Freedom Holding Corp. Compliance Department ensures compliance with legal requirements, engages with regulators, and ensures regulatory reporting in all regions where the Group operates. It is headed by the Chief Compliance Officer, whose responsibilities also include interaction with regulators and external stakeholders, including rating agencies and industry organizations.

In each subsidiary of Freedom Holding Corp. the responsibility for ensuring compliance with the applicable regulatory requirements, in coordination with the Chief Compliance Officer, is assigned to local Compliance officers. Their authority and duties may vary in accordance with the local internal regulations and specifics of the business model.

Where local legislation is less stringent than Freedom Holding Corp.’s Policies and internal standards, Freedom Holding Corp. policy applies as a minimum baseline. Each subsidiary ensures local implementation in line with Freedom Holding Corp. expectations and international best practices.

Freedom Holding Corp. is committed to maintaining the highest standards of ethical conduct and integrity. The Company places particular emphasis on the identification, prevention, and proper management of conflicts of interest across all levels of its operations.

The foundation for managing conflicts of interest is set out in the Company’s Code of Ethics and Business Conduct, which is mandatory for all directors, officers, and employees of Freedom Holding Corp. and its subsidiaries.

A conflict of interest arises when an individual’s personal interests, or those of their close associates, may interfere — or appear to interfere — with the interests of the Company. Such situations can compromise objectivity, professional judgment, or the ability to act in the Company’s best interest.

To uphold transparency and trust, the Company adheres to the following principles in managing conflicts of interest:

• Integrity and accountability – Employees are expected to act with integrity and avoid situations where personal interests conflict with professional responsibilities.
• Transparency – Potential conflicts must be disclosed promptly and fully to allow appropriate assessment and action.
• Fairness – Decisions must be made based on objective criteria and in the Company’s best interest, without favoritism or bias.
• Oversight – The Company maintains internal procedures for reviewing, mitigating, and resolving conflicts of interest in a consistent and controlled manner.

Freedom Holding Corp. expects all personnel to remain vigilant, exercise sound judgment, and seek guidance when unsure about a potential conflict. By fostering a culture of ethical awareness, the Company aims to ensure that all decisions are aligned with its values and long-term objectives.

Incidents of corruption can cause significant economic and reputational damage to the Company. They can undermine its stakeholders’ trust and investor interest. Freedom Holding Corp. is committed to maintaining the highest standards of integrity, transparency, and accountability in all its business dealings and relationships wherever it operates, as well as to implementing and enforcing effective systems to counter bribery and corruption. Freedom Holding Corp. adopts a zero-tolerance policy for corruption, bribery, and unethical behavior.

The primary document governing the Company’s approach toward combating corruption within its operations is the Anti-Bribery and Corruption Policy. The Policy applies to all entities owned, controlled, or operated by Freedom Holding Corp., including its subsidiaries, affiliates, and joint ventures. It is binding on all employees (whether temporary, fixed-term, or permanent), management, contractors, and business partners, regardless of location or role. Additionally, the Policy applies to the Board of Directors, Committee members at all levels, and any other individual acting on behalf of the Company.

Freedom Holding Corp. requires all team members to complete mandatory training on the topics outlined in this Policy. This includes management, staff, and relevant third parties, who must take anti-bribery and corruption courses through either face-to-face sessions or an online training platform.

Regular refresher courses are conducted to ensure Freedom Holding Corp.’s employees remain informed about changes in legal requirements and company policies. Employees, deemed to have significant exposure to bribery and corruption risks, must undergo specialized anti-corruption training on an annual basis to further mitigate risks and ensure the highest standards of conduct.

Freedom Holding Corp. incorporates Financial Institutions it recognizes the critical importance of combating money laundering and the financing of terrorism.

In pursuit of this objective, Freedom Holding Corp. has implemented a comprehensive AML/CFT framework guided by our Global Ani-Money Laundering and Combating the Financing of Terrorism Policy. This Policy has been designed to establish an effective and uniform standard for managing money laundering/financing terrorism (ML/FT) risks within financial institutions that are part of Freedom Holding Corp. It assigns clear individual accountability to uphold these standards and to meet our regulatory requirements.

