Timing of Compensation Decisions

We do not grant stock options or PSUs to our executive officers in anticipation of the release of significant earnings announcements or other material non-public information likely to result in changes to the price of our Common Stock. Similarly, we do not time the release of material non-public information based on equity award grant dates. In the event material non-public information becomes known to the Committee prior to granting an equity award, the Committee will take the existence of such information into consideration and use its business judgment to determine whether to delay the grant of equity to avoid any appearance of impropriety.

As required by Item 402(x) of Regulation S-K under the Exchange Act, during fiscal 2024, the Committee awarded stock options to our NEOs in the period beginning four business days before our filing of a periodic report on Form 10-K or Form 10-Q or the filing or furnishing of a current report on Form 8-K that disclosed material non-public information, and ending one business day after the filing or furnishing of such report (the “Designated Periods”). In this case, EPAM disclosed the new grant of PSUs on March 20, 2024. Pursuant to SEC Rules, we are providing the following information relating to stock options awarded to our NEOs in the Designated Periods occurring during fiscal year 2024:


Name	Grant date	Number of securities underlying the award	Exercise price of the award ($/Share)	Grant date fair value of the award	Percentage change in the closing market price of the securities underlying the award between the trading day ending immediately prior to the disclosure of material non-public information and the trading day beginning immediately following the disclosure of material non-public information
Arkadiy Dobkin	March 15, 2024	9,365	$298.89	$1,550,095	(4.02%)
Jason Peterson	March 15, 2024	9,063	$298.89	$1,500,108	(4.02%)
Balasz Fejes	March 15, 2024	9,063	$298.89	$1,500,108	(4.02%)
Viktar Dvorkin	March 15, 2024	6,042	$298.89	$1,000,072	(4.02%)
Larry Solomon	March 15, 2024	6,042	$298.89	$1,000,072	(4.02%)

Award Timing, How MNPI Considered

We do not grant stock options or PSUs to our executive officers in anticipation of the release of significant earnings announcements or other material non-public information likely to result in changes to the price of our Common Stock. Similarly, we do not time the release of material non-public information based on equity award grant dates. In the event material non-public information becomes known to the Committee prior to granting an equity award, the Committee will take the existence of such information into consideration and use its business judgment to determine whether to delay the grant of equity to avoid any appearance of impropriety.

Awards Close in Time to MNPI Disclosures, Table

As required by Item 402(x) of Regulation S-K under the Exchange Act, during fiscal 2024, the Committee awarded stock options to our NEOs in the period beginning four business days before our filing of a periodic report on Form 10-K or Form 10-Q or the filing or furnishing of a current report on Form 8-K that disclosed material non-public information, and ending one business day after the filing or furnishing of such report (the “Designated Periods”). In this case, EPAM disclosed the new grant of PSUs on March 20, 2024. Pursuant to SEC Rules, we are providing the following information relating to stock options awarded to our NEOs in the Designated Periods occurring during fiscal year 2024:


Name	Grant date	Number of securities underlying the award	Exercise price of the award ($/Share)	Grant date fair value of the award	Percentage change in the closing market price of the securities underlying the award between the trading day ending immediately prior to the disclosure of material non-public information and the trading day beginning immediately following the disclosure of material non-public information
Arkadiy Dobkin	March 15, 2024	9,365	$298.89	$1,550,095	(4.02%)
Jason Peterson	March 15, 2024	9,063	$298.89	$1,500,108	(4.02%)
Balasz Fejes	March 15, 2024	9,063	$298.89	$1,500,108	(4.02%)
Viktar Dvorkin	March 15, 2024	6,042	$298.89	$1,000,072	(4.02%)
Larry Solomon	March 15, 2024	6,042	$298.89	$1,000,072	(4.02%)