EPAM Systems legal chief Rockwell acquires 79 shares

The ESPP purchase price was the lesser of 85% of fair market value on the period’s first and last trading days.

Available on EDGAR 11/03/2026 - 05:34 PM EST Accepted by SEC EDGAR 11/03/2026 - 05:33 PM EST Learn about SEC filing dates

Rhea-AI Filing Summary

EPAM Systems, Inc. SVP/Chief Legal Officer Edward Rockwell acquired 79 shares of EPAM common stock on October 31, 2026, at $95.48 per share through the company’s 2021 Employee Stock Purchase Plan. His reported direct holdings afterward were 15,201 shares. The purchase period ran from May 1, 2026, through October 31, 2026; no Rule 10b5-1 plan is reported.

Insider Trade Summary

Other: 78.55 shares

Other 1 txn

Insider Rockwell Edward

Role SVP/Chief Legal Officer

Type	Security	Shares	Price	Value
Other	EPAM Common Stock F1	78.55	$95.48	$7K

Holdings After Transaction: EPAM Common Stock — 15,201.192 shares (Direct)

Holdings Before and After: EPAM Common Stock, 15,122.642 to 15,201.192 shares (Direct)

Footnotes (1)

1. F1. 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 purchase period of May 1, 2026 through October 31, 2026 (the "Purchase Period"). The ESPP is a tax-qualified employee stock purchase plan under Section 423 of the Internal Revenue Code, and the reporting person's enrollment election was made prior to the commencement of the Purchase Period. Accordingly, this transaction is exempt from Section 16(b) of the Securities Exchange Act of 1934 pursuant to Rule 16b-3(c). Per the ESPP, shares were purchased at the lesser of (i) 85% of the fair market value of the Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of the Common Stock on the last trading day of the Purchase Period.

Key Figures

Shares acquired: 79 shares Price per share: $95.48 per share Direct holdings after transaction: 15,201 shares

3 metrics

Shares acquired 79 shares October 31, 2026; through the 2021 Employee Stock Purchase Plan

Price per share $95.48 per share October 31, 2026 acquisition

Direct holdings after transaction 15,201 shares Reported after the October 31, 2026 transaction

Key Terms

Employee Stock Purchase Plan, Section 423, Rule 16b-3(c), fair market value

4 terms

Employee Stock Purchase Plan financial

"pursuant to the EPAM Systems, Inc. 2021 Employee Stock Purchase Plan"

An employee stock purchase plan is a company program that lets workers buy shares through small payroll deductions, often at a discount to the market price and after a set offering period. Think of it like a workplace savings plan that turns into ownership: it encourages employees to share in the company’s success and can create predictable buying or selling of stock that investors watch because it affects supply, demand and employee incentives.

Section 423 regulatory

"tax-qualified employee stock purchase plan under Section 423"

Rule 16b-3(c) regulatory

"exempt from Section 16(b) ... pursuant to Rule 16b-3(c)"

An SEC rule that lets corporate insiders avoid automatic "short‑swing" profit recovery when they buy or sell their company’s stock under a pre‑approved, written plan that meets specific conditions. For investors, it matters because it clarifies when insider trades are treated as routine, reducing legal uncertainty and helping distinguish trades made for ordinary compensation or pre‑planned reasons from those that might signal opportunistic or timely insider advantage.

fair market value financial

"85% of the fair market value on the first trading day"

The price a willing buyer and a willing seller would agree on for an asset or security when neither is under pressure and both have access to the same information. Think of it as the market’s neutral estimate of what something is worth, like the price two neighbors would settle on for a car after comparing similar listings. Investors care because fair market value guides buying and selling decisions, tax reporting, portfolio valuation, and how accurately company assets are reflected in financial statements.

FAQ

AI-generated questions and answers. How Rhea-AI works. Not financial advice.

How many EPAM shares did Edward Rockwell acquire, and at what price?

Edward Rockwell acquired 79 shares at $95.48 per share on October 31, 2026. His reported direct holdings afterward were 15,201 shares. The acquisition was through the company’s 2021 Employee Stock Purchase Plan, and no Rule 10b5-1 plan is reported.

How was the EPAM ESPP share price determined?

For the purchase period from May 1, 2026, through October 31, 2026, the price was the lesser of 85% of fair market value on the first trading day and 85% of fair market value on the last trading day.

AI-generated analysis. How Rhea-AI works. Not financial advice.

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SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
Estimated average burden
hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Rockwell Edward

(Last) (First) (Middle)

C/O EPAM SYSTEMS, INC.

41 UNIVERSITY DRIVE, SUITE 202

(Street)

NEWTOWN PENNSYLVANIA 18940

(City) (State) (Zip)

UNITED STATES

(Country)

2. Issuer Name and Ticker or Trading Symbol
EPAM Systems, Inc. [ EPAM ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	SVP/Chief Legal Officer

2a. Foreign Trading Symbol

3. Date of Earliest Transaction (Month/Day/Year)
10/31/2026

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

4. If Amendment, Date of Original Filed (Month/Day/Year)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
EPAM Common Stock	10/31/2026		J	V	78.55(1)	A	$95.48	15,201.192	D

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares

Explanation of Responses:

1. 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 purchase period of May 1, 2026 through October 31, 2026 (the "Purchase Period"). The ESPP is a tax-qualified employee stock purchase plan under Section 423 of the Internal Revenue Code, and the reporting person's enrollment election was made prior to the commencement of the Purchase Period. Accordingly, this transaction is exempt from Section 16(b) of the Securities Exchange Act of 1934 pursuant to Rule 16b-3(c). Per the ESPP, shares were purchased at the lesser of (i) 85% of the fair market value of the Common Stock on the first trading day of the Purchase Period and (ii) 85% of the fair market value of the Common Stock on the last trading day of the Purchase Period.

Remarks:

	/s/ Kate Pytlewski as Attorney-in-Fact	11/03/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 4: SEC 1474 (03-26)