Freedom Holding Corp. (FRHC) Business

ITEM 1. BUSINESS

OVERVIEW

Freedom Holding Corp. ("FRHC") is organized under the laws of the State of Nevada and acts as a holding company for all of our subsidiaries. Our subsidiaries engage in a broad range of activities including securities brokerage, securities dealing for customers and for our own account, market making activities, investment research, investment counseling, retail and commercial banking, and insurance products. We also own several ancillary businesses and lifestyle solutions, which complement our core financial services businesses, including payment and information processing services, entertainment and travel ticketing services, e-commerce business, cloud services, and telecommunications and media businesses in Kazakhstan that are in a developmental stage.

Our mission has always been to democratize access to financial markets for global customers. Our company was founded to provide access to the international capital markets for retail brokerage customers and has rapidly grown providing a world-class digital infrastructure that has led to innovative, integrated financial technologies that address customer needs in Kazakhstan, our home market, and dozens of other countries across Europe, Asia, and North America.

The main market of our operations is Kazakhstan. Our operating subsidiaries are located in Kazakhstan, Cyprus, the United States, the United Kingdom, Armenia, the United Arab Emirates, Uzbekistan, Kyrgyzstan, Tajikistan, Azerbaijan, Türkiye, Bulgaria, Germany, Greece, Lithuania, The Netherlands, Portugal, Spain, Austria, France and Poland and the Group also has representative office in Italy. We divested our Russian subsidiaries in February 2023. Our subsidiaries in the United States include an SEC- and FINRA-registered broker dealer. As of March 31, 2026, we had 11,627 full-time employees, 230 offices (of which 32 offered brokerage services, 63 offered insurance services offices, 9 offered banking services and 126 offered other financial and non-financial services) and 858,000 retail brokerage customer accounts.

From the beginning of calendar 2024, our Chief Executive Officer, Chief Financial Officer and President, who collectively act as our chief operating decision maker (CODM), began to manage our business, make operating decisions, and evaluate operating performance on the basis of a new segmental structure. As a result, we have realigned our reportable segments into the following four segments: Brokerage, Banking, Insurance, and Other. All prior period segment information has been recast to reflect this change in reportable segments.

FRHC's common stock is included in the Russell 3000® Index.

Financial information concerning us, our business segments for each of the years ended March 31, 2026, 2025 and 2024 is included in Part II Item 8 "Financial Statements and Supplementary Data" of this annual report.

Our Corporate History

Reverse Acquisition Transaction

Founded as its current business in 2015, the Company draws its origins from two companies: BMB Munai, a Kazakhstani energy company founded in 1981, and Freedom Finance, a brokerage company founded by Timur Turlov in Kazakhstan in 2011.

BMB Munai was originally incorporated in the State of Utah in July 1981. In December 2004 it redomiciled to the State of Nevada. In November 2015, BMB Munai entered into a reverse acquisition agreement with Timur Turlov, whereby the company changed name to Freedom Holding Corp., to acquire 100% ownership interests in several companies, owned by Timur Turlov. These acquisitions closed in several stages from November 2015 to November 2017 as required audits and regulatory approvals were received. At the completion of the acquisitions, Timur Turlov was our controlling shareholder.

Significant Historical Milestones

In 2019, FRHC's shares were listed on Nasdaq.

In December 2020, we acquired Kassa Nova Bank JSC, a Kazakhstan consumer bank with 10 branch offices across Kazakhstan, which in May 2024, we renamed Freedom Bank Kazakhstan JSC ("Freedom Bank KZ").

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In December 2020, we acquired Prime Executions, Inc. (d/b/a Freedom Capital Markets) ("FCM"), a registered agency-only execution broker-dealer on the floor of the New York Stock Exchange, which represented our initial entry into the U.S. market. In January 2022, FCM received regulatory approval from FINRA to conduct specific types of investment banking business.

In May 2022, we acquired two insurance companies, Freedom Finance Life JSC ("Freedom Life") and Freedom Finance Insurance JSC ("Freedom Insurance"). These two companies had been 100% controlled by the FRHC's chief executive officer, chairman of the Board of Directors and majority shareholder, Mr Timur Turlov, at the time of the acquisition.

In February 2023, we completed the divestiture of our Russian business units which included, inter alia, LLC Investment Company Freedom Finance and its subsidiaries.