Given that Freedom Holding Corp. is not an operating company and does not directly provide financial services to customers, the Policy is specifically designed to ensure that all subsidiary financial institutions implement necessary controls to effectively manage ML/FT risks. Accordingly, compliance with the Policy is mandatory to all financial institutions within the Group, as well as other subsidiaries of Freedom Holding Corp., that are legally obligated to implement AML/CFT measures under applicable legislation.

The Policy also formulates requirements for entities within its scope regarding AML/CFT training and competency assessment procedures. To ensure compliance with applicable legislation, subsidiary financial institutions must train and assess the competency of newly hired employees and employees newly assigned to roles requiring such training within three months of their start date in the relevant position.

Integrity and compliance are top priorities at Freedom Holding Corp. Our AML/CFT framework is a key part of our efforts to help protect the financial system from illegal activities.

Freedom Holding Corp. prohibits business relationships and transactions involving sanctioned persons, entities, or comprehensively sanctioned jurisdictions, as defined by applicable sanction regimes.

Freedom Holding Corp. also does not support any activity that would constitute circumvention or evasion of applicable sanctions laws and regulations.

To ensure effective management of sanctions risk and prevent any violations, Freedom Holding Corp. has implemented robust controls, including sanctions screening and training for employees. These measures, combined with a culture of compliance fostered through ongoing training and clear reporting channels, ensure that Freedom Holding Corp. remains vigilant in preventing any Sanctions-related violations.

The opportunity for stakeholders to quickly and safely communicate their concerns regarding the Company’s operations is paramount to ensuring effective stakeholder engagement and the timely identification of risks. Thus, Freedom Holding Corp. implements a clear, confidential, and reliable mechanism for reporting actual or suspected fraud, misconduct, wrongdoing, and other violations of applicable laws, regulations, or Company policies.

The key document regulating the whistleblowing process in Freedom Holding Corp. is the Whistleblowing Policy. The Policy reinforces Freedom Holding Corp. and its subsidiaries’ unwavering commitment to the highest standards of integrity, accountability, and ethical conduct.

This Policy applies worldwide across all jurisdictions where the Company operates and complies with applicable international and local regulations. These include FCPA, SOX, the EU Whistleblowing Directive 2019/1937, local whistleblowing laws and relevant data protection regulations such as GDPR. While the Policy applies across all jurisdictions, each subsidiary is responsible for its local implementation and alignment, ensuring consistency with both group-wide standards and local legal requirements.

The Policy applies to all employees, directors, officers, and relevant third parties, including clients, contractors, suppliers, and business partners of the Company.

The revised whistleblowing mechanism implemented by Freedom Holding Corp. covers reports related to the following issues:

• Breaches of the Company’s Code of Ethics, policies, or procedures.
• Misconduct related to accounting practices, internal controls, financial reporting, or fraudulent activities.
• Violations of applicable laws, regulations, or external standards, including anti-bribery, anti-corruption, sanctions and data protection regulations.
• Retaliation, discrimination, or harassment against individuals who report concerns in good faith or participate in investigations.

There are two primary reporting channels:

1. Compliance hotline telephone lines;
2. Online reporting platform;

Email support for whistleblowing inquiries and policy clarification is available.

The Company has a structured framework in place to support an effective whistleblowing process, ensuring transparency, accountability, and protection for whistleblowers.

Managers and supervisors are key to fostering a culture of integrity by:

• Encouraging open communication and supporting employees who report concerns.
• Escalating reported issues promptly and accurately.

The Compliance and Investigative Teams are responsible for:

• Conducting fair, timely, and thorough investigations.
• Maintaining confidentiality to protect those involved, in line with laws and Company policies.
• Ensuring investigations are handled with professionalism and integrity.

Senior Management and the Board of Directors oversee the whistleblowing process by:

• Approving and supporting the Whistleblowing Policy.
• Monitoring compliance through regular reviews, audits, and assessments.
• Ensuring appropriate corrective actions are taken when concerns are validated.

The Company enables confidentiality and protection of individuals who file the reports via the whistleblowing mechanism; ensures timely and impartial investigations, non-discrimination and non-retaliation against the whistleblowers.

Reporters can choose to remain anonymous when submitting concerns via the whistleblowing compliance hotline or online reporting platform.

