EPAM · EPAM Systems, Inc. · Insider Trading

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan. This disposition is exempt from Section 16(b) of the Securities Exchange Act of 1934 pursuant to Rule 16b-3(e), as shares were withheld by the Issuer to satisfy tax withholding obligations in connection with the vesting of the underlying award, which was approved in advance by the Issuer's Board of Directors.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Non-Employee Directors Compensation Plan.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Number of securities reported in Column 5 corrected to reflect shares of common stock reported as gifts in December 2023, 2024, and 2025 were made from the Reporting Person's Trust and not from the Reporting Person's direct holdings.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

Represents restricted stock units awarded pursuant to the EPAM Systems, Inc. Non-Employee Director Compensation Policy. These restricted stock units will vest on the first anniversary of the grant date.

The reporting person is voluntarily reporting the acquisition of the Issuer's Common Stock pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan (the "ESPP"), for the ESPP purchase period of November 1, 2025 through April 30, 2026 (the "Purchase Period"). This transaction is also exempt from Rule 16b-3(c). In accordance with the ESPP, these shares were purchased at the lesser of (i) 85% of the fair market value of such shares of Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of such shares of Common Stock on the last day of the Purchase Period.

The reporting person is voluntarily reporting the acquisition of the Issuer's Common Stock pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan (the "ESPP"), for the ESPP purchase period of November 1, 2025 through April 30, 2026 (the "Purchase Period"). This transaction is also exempt from Rule 16b-3(c). In accordance with the ESPP, these shares were purchased at the lesser of (i) 85% of the fair market value of such shares of Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of such shares of Common Stock on the last day of the Purchase Period.

The reporting person is voluntarily reporting the acquisition of the Issuer's Common Stock pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan (the "ESPP"), for the ESPP purchase period of November 1, 2025 through April 30, 2026 (the "Purchase Period"). This transaction is also exempt from Rule 16b-3(c). In accordance with the ESPP, these shares were purchased at the lesser of (i) 85% of the fair market value of such shares of Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of such shares of Common Stock on the last day of the Purchase Period.

The reporting person is voluntarily reporting the acquisition of the Issuer's Common Stock pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan (the "ESPP"), for the ESPP purchase period of November 1, 2025 through April 30, 2026 (the "Purchase Period"). This transaction is also exempt from Rule 16b-3(c). In accordance with the ESPP, these shares were purchased at the lesser of (i) 85% of the fair market value of such shares of Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of such shares of Common Stock on the last day of the Purchase Period.

The reporting person is voluntarily reporting the acquisition of the Issuer's Common Stock pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan (the "ESPP"), for the ESPP purchase period of November 1, 2025 through April 30, 2026 (the "Purchase Period"). This transaction is also exempt from Rule 16b-3(c). In accordance with the ESPP, these shares were purchased at the lesser of (i) 85% of the fair market value of such shares of Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of such shares of Common Stock on the last day of the Purchase Period.

The reporting person is voluntarily reporting the acquisition of the Issuer's Common Stock pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan (the "ESPP"), for the ESPP purchase period of November 1, 2025 through April 30, 2026 (the "Purchase Period"). This transaction is also exempt from Rule 16b-3(c). In accordance with the ESPP, these shares were purchased at the lesser of (i) 85% of the fair market value of such shares of Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of such shares of Common Stock on the last day of the Purchase Period.

Represents restricted stock units that are scheduled to vest as to 1/3 of the shares on each of the first, second, and third anniversaries of the grant date.

The stock option was automatically exercised on a net share settlement basis immediately before its expiration, in accordance with its terms. The Company delivered to the reporting person the number of shares underlying the stock option less the number of shares having a Fair Market Value on the date of such exercise equal to (i) the aggregate exercise price for the stock option and (ii) the amount necessary to satisfy any federal, state and local withholding taxes related to such exercise.

The option became exercisable as to 25% of the shares on each of March 25, 2017, 2018, 2019 and 2020.

The stock option was automatically exercised on a net share settlement basis immediately before its expiration, in accordance with its terms. The Company delivered to the reporting person the number of shares underlying the stock option less the number of shares having a Fair Market Value on the date of such exercise equal to (i) the aggregate exercise price for the stock option and (ii) the amount necessary to satisfy any federal, state and local withholding taxes related to such exercise.

The stock option was automatically exercised on a net share settlement basis immediately before its expiration, in accordance with its terms. The Company delivered to the reporting person the number of shares underlying the stock option less the number of shares having a Fair Market Value on the date of such exercise equal to (i) the aggregate exercise price for the stock option and (ii) the amount necessary to satisfy any federal, state and local withholding taxes related to such exercise.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

Represents restricted stock units that are scheduled to vest as to 25% of the shares on each of March 15, 2027, 2028, 2029, and 2030.

Represents restricted stock units that are scheduled to vest as to 25% of the shares on each of March 15, 2027, 2028, 2029, and 2030.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

Represents restricted stock units that are scheduled to vest as to 25% of the shares on each of March 15, 2027, 2028, 2029, and 2030.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

Represents restricted stock units that are scheduled to vest as to 25% of the shares on each of March 15, 2027, 2028, 2029, and 2030.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

Represents restricted stock units that are scheduled to vest as to 25% of the shares on each of March 15, 2027, 2028, 2029, and 2030.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

Represents restricted stock units that are scheduled to vest as to 25% of the shares on each of March 15, 2027, 2028, 2029, and 2030.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.

These shares were withheld by the Issuer to satisfy the tax withholding requirement arising from the vesting of restricted stock units granted to the reporting person under the Issuer's Long Term Incentive Plan.