In 2024, as part of our digital fintech strategy, we launched our expansion into the Kazakhstan telecommunications market with the goal of offering a diverse range of telecommunications and related services through our subsidiary, Freedom Telecom. This expansion path has involved a series of acquisitions of local telecommunications companies. Additionally, we established Freedom Media LLP with the aim of building a regional streaming platform for Kazakhstan and the broader Central Asian region.

In April 2024, Freedom Bank KZ launched SuperApp, an all-in-one financial platform offering retail banking, payment, insurance and lifestyle services. By March 2026, the number of registered users of SuperApp reached 5.2 million, having doubled within a year.

Our Business Strategy

Our focus has been to establish ourselves as a leader in the financial services industry, serving individuals and institutions by offering them efficient access to international capital markets and market-leading financial services.

We focus on building financial products that combine advanced technology with simple, reliable, and intuitive user experience. Whether it is trading, banking, payments, or insurance, our goal is to offer best-in-class solutions that work seamlessly across different countries, comply with local regulations, and meet the everyday needs of our customers. We invest in continuous product development, using customer feedback, usage data, and market trends to improve and expand our products and services. By doing so, we aim to lead not just through scale, but by the quality and usability of the products we deliver - we aim to set a high standard in every market we operate.

We provide an integrated ecosystem: Freedom's proprietary cloud stack - anchored by the Freedom SuperApp for everyday finance and Tradernet for multi venue trading - is the Group's operating system. Every current or future service (payments, banking, insurance, lifestyle commerce, and forthcoming connectivity layers) is engineered as a usable module in this architecture. Each addition enlarges the network of services available to every customer, deepens engagement through richer data insights, and unifies the customer’s experience across geographies. We strive to leverage big data analytics and predictive AI within our ecosystem to better understand, anticipate, and proactively address customer needs, thereby enhancing customer satisfaction, retention, and overall value.

Strategic goals

•Regional and Global Expansion. Our primary strategic goal is to build a network of banks, brokers, and digital financial infrastructure that connects markets across Central Asia, the Caucasus, and beyond. By applying our expertise in digital finance, we aim to build a cross-border banking network that links key markets from Asia to Europe - enabling seamless transactions and supporting our brokerage operations in each jurisdiction, while fostering deeper economic integration across the region. To achieve this, we pursue selective acquisitions of companies whose licenses, technology or expertise enhance our platform - such as fintech providers, digital commerce enablers, and lifestyle service companies. These additions allow us to expand our service offering, deepen our presence in each market, and increase the overall value of our ecosystem for customers.

•AI and Data-Driven Ecosystem. Big data, predictive modeling and machine learning are core to our strategy as an AI-driven firm while we scale and expand into new markets. By building advanced data infrastructure and AI analytics capabilities, we are able to anticipate customer behavior, tailor products and pricing, and enhance engagement across our ecosystem. This AI-driven approach also supports smarter decision-making and helps us identify the right partners, forecast market trends, and allocate resources effectively. As our ecosystem grows, investing in the ability to acquire, process, and apply data and AI models at scale remains our key priority.

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Governance and Regulatory Focus.

A central compliance office designs group policies and technology, while locally licensed officers tailor and enforce them in their jurisdictions. From the first click of onboarding, each customer and transaction is run through automated KYC, AML/CTF and sanctions screening embedded in our trading engine and fed by leading global data providers. Ongoing trade surveillance, whistleblower channels and independent audits keep the framework transparent and adaptive.

PRODUCTS AND SERVICES

Our business is organized into four segments: Brokerage, Banking, Insurance, and Other. Additional information regarding our segments can be found in the narrative and tabular descriptions of segments and operating results under "Management's Discussion and Analysis of Results of Operations and Financial Condition" included in Part II Item 7 of this annual report and Note 30 "Segment Reporting" in the notes to consolidated financial statements included in Part II Item 8 of this annual report.

Our Brokerage segment primarily focuses on retail brokerage and broader investment banking services. Our Banking segment encompasses lending, deposit services, payment card services, money transfers, and correspondent accounts, supporting both individual and corporate customers with innovative digital financial solutions. Our Insurance segment offers life and general insurance services. Our Other segment includes payment processing services, e-commerce, online ticket sales, and new business areas including telecommunications and media services. We also engage in proprietary securities trading activities through each of our four segments.

The expansion of our retail customers’ activity has been a major driver of our growth, particularly in Kazakhstan, Europe and other Central Asian jurisdictions. Over recent years, we have experienced a significant increase in retail customers' activity across these key markets, which has been instrumental in scaling our business. The table sets forth the number of our customers across our key segments as of the date indicated:

Banking Segment

Banking segment consists of the operations of Freedom Bank KZ and Freedom Bank TJ.

