The initiative tracks the company’s progress towards achieving the 9 UN’s Sustainable Development Goals. 0.05 0.8 PrJSC Carlsberg The website of LLC “Lemtrans”, a company apart of the Ukraine SCM Group, contains the SCM Group’s Sustainable Devel- A B C D E opment Policy. Some companies provide information about their sus- tainable development strategies in their non-financial 7 Number Number 7.5 reports (e.g. JSB “Ukrgasbank”). JSC “Alfa-Bank” Other companies’ non-financial reports only contain companies of 20 general information about the significance of other com- 26 panies’ CSR policies. 37 A Mission and vision, values The integration of the UN’s Sustainable Development 40 B Company strategy Goals in Ukrainian companies’ CSR policies is extremely Maximum score 7 low. C CSR strategy or CSR goals LLC “Lemtrans” Seven Ukrainian companies mentioned the UN’s Sus- Average score of companies involved in the D Integration of the Sustainable Max possible score = 9 tainable Development Goals on their corporate website assessment Development Goals in the company’s CSR pages, and only two of them disclosed their clear com- strategy/goals (commitments) mitments to achieving the goals. Number of companies having placed relevant information E Code of ethics COMPANY TRANSPARENCY INDEX 2019 UKRAINE 11 CORPORATE Score, Score, max

2 GOVERNANCE Information disclosure level in the Corporate Governance component

A Ownership structure: owners and beneficiaries B Company governance: governing bodies and their functional 1.1 responsibilities (Management Board, Board of Directors, Corporate Secretary) 1 C Membership of Board of Directors/Supervisory Board (informa- tion about members, independent members) 75 companies in the D Code (principles) of corporate governance 0.75 E Information for investors (reports, minutes, announcements, 0.64 Transparency presentations, etc.) Index 2019 placed F Policy on wages, bonuses and rewards for supervisory board 0.5 and management 0.4 0.4 information G Corporate social responsibility governance (entities or persons regarding corporate responsible for implementation of the CSR policy/strategy) 0.3 0.3 0.2 0.2 governance policies H Entity performing compliance functions, including existence of a committee for compliance and/or ethics within the 0.03 0.08 on their websites supervisory board 0.01 I Anti-corruption programme/policy A B C D E F G H I J K L M

J Commissioner for anti-corruption programme K Communication channels for reporting of breaches (hotline, etc.) 4 1 5

L 37001 standard certification Number 14 12 M Stakeholder engagement plan 16 of companies of 23 30 Maximum score 34 35 Average score of companies involved in the 39 The companies usually disclose information about assessment 49 their governing bodies, management, and the elimina- tion of corruption for shareholders and investors. Number of companies having placed relevant information 62 COMPANY TRANSPARENCY INDEX 2019 UKRAINE 13 CORPORATE GOVERNANCE

ISO 29 сompanies disclose 12 companies 2 companies information placed corporate mentioned 37001 regarding the governance codes the existence Anti-Bribery Management breaches of anti- on their websites, of corporate Systems corruption channels including four state- governance codes and codes of ethics/ owned enterprises in their nonfinancial business conduct reports on their website

Some companies mention the existence of an anti-cor- ruption program, a commissioner for anti-corruption programs, and available communication channels in their Management Reports. The information disclo- sure level concerning the implementation of compa- nies’ anti-corruption programs is also low. In 2019, only JSC “Ukrainian Railways,” NNEGC “Energoatom,” PrJSC “Ukrhydroenergo,” SE “Ukraine Sea Port Author- company placed companies provided ity,” JSC CB “Privatbank,” and SC “” posted 7 companies, provide 1 10 the results of anti-corruption implementation on their their respective information about information about websites. Only PJSC “Credit-Agricole Bank” provided rewards to its data regarding certification of the ISO 37001 standard, commissioners for rewards to its “Anti-bribery management systems – Requirements anti-corruption management staff management staff with guidance for use,” on the website. In our opinion, in supervisory board disclosures on the prevention of corruption are higher programs’ contact on the website among state-owned enterprises and banks compared to (JSC “NJSC reports or securities other companies due to the approval of relevant regula- information on their tory documents. websites “ of issuer reports The publication of information regarding rewards to Ukraine”) management staff is a relatively new concept to the Ukrainian business environment. Only JSC “NJSC “Naf- togaz of Ukraine” placed this information on its website. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 15 CORPORATE Companies with GOVERNANCE highest disclosure levels for the Corporate Governance component 11 companies, seven 12 companies provided being state-owned, information about placed information company ownership 16 about company structure in the JSB “Ukrgasbank” ownership structure non-financial on their corporate reports websites 15.5 PrJSC “Ukrhydroenergo”

5 companies 4 companies published their mentioned The practice of disclosing information concerning own- ership structure, the establishment of corporate social stakeholder departments or responsibility governance structures, and stakeholder engagement is not common in the Ukrainian compa- engagement plans persons responsible nies’ corporate governance system. 15.5 on their corporate for their CSR policies JSC “First Ukrainian Only 5 companies, JSB “Ukrgasbank,” JSC Ukrtransnafta, websites on their corporate PJSC “ArcelorMittal ,” JSC “Ukrainian Rail- International Bank” ways,” and NNEGC “Energoatom” published their stake- websites holder engagement plans. JSC “First Ukrainian Interna- tional Bank,” JSC “Ukrainian Railways,” NPC “Ukrenergo,” and JSC “Farmak” mentioned departments or persons responsible for their CSR policies on their corporate website pages. Max possible score = 22 COMPANY TRANSPARENCY INDEX 2019 UKRAINE 17 CONCLUSIONS

Companies demonstrating the highest levels of transparency of their 25,5 % corporate websites The website transparency JSB “Ukrgasbank” level of the PrJSC Carlsberg Ukraine largest taxpaying JSC “First Ukrainian International Bank” companies in 2019 NNEGC “Energoatom” JSC “NJSC “Naftogaz of Ukraine” NPC “Ukrenergo” PJSC “ArcelorMittal Kryvyi Rih” PrJSC “Ukrhydroenergo” JSC “Farmak” 52,3 % JSC “Ukrainian Railways” Level of information disclosure of TOP 10

Ukrainian companies do not regard corporate websites companies of as an effective tool of transparency or an efficient Transparency Index stakeholder of communication channels. The fact that the companies analyzed in this report provide more 2019, 6 of them are information about their CSR policies or CSR practices state property rather than the implementation of CSR policies and practices supports this conclusion. Implementation results of CSR policies and practices are most often provided by the companies in their non-financial and management reports. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 19 CONCLUSIONS

The level of preparation The integration of of non-financial reports the UN’s Sustainable and management Development Goals reports in 2019 remains into the companies’ extremely low and is CSR strategies and the lowest out of all non-financial reporting the years for which the remains low. Companies disclose information regarding their policies and programs concerning environmental protection, Transparency Index employee relationships, community relations, and some corporate governance aspects (company management, was prepared. membership of supervisory boards, information for in- vestors, anti-corruption programs) the most frequently. There is no information (perhaps, no implementation practice as well) regarding the protection of human Only 7 Ukrainian companies mentioned the Sustainable rights, CSR integration in the supply chain, and manage- Development Goals on their corporate website pages, ment and company leadership. whereas ten companies, including five of the abovemen- tioned seven, included information regarding the com- Only 6 companies published their 2019 nonfinancial panies’ contributions towards achieving the Sustainable reports on their websites. Companies most likely post- Development Goals in their non-financial reports for poned the deadlines of non-financial reporting due to 2019. the COVID-19 pandemic and the lack of normative and legal regulation influenced the collection and analysis of management reports. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 21 CONCLUSIONS The highest disclosure Company Transparency level is demonstrated Index 2019 TOP-10 by companies in finance sector, transportation, and electricity Position Company name Activity of Form ownership Score

Finance and insurance activities State-owned 1 JSB “Ukrgasbank” S 62.5 2 Private Joint Stock Company Carlsberg Ukraine Manufacturing. Manufacture of enterprises have 4 of the 9 companies beverages P 60 in finance sector are higher indicators 3 Joint Stock Company “First Ukrainian Finance and insurance activities state-owned International Bank” P 55.5 of transparency 4 State Enterprise “National Nuclear Energy Electricity, gas, steam and air conditioning supply S 53 than private Generaing Company “Energoatom” 5 Joint Stock Company “National Joint Stock Professional, scientific and tech- companies Company “Naftogaz of Ukraine” nical activities S 52 8 of the 11 6 Private Joint Stock Company “National Power Electricity, gas, steam and air conditioning supply 50 in every companies in Company “Ukrenergo” S transportation are 7 PJSC “ArcelorMittal Kryvyi Rih” Manufacturing. Manufacture of Transparency basic metals P 49.5 state-owned Index component 8 Private Joint Stock Company “Ukrhydroenergo” Electricity, gas, steam and air conditioning supply S 48 9 Joint Stock Company “Farmak” Manufacturing. Manufacture of pharmaceuticals 47 and pharmaceutical materials P

10 Joint Stock Company “Ukrainian Railways” Transportation and storage, 5 of the 9 companies postal and courier activities S 46 in electricity sector More than a half of the companies among the Trans- parency Index Top 10 are state-owned. In our opinion, are state-owned this is a positive sign of corporate governance reform in Ukrainian state-owned enterprises. S P The highest disclosure level is demonstrated by compa- nies in financial sector, transportation, and electricity, state private many of them are state-owned. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 23 1 2 3 4 5 6 7 8 9 10 11 12 13 13 15 16 17 18 18 18 21 21 23 24 24 Company Transparency24 Index 27 28 28 1 30 2 3 31 4 31 5 2019 Results 6 31 31 7 1 8 2 35 9 3 35 10 4 35 11 5 35 12 13 6 39 13 7 40 15 8 62.5 JSB “Ukrgasbank” 1 S 40 16 9 42 17 Private Joint Stock Company Carlsberg Ukraine 22 P 10 60.0 18 11 42 18 Joint Stock Company “First Ukrainian International Bank” 33 P 55.512 44 18 Private Property 13 45 21 21 63 companies State Enterprise “National Nuclear Energy Generaing Company “Energoatom” 44 S 53.013 45 15 23 47 Average score 22.7 Joint Stock Company “National Joint Stock Company “Naftogaz of Ukraine” 55 S 52.016 24 17 47 24 Company Transparency24 Index 18 49 Private Joint Stock Company “National Power Company “Ukrenergo” 6 S 50.0 27 6 18 50 28 PJSC “ArcelorMittal Kryvyi Rih” 77 P 49.5 18 51 28 21 52 30 21 Private Joint Stock Company “Ukrhydroenergo” 8 S 48.0 52 State Property 31 8 23 31 54 2019 23 Resultscompanies Joint Stock Company “Farmak” 9 P 47.0 24 31 9 24 54 Average score 32.7 31 Company Transparency24 Index56 35 Joint Stock Company “Ukrainian Railways” 1010 S 46.0 27 56 35 35 28 58 Joint Stock Company “State Savings Bank Of Ukraine” 1111 S 43.5 28 35 59 39 30 40 “New Post” Limited Liability Company 12 P 42.5 31 60 62.5 12 JSB “Ukrgasbank” 1 S 40 31 60 2019 Results Private Joint Stock Company Carlsberg Ukraine 22 P 60.0 42 Joint-Stock Company “Alfa-Bank” 1313 P 42.0 31 62 42 31 Joint Stock Company “First Ukrainian63 International Bank” 33 P 55.5 44 Private Property Joint-Stock Company Commercial Bank “Privatbank” 1313 S 42.0 35 63 45 State Enterprise “National Nuclear Energy Generaing Company “Energoatom” 53.0 63 companies 35 65 44 S 45 Joint Stock Company “Ukrsibbank” 1515 P 41.0 35 47 Average score 22.7 Joint35 Stock Company “National Joint Stock Company66 “Naftogaz of Ukraine” 55 S 52.0 47 Joint-Stock Company “Credit-Agricole Bank” 16 P 38.5 39 Private Joint Stock Company “National Power66 Company “Ukrenergo” 6 S 50.0 49 16 6 50 JSB “Ukrgasbank” 62.5 40 66 1 S 40 PJSC “ArcelorMittal69 Kryvyi Rih” 77 P 49.5 51 Limited Liability Company “ Yeristovo Mining” 1717 P 37.5 52 COMPANY 42 Private Joint Stock Company Carlsberg Ukraine 22 P 60.0 Private Joint Stock Company69 “Ukrhydroenergo” 48.0 52 State Property Mining and quarrying 42 88 S Limited Liability Company “Lifecell” 1818 P 34.0 69 54 by property5 5 23 companies 44

14 companies 15 15 Joint Stock Company “First Ukrainian International Bank” 55.5 47.0 10 10 35 35 3 P Joint Stock Company “Farmak” 9 P 25 25 45 45 30 30 3 9 20 54 20 Transparency72 level Private40 Property Average score 32.740 45 Private Joint Stock Company “Abinbev Efes Ukraine” 1818 P Average 34.0 score 24.0 72 63 companies 56 State Enterprise “National Nuclear Energy Generaing Company “Energoatom” 44 S 53.0 45 Joint Stock Company “Ukrainian Railways” 1010 S 46.0 56 Average score 22.7 TRANSPARENCY INDEX Joint Stock Company “Ukrgasvydobuvannya” 1818 S 34.0 47 Joint Stock Company “State Savings72 Bank Of Ukraine” 1111 S 43.5 58 Joint Stock Company “National Joint Stock Company “Naftogaz of Ukraine” 55 S 52.0 47 72 59 49 “New Post” Limited Liability Company 12 P 42.5 type60 Private Joint Stock CompanyPrivate “National Joint Stock Power Company Company “Ukrenergo”“Central Iron6 6OreS Enrichment Works” 21 21 P 50.0 32.0 76 12 50 77 60 51 Joint-Stock Company “Alfa-Bank” 1313 P 42.0 62 PJSC “ArcelorMittal Kryvyi Rih” 77 P 49.5 32.0 77 Auchan Ukraine Hypermarket LLC 2121 P 52 63 2019 RESULTS Joint-Stock Company Commercial77 Bank “Privatbank” 1313 S 42.0 63 Private Joint Stock Company “Ukrhydroenergo” 8 S 48.0 52 State Property 8 65 Private Joint Stock Company “Azovstal Iron And Steel Works” 2323 P 31.5 54 Joint Stock 80Company “Ukrsibbank” 41.0 23 companies 1515 P 66 Joint Stock Company “Farmak” 99 P 47.0 54 81 Public Joint-Stock Company “Dneprovsky Iron & Steel Integrated Works” 2424 P 30.5 Joint-Stock CompanyAverage “Credit-Agricole score 32.7 Bank” 1616 P 38.5 66 Joint Stock Company “Ukrainian Railways” 10 S 46.0 56 82 66 10 56 by industry Limited Liability Company “Ferrexpo82 Yeristovo Mining” 1717 P 37.5 69 Public Joint Stock Company “Integrated Iron And Steel Works “” 2424 P 30.5 58 Joint Stock Company “State Savings Bank Of Ukraine” 1111 S 43.5 82 Mining and quarrying 69 59 Limited Liability Company “Lifecell” 1818 P 34.0 69 5 5

14 companies 15 15

85 10 10 35 35 25 25 45 45 30 30 20 20 “New Post” Limited LiabilityState Company Enterprise1212 “Ukrkhimtransamiak”P 24 24 S 42.5 30.5 60 72 40 40 60 Private Joint Stock Company 85“Abinbev Efes Ukraine” 1818 P Average 34.0 score 24.0 72 Joint-Stock CompanyPrivate “Alfa-Bank” Joint13 13StockP Company Kyivstar 27 27 P 42.0 30.0 62 Joint Stock Company “Ukrgasvydobuvannya” 1818 S 34.0 72 63 72 Joint-Stock Company CommercialInhuletskyi Bank “Privatbank” Mining and13 13ProcessingS Works PrJSC 28 28 P 42.0 29.0 63 WholesalePrivate Joint and Stock retail Company trade “Central and repairIron Ore Enrichment Works” 2121 P 32.0 Electricity, gas, steam and76 air 65 77 Joint Stock Company “Ukrsibbank” 15 P 41.0 Auchan Ukraine Hypermarket LLC 21 P 32.0 77 15 28 29.0 66 of motor vehicles and motorcycles 21 conditioning supply State Enterprise “Ukraine Sea Port Authority” 28 S 77 66 Joint-Stock Company “Credit-Agricole Bank” 1616 P 38.5 10 companiesPrivate Joint Stock Company “Azovstal Iron And Steel Works” 2323 P 31.5 9 companies 80 Joint Stock Company “Odessaoblenergo” 3030 P 28.5 66 81 Public Joint-Stock Company “Dneprovsky Iron & Steel Integrated Works” 24 P 30.5 Limited Liability Company “Ferrexpo Yeristovo Mining” 1717 P 37.5 69 Average score 12.0 24 Average score 29.0 82 Private Joint Stoc Company “A/T B.A.T.-Prilucky Tobacco Company” Mining3131 andP quarrying 28.0 Public69 Joint Stock Company “Integrated Iron And Steel Works “Zaporizhstal” 2424 P 30.5 82 Limited Liability Company “Lifecell” 1818 P 34.0 69 82 5 5

14 companies 15 15 10 10 35 35 25 25 45 45 30 30 20 20 Private Joint Stock Company “Northern Iron Ore Enrichment Works” 3131 P 28.0 7221 State Enterprise “Ukrkhimtransamiak”Manufacture of40 24beverages24 S 30.5 4 40 85 Private Joint Stock Company “Abinbev Efes Ukraine” 1818 P Average 34.0 score 24.0 72 85 63 Private Joint Stock Company Kyivstar 27 P 30.0 Joint Stock Company “Ukrgasvydobuvannya” 18Ferrexpo18 S Mining 31 34.031 P 28.0 72 5 companies 27 6 7266 Inhuletskyi Mining and Processing Works PrJSC 2828 P 29.0 Wholesale8 and retail trade and repair Electricity, gas, steam and air 76 Average score 25.8 Repair and technical Private Joint Stock Company “Central Iron Ore Enrichment Works” 2121 P PJSC 32.03131 S 28.0 69 30 77 State Enterprise “Ukraine Sea Port Authority” 2828 S 29.0 of motor vehicles and motorcycles maintenance of industrial conditioning supply Private Joint StockAuchan Company Ukraine “IlyichHypermarket Iron And LLC Steel2121 PWorks Of ” 32.035 P 27.5 7772 1044 companies 9 companies 35 77 Joint Stock Company2 “Odessaoblenergo” 3030 P 28.5 Private Joint Stock Company “Azovstal Iron And Steel Works” 23 P 31.5 72 Average47 score 12.0 machinery and equipmentAverage score 29.0 23 80 Private Joint Stoc Company “A/T B.A.T.-Prilucky18 Tobacco Company” 31 28.0 Public Joint Stock Company “Interpipe Nizhnedneprovsky Tube Rolling Plant” 3535 P 27.5 72 31 P 60 Public Joint-Stock Company “Dneprovsky Iron & Steel Integrated Works” 2424 P 30.5 81 47 1 companies 8277 Private Joint Stock Company “Northern Iron Ore Enrichment Works” 3131 P 28.0 21 Manufacture of beverages 4 Stock Company “Ukrposhta” 3535 S 27.5 82 Manufacture 76 Average score 12.0 Public Joint Stock Company “Integrated Iron And Steel Works “Zaporizhstal” 2424 P 30.5 82 63 5 companies 6 8277 Ferrexpo Poltava Mining 3131 P 28.0 77 35 82 of tobacco products 66 8 Private Joint-Stock Company “Kyivvodokanal” 30.535 P 27.5 85 Average score 25.8 Repair and technical State Enterprise “Ukrkhimtransamiak” 2424 S 85 Ukrnafta PJSC 3131 S 28.0 69 66 30 85 3 companies 72 maintenance of industrial Private Joint Stock CompanyPrivate KyivstarJoint Stock2727 CompanyP “VF Ukraine” 30.03939 P 27.0 Private Joint Stock Company “Ilyich Iron And Steel Works Of Mariupol” 3535 P 27.5 2 44 72 Average score 21.0 Water supply;18 sewerage, 47 machinery and equipment Inhuletskyi Mining and Processing Works PrJSC 2828 P 29.040 25.5 Public Joint Stock Company “Interpipe Nizhnedneprovsky Tube Rolling Plant” 3535 P 27.5 72 Boryspil International Airport SE 40 S Wholesale and retail trade and repair Electricity, gas, steam and air 47 60 1 companies 77 waste management State Enterprise “Ukraine Sea Port Authority” 2828 S 29.0 of motor vehicles and motorcycles Information and Stock Company “Ukrposhta”conditioning3535 S supply 31 27.5 82 Manufacture 76 Average score 12.0 Joint Stock Company Ukrtransgaz 4040 S 25.5 77 77 10 companies Private Joint-Stock Company “Kyivvodokanal”9 companies35 P 27.5 1 companies 82 of tobacco products Joint Stock Company “Odessaoblenergo” 3030 P 28.5 communication 35 42 85 The State Export Import Bank of Ukraine JSC 42 S 25.0 3 companies 66 42 Average score 12.0 Private Joint Stock Company “VF Ukraine”Average3939 P score 72 29.0 27.0 Average score 27.5 Private Joint Stoc Company “A/T B.A.T.-Prilucky Tobacco Company” 3131 P 28.0 4 companies Average score 21.0 Water supply; sewerage, Imperial Tobacco Production Ukraine JSC 4242 P 25.0 Boryspil International Airport SE 4040 S 25.5 Private Joint Stock Company “Northern Iron Ore Enrichment Works” 3131 P 28.0 21 AverageManufacture score of 27.0beverages 4 35 waste management 40 25.5 Information and 31 PJSC 4444 S 63 24.5 Joint Stock Company Ukrtransgaz6 40 S 1 companies Ferrexpo Poltava Mining 3131 P 28.0 5 companies 42 Приватна 66 42 communication 18 Average score 25.8 The State Export Import Bank of Ukraine JSC8 42 S 25.0 72 Average score 27.5 DonetsksteelUkrnafta PJSC Iron3131 andS Steel Works PrJSC 28.04545 P 24.0 Repair4 companies and technical 69 27 Imperial Tobacco Production Ukraine30 JSC 4242 P 25.0 Finance and insuranceформа activities власності 72 maintenanceAverage score of27.0 industrial Private Joint Stock Company “Ilyich Iron And Steel Works Of Mariupol” 3535 P Company 27.54545 S 24.0 392 44 35 72 Centrenergo PJSC47 4444 S 24.5 machinery and equipment 9 companies Приватна 6218 63 компанії Public Joint Stock Company “Interpipe Nizhnedneprovsky Tube Rolling Plant” 3535 P 27.547 72 18 Private Joint-Stock Company “Obolon” 47 P 23.0 47 Donetsksteel Iron and Steel Works PrJSC60 4545 P 24.0 1 companies Average score 40.9 35 27.5 77 76 27 Finance and insuranceформа activities власності Stock Company “Ukrposhta” 35 S 82 Manufacture Antonov Company 4545 S 24.0 39Average score 12.0 DTEK Grids Joint-Stock Company 4747 P 77 23.0 77 Середній Індекс 22,7 9 companies 35 27.5 82 of tobacco products 62 63 компанії Private Joint-Stock Company “Kyivvodokanal” 35 P 85 Private Joint-Stock Company “Obolon” 4747 P 23.0 Manufacture 1 Average score 40.9 “Turboatom” Joint Stock Company 4949 S 22.5 3 companies 66 Private Joint Stock Company “VF Ukraine” 3939 P 27.0 DTEK Dnipro Grids Joint-Stock Company 4747 P 23.0 of pipes 3 Середній Індекс 22,7 JV Poltava Company 50 P 22.0 Average score 21.0 Water supply; sewerage, 11 Manufacture 1 Boryspil International Airport SE 4040 S 25.5 50 Manufacture “Turboatom” Joint Stock Company 4949 S 22.5 1 companies waste management 13 of pipes 3 51 21.5 50 22.0 11 Joint Stock CompanyLimited Ukrtransgaz Liability4040 CompanyS “Lemtrans” 25.5 51 P Information and of engines and turbines31 JV Poltava Petroleum Company 50 P Manufacture Average score 27.5 13 1 companies 1 companies 13 communication 42 Limited Liability Company “Lemtrans” 51 P 21.5 The State ExportPrivate Import Bank Joint of Stock Ukraine Company JSC 4242 “AvdiivkaS Coke Plant” 25.0 52 P 21.0 1 companies 51 Average score 27.5 of engines and turbines 15 Average score 27.5 13 52 72 35 4 companies Private Joint Stock Company “ Coke Plant” 5252 P 21.0 1 companies 16 15 Imperial Tobacco Production Ukraine JSC 42 P 25.0 Average scoreДержавна 22.5 35 Private Joint Stock Company “Mining Company42 “Ukrnaftoburinnya” 5252 P Average 21.0 score 27.0 Average score 22.5 16 Private Joint Stock Company “Mining Company “Ukrnaftoburinnya” 5252 P35 21.0 Державна 42 Centrenergo PJSC 4444 S 24.5 49 42 Roshen Confectionery Corporation Subsidiary Company 5454 P 20.0 49 Приватна 59 18 Roshenформа Confectionery власності Corporation Subsidiary Company 5454 P 20.0 форма власності 59 Donetsksteel Iron and Steel Works PrJSC 4545 P 24.0 Private Joint Stock Company “Zaporizkyi Iron-Ore Plant” 5454 P 27 20.0 Private Joint Stock Company “Zaporizkyi Iron-Ore Plant” 5454 P 20.0 Finance and insuranceформа activities власності Antonov Company 4545 S 24.0 39 23 компанії 23 компанії Ukraine Printing Plant 56 S 19.0 Ukraine Printing Plant 5656 S 19.0 9 companies Private Joint-Stock Company “Obolon” 47 P 23.0 56 62 Середній63 компанії Індекс 32,7 47 Середній ІндексKryvbaszalizrudkom 32,7 PJSC 5656 P 19.0 Average score 40.9 Kryvbaszalizrudkom47 23.0PJSC 5656 P 19.0 Manufacture of cokeСередній and Індекс 22,7 Professional, scientific and DTEK Dnipro Grids Joint-Stock Company 47 P Joint Stock Company Ukrtransnafta 5858 S 18.5 Manufacture of coke and Manufacture 1 refined petroleum products Professional, scientific and technical activities “Turboatom” Joint StockJoint Company Stock49 49CompanyS Ukrtransnafta 22.5 5858 S 18.5 59 refined petroleum productsRaiffeisen Bank Aval Joint Stock Company 59 P 18.0of pipes 3 2 companies technical activities 2 companies JV Poltava PetroleumRaiffeisen Company Bank Aval5050 JointP Stock Company 22.0 5959 P Manufacture 18.0 Enerhorynok SE 6060 S 17.51 companies 11 Average score 16.0 Average score 28.5 2 companies 13 2 companies Limited Liability Company “Lemtrans” 5151 P 21.5 of engines and turbines Ivano-Frankivskcement PrJSC 6060 P 17.5Average score 27.5 Average Enerhorynok SE 60 S 17.5 13 5 60 Average score 16.0 52 Average scorescore 28.5 in Private Joint Stock Company “” 5252 P 21.0 1 companies PJSC 6262 P 17.0 15 actual 85 60 35 69 Ivano-Frankivskcement PrJSC 60 P 17.5 Average 16 activity Private Joint Stock Company “Mining Company “Ukrnaftoburinnya” 52 P 21.0 Average scoreДержавна 22.5 JSC 6363 P 15.0 5 52 52 score in 42 Ukrtelecom PJSC 6262 P 17.0 63 P 15.0 actual 85 Roshen Confectionery Corporation Subsidiary Company 5454 P 20.0 49 форма власності69 Limited Liability Company “Epicentr K” 63 59 5 63 65 13.0 activity Accommodation and food Private Joint Stock Company “Zaporizkyi Iron-Ore Plant” 5454 P Motor Sich 20.0 JSC 63 P 15.0 DTEK Pavlohradcoal Private Joint-Stock Company 65 P 10 23 компанії 66 12.0 service activities 15 56 63 P 15.0 Company “Colliery Group “Pokrovs’ke” 66 P Publishing, printing and Ukraine PrintingLimited Plant Liability56 CompanyS “Epicentr 19.0 K” 63 5 1 companies 20 Середній Індекс 32,7 Limited Liability Company “-Promservice” 6666 P 12.0 reproduction of recorded media DTEKKryvbaszalizrudkom Pavlohradcoal PJSC Private5656 Joint-StockP Company 19.0 6565 P 13.0 Accommodation and food 10 Average score 7.0 25 Manufacture of coke and Limited Liability Company “Tedis Ukraine” 6666 P 12.0 Professional, scientific and 1 companies 58 service activities 81 30 Joint Stock Company UkrtransnaftaCompany “Colliery58 S Group “Pokrovs’ke” 18.5 6666 P 12.0 69 15 Average score 19.0 refined petroleum products 1 companies Ukrtatnafta PJSC 69 P 11.0 technical activities Publishing, printing35 and Raiffeisen Bank Aval Joint Stock Company 5959 P 18.0 69 20 Limited Liability Company “Metinvest-Promservice” 6666 P 12.02 companies Joint-Stock Company “Yuzhniy GOK” 69 P 11.0 2 companies reproduction40 of recorded media 56 60 S 17.5 Average score 7.0 25 Manufacture of other 45 Enerhorynok SE 60 66 Average score 16.0 Toyota-Ukraine CFI 6969 P 11.0 Average score 28.5 Limited Liability Company “Tedis Ukraine” 66 P 12.0 transport equipment 1 companies50 Manufacture of cement, Ivano-Frankivskcement PrJSC 6060 P 17.5 81 Average 72 30 PrJSC “Philip Morris Ukraine” 72 P 10.0 5 1 companies lime and plaster Ukrtatnafta PJSC 69 P 11.052 score in Average score55 19.0 Ukrtelecom PJSC 62 P 17.0 69 72 35 85 1 companies 62 69 Energy Service Companyactual “ESCO-PIVNICH” 72 P 10.0 Average score 15.0 Manufacture 60 Mining and quarrying 69 activity 40 MotorJoint-Stock Sich JSC 6363 CompanyP “Yuzhniy 15.0 GOK” 69 P 11.0 Limited Liability Company “Philip Morris Sales And Distribution” 7272 P 10.0 of food products 56 65 Average score 17.5 14 companies Manufacture of other 63 1 companies Average score 24.0 Limited Liability Company “Epicentr K” 6363 PToyota-Ukraine 15.0 CFI 69 P 11.0 METRO Cash & Carry Ukraine LLC 7272 P 10.0 45 60 69 transport equipment 5 Manufacture of cement,Average score 20.0 76 50 Transportation and storage, 17 DTEK Pavlohradcoal Private Joint-Stock Company 6565 P 13.0 72 Accommodation and food Private Joint Stock Company10 “Kyivoblenergo” 76 P 9.0 PrJSC “Philip Morris Ukraine” 72 P 10.0 lime and plaster54 service activities 1 companies 77 8.0 55 postal and courier activities Construction 18 66 P 12.0 DTEK Westenergy15 Joint-Stock Company 77 P 21 Company “Colliery GroupEnergy “Pokrovs’ke” Service Company66 “ESCO-PIVNICH” 72 P 10.0 Average score 15.0 Manufacture Publishing,10 companies printing and1 companies Mining and quarrying 1 companies 72 1 companies 20 77 P 8.0 60 28 Limited Liability Company “Metinvest-Promservice” 66 P 12.0 ATB Market LLC 77 Average score 29.8 Average score 7.0 No score companies 66 Average score 7.0 of food products reproduction of recordedAverage media score 17.5 14 companies 31 Limited Liability Company “Philip Morris Sales And Distribution” 7272 P 10.0 DTEK Trading Limited25 Liability Company 77 P 8.0 65 Manufacture of basic metals 66 12.0 63 77 1 companies 80 31 Limited Liability Company “Tedis Ukraine” 66 P 30 1 companies 10 7 companies Average score 24.0 81 80 P 7.0 DTEK Dniproenergo31 Joint- Stock Company METRO Cash & Carry Ukraine LLC 7272 P 10.0 Limited Liability Company “Podilskiy Energoconsulting” 80 12Average score 19.0 60 П Ukrtatnafta PJSC 6969 P 11.0 35 Average score 28.5 50 McDonald’s UkraineAverage Ltd score81 P 20.0 7.0 24 Limited Liability Company Logistyk Union 76 9.0 Transportation and storage, 81 17 52 П Joint-Stock CompanyPrivate “Yuzhniy Joint Stock GOK” Company6969 P “Kyivoblenergo” 11.0 76 P 40 5628 Manufacture of pharmaceuticals Limited Liability Company “Metallurgical Plant “Dneprosteel” 82 P 6.0 7 Private Joint Stock Company54 “Natural Resources” Manufacture of other postal and courier activities 45 54 82 35 Construction 18 and pharmaceutical materials П Toyota-UkraineDTEK Westenergy CFI 69 Joint-StockP 11.0 Company 77 P 8.0 23 56 69 77 transport equipment Limited Liability Company “Global Spirits Group” 82 P 6.0Manufacture of cement, 40 21 Napoi Plus LLC 10 companies 50 82 1 companies 24 1 company 65 П PrJSC “Philip Morris Ukraine” 72 P 10.0 40 24 72 ATB Market LLC 7777 P 8.0 1 companies Limited Liability Company “LVN Limited” 82 P 6.0lime and plaster 28 Average score 47.0 DTEK66 Dobropillyavuhillya LLC Average score 29.8 55 82 45 Average score 7.0 П Energy Service Company “ESCO-PIVNICH” 72 P 10.0 Average score 15.0 Manufacture Manufacture of 85basic metals1 companies Mining and quarrying 35 31 69 72 77 P 8.0 SE “State Kyiv60 Design Bureau “Luch” 85 S 5.0 51 45 Naftogazvydobuvannya PrJSC DTEK Trading Limited Liability Company 77 31 9 П 72 of food products Average score 17.5 5814 companies 80 82 Limited Liability Company “Philip Morris Sales And Distribution” 72 P 10.0 63 10 Limited Liability 65Company7 companies “Silpo-Food” 8585 P 5.0 Google LLC Limited Liability Company “Podilskiy Energoconsulting” 8080 P 7.0 1 companies Average score 24.0 31 П 72 10.0 12 Average score 28.5 60 METRO Cash & Carry Ukraine LLC 72 P 50 JT International Ukraine PJSC П McDonald’s Ukraine Ltd 8181 P 7.0 Transportation and storage, 24 Average score 20.0 Private Joint Stock Company “Kyivoblenergo” 7676 P 9.0 17 52 Ukrainian Distribution Company LLC 28 7 Manufacture of pharmaceuticals П Limited Liability Company “Metallurgical77 Plant 8.0 “Dneprosteel” 8282 P 6.0 postal and courier activities 54 Construction 18 54 DTEK Westenergy Joint-Stock Company 77 P 35 21 and pharmaceutical materials PJSC “DTEK Skhidenergo” 10 companies 23 1 companies 56 П Limited LiabilityATB Market Company LLC 77 “GlobalP 8.0 Spirits Group” 82 P 6.0 40 28 77 82 Average score 29.8 24 Average score 7.0 1 company 65 Ukrgasvydobutok PrJSC П 77 P 8.0 82 40 Manufacture of basic metals 24 31 DTEK Trading Limited LiabilityLimited Company Liability77 Company “LVN Limited” 82 P 6.0 31 Average score 47.0 66 Vynnyky Tobacco Factory LLC П 10 45 7 companies 35 80 Limited Liability Company “Podilskiy Energoconsulting” 80 P 7.0 31 69 National Vodka Company LLC SE “State Kyiv80 Design Bureau “Luch” 85 S 5.0 12 51 П 85 Average score 28.5 45 50 9 McDonald’s Ukraine Ltd 81 P 7.0 24 JT International Company Ukraine JSC 81 85 58 82 52 П Limited Liability Company “Silpo-Food” 85 P 5.0 28 Manufacture of pharmaceuticals Limited Liability Company “Metallurgical Plant “Dneprosteel” 82 P 6.0 7 54 82 35 and pharmaceutical materials 23 56 Limited Liability Company “Global Spirits Group” 82 P 6.0 40 82 24 1 company 65 40 Limited Liability Company “LVN Limited” 82 P 6.0 24 Average score 47.0 66 82 45 35 69 Scan for full resolution 85 S 5.0 51 SE “State Design Bureau “Luch” 85 45 9 Limited Liability Company “Silpo-Food” 8585 P 5.0 58 82 diagram COMPANY TRANSPARENCY INDEX 2019 UKRAINE 25 Corporate Governance professional Association (CGPA) was established in Kyiv, Ukraine, in 2009 as a non-government organization and currently ranks as a leading expert community and center for generating corporate governance reform in Ukraine. It unites more than 160 specialists in corporate governance and corporate law. CGPA Mission is to help Ukrainian businesses become more profitable and sustainable by developing effective corporate governance. CGPA is a center of knowledge and expertise for corporate governance specialists and Ukrainian businesses. CGPA is actively involved in forming and implementing public policy in joint-stock companies and good corporate governance in Ukraine. It gives explanations and recommendations to draft bills and adopted laws. www.cgpa.com.ua

CSR Ukraine is an expert organization working in Ukraine for 10 years, uniting more than 40 big companies, promoting the principles of sustainable business and corporate social responsibility, implementing its own social projects and conducting trainings regarding CSR-policies and reports for companies and state authorities. CSR Ukraine is a national partner for CSR Europe (Brussels, Belgium) and World Business Council for Sustainable Development (Geneva, Switzerland). www.csr-ukraine.org

The Center for International Private Enterprise (CIPE) strengthens democracy around the globe through private enterprise and market-oriented reform. CIPE is one of the four core institutes of the National Endowment for Democracy and an affiliate of the U.S. Chamber of Commerce. Since 1983, CIPE has worked with business leaders, policymakers, and civil society to build the institutions vital to a democratic society. CIPE’s key program areas include enterprise ecosystems, democratic governance, business advocacy, and anti-corruption & ethics. www.cipe.org

Company Transparency Index 2019 – Ukraine was conducted and prepared jointly by experts of the Corporate Governance Professional Association (CGPA) and CSR Ukraine with the support of the Center for International Private Enterprise (CIPE). The results of the research highlight the main trends of transparency of Ukraine’s 100 largest taxpaying companies in 2019, as per the State Tax Service Data. The results will be useful for representatives of foreign and Ukrainian companies, investors, busi- ness development experts, and diplomatic commu- nities.