All channels are available 24/7, whereas the online platform and compliance hotline offer multilingual accessibility. The reporting channels are free of charge for all users.

The Company tracks all reports and investigations in a centralized system, regularly reviews key trends and statistics, and presents summary analytics to senior management and the Board.

The Hotline operates according to the following principles:

• The reporter is protected from any form of retaliation or discrimination.
• Through the Whispli platform, the reporter can communicate securely with the investigator while remaining completely anonymous.
• Each investigation involves only a limited number of specialists whose expertise is necessary for conducting the review.
• The reporter will be informed of the outcome of the review within the limits permitted by applicable law and confidentiality obligations.
• The Hotline must not be used to resolve personal conflicts or grievances unrelated to misconduct.
• Knowingly submitting false or misleading reports is considered a serious violation and may result in disciplinary action or liability under applicable law.
• Reports made in good faith - even if later unconfirmed - will not result in any negative consequences for the reporter.
• The Hotline is not an emergency service. If you are in immediate danger or face an emergency situation, please contact local emergency services or law enforcement authorities.

• Violations of applicable laws, the Code of Ethics and Business Conduct, Company policies, or internal procedures.
• Any form of corruption, including bribery, extortion, facilitation payments, or improper gifts and hospitality involving public officials or private parties.
• Safety threats, workplace discrimination, bullying, or harassment.
• Violations of labor laws or employee rights.
• Incidents related to information security, personal data protection, confidentiality breaches, or unauthorized disclosure of legally protected information.
• Conflicts of interest (e.g., nepotism, outside employment, providing services to competitors, or abuse of authority).
• Unfair or anti-competitive practices.
• Accounting irregularities or financial misstatements.
• Theft, misappropriation of assets, or fraud.
• Misconduct or violations in procurement and supply-chain activities.
• Money laundering, terrorist financing, or sanctions violations.
• Any other behavior that may pose legal, financial, operational, or reputational risks to Freedom Holding Corp.

Employees, contractors, third parties, business partners, and any other individuals who become aware of actual or suspected misconduct - including bribery, corruption, fraud, theft, abuse of authority, harassment, or any other violations of the Code of Ethics and Business Conduct - may report their concerns through the Compliance Hotline.

Reporters are responsible for ensuring that the information they provide is accurate to the best of their knowledge.

Reports should be objective, unbiased, and include all relevant facts, reasons for concern, and any supporting documentation (if available).

Knowingly submitting false or misleading information is a serious violation and may result in disciplinary action or liability under applicable law. Where a report is intentionally false and sufficient grounds exist, the matter may be referred to law enforcement authorities.

Any employee, counterparty, or other third party who reports a concern in good faith is protected from dismissal, demotion, refusal of cooperation, retaliation, or any other form of discrimination as a result of submitting the report.

However, this protection must not be abused. The protection provided does not exempt a reporter from disciplinary action or liability for knowingly submitting a false report.

Reports are submitted through the website or mobile application of the independent whistleblowing platform, Whispli.

All records of actions taken within the system are protected from deletion and are securely stored on the platform.

Authorized personnel from the FRHC Compliance Department receive automatic notifications generated by the platform. A designated Compliance Officer oversees the entire process - from receipt of the report to final decision-making.

Within five (5) working days from the date a report is received, a Compliance Officer will determine whether to accept the report for review, leave it without consideration, or reject it if there are no indications of a violation or if the initial information is insufficient.

The duration of the subsequent review may vary depending on the scope of the case, the level of risk, and any newly discovered information.

In anonymous mode, the reporter’s identity is not known to the Company and cannot be determined through the platform. All communication with the investigator is conducted without revealing any identifying information.

In confidential mode, the reporter’s identity is known but is disclosed only to a limited number of authorized individuals involved in handling the case. This information will not be shared with other employees not directly engaged in the review.

Anonymity is guaranteed only when reports are submitted through the Whispli website or telephone hotline.

When submitting a report, you can choose to remain anonymous or, if you prefer, voluntarily provide your name, email address, or other contact details.

After submitting the report, you will receive a unique link, a system-generated username (a nickname such as “Funny Zebra”), and a password. These credentials allow you to log in later and securely communicate with the investigator through a dedicated chat on the platform without revealing your identity.