Freedom Bank KZ is a pioneer in digital retail and commercial banking services in Kazakhstan, offering deposits, multi‑currency payment cards, consumer and SME loans, payment and acquiring solutions. The bank extends our capital market heritage into everyday finance, providing the funding, payments and credit backbone of the wider Freedom ecosystem.

Freedom Bank TJ, a closed joint-stock company organized under the laws of the Republic of Tajikistan, obtained its banking license from the National Bank of Tajikistan on October 15, 2024, which permits it to conduct banking operations in both national and foreign currencies. The bank is being developed as a digitally led retail and commercial bank intended to extend our digital fintech ecosystem to the Tajikistan market, with a target product set covering current and savings accounts, multi‑currency payment cards, money transfers, and consumer and small and medium enterprise (SME) lending, delivered primarily through digital channels. As of March 31, 2026, Freedom Bank TJ conducted its activities through its office in Tajikistan and continued the phased build‑out of its branch network and digital service channels.

The Company continues considering expansion of its banking segment into other jurisdictions. In March 2026, FRHC and its subsidiary Freedom Finansial Hizmetler Anonim Şirketi entered into an agreement to purchase approximately 99.32% of Turkish Bank A.S., a bank operating in Türkiye. The transaction is subject to certain conditions, including obtaining of regulatory permits. In addition, the Company is taking steps to establish a bank in Georgia which is subject to obtaining the required regulatory approvals.

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As of March 31, 2026, Banking segment combined assets increased by 21% to $5,359.8 million, loan portfolio increased by 29% to $2,045.3 million, deposit portfolio increased by 46% to $2,522.8 million, held-to-maturity increased by 552% to $429,423 in comparison with March 31, 2025. As of March 31, 2026, we had 3,628 employees in our Banking segment, all of which were full-time employees.

In Kazakhstan, the Kazakhstan Deposit Insurance Fund ("KDIF") administers the deposit insurance system. The KDIF insures deposits in the case of liquidation of a bank-member of the KDIF fund. Deposits are insured up to 20 million Kazakhstan tenge (approximately $40,000 as of March 31, 2026) per customer. In our Banking segment we also conduct proprietary securities trading activities.

Strategy and Competitive Position

•Digital core: All key processes - onboarding, credit decisioning, account servicing - run on cloud infrastructure with biometric ID and live links to government and credit‑bureau databases.

•Ecosystem integration: Banking functionality is embedded in the Freedom SuperApp and Tradernet platforms, enabling seamless money movement between brokerage, payments and lending.

•Focused physical network: Thirty-one service centers across Kazakhstan and our Tajikistan subsidiary's office support complex transactions and cash services; the majority of new business originates through mobile and web channels.

Products and Services

In our banking segment, we offer deposits, multi‑currency payment cards, consumer and small and medium enterprise (SME) loans, payment and acquiring solutions. A detailed description of these products, including our credit products, card products and lifestyle services is provided in "Digital Fintech Ecosystem" below in this Item 1.

Insurance Segment

FRHC owns two insurance companies in Kazakhstan: Freedom Life and Freedom Insurance.

We believe incorporating the offerings of these insurance companies with our brokerage and banking product and service lines, along with our developing fintech ecosystem in Kazakhstan, allows us to offer an integrated, efficient and convenient single source for financial services in Kazakhstan.

•Freedom Life. Freedom Life provides a range of health and life insurance products to individuals and businesses, including life insurance, health insurance, annuity insurance, accident insurance, obligatory worker emergency insurance, travel insurance and reinsurance. As of March 31, 2026, Freedom Life had 279,615 customers and 319,538 active contracts. "Active contracts" refers to insurance policies that are currently in force, meaning they have been issued and are not expired, canceled, or otherwise inactive as of the reporting date. As of March 31, 2026, Freedom Life had total assets of approximately $665.5 million and total liabilities of approximately $546.4 million. During the fiscal year ended March 31, 2026, Freedom Life recognized a net profit of approximately $32.9 million. As of March 31, 2026, Freedom Life's market share in the Kazakhstan life insurance market was 1.9% based on gross written premiums for the voluntary life insurance, and it held an approximately 7.4% market share in the Kazakhstan voluntary accident insurance and 19.3% of the pension annuity insurance segment in Kazakhstan, in each case according to the National Bank of Kazakhstan (NBK).

•Freedom Insurance. Freedom Insurance operates in the "general insurance" sector and is the leader in online insurance in Kazakhstan offