Case: Ozon Conversion

On 31 March 2026, the application period expired for the mandatory conversion of American Depositary Receipts (ADRs) evidencing rights to the ordinary shares of OZON IPJSC.

The mandatory conversion enabled investors whose ADRs are held in foreign financial institutions and who were unable to effect voluntary conversion of such ADRs and obtain ordinary shares of OZON IPJSC by submitting an application to the registrar maintaining the shareholders' register of OZON IPJSC.

The procedure and timeline of the mandatory conversion are governed by Russian law, in particular the Federal Law No. 452-FZ dated 4 August 2023 "On Amendments to Certain Legislative Acts of the Russian Federation", as well as the Decision of the Board of Directors of the Bank of Russia dated 24 December 2024 "On Establishing the Procedure and Timeline for the Mandatory Conversion of Securities of Foreign Issuers Evidencing Rights to Shares of Joint-Stock Companies Having the Status of an International Company into Shares of Such Joint-Stock Companies".

GRATA International team advised a client, who is a citizen of the Russian Federation currently residing outside its territory, on the conversion of his ADRs into ordinary shares of OZON IPJSC, which was successfully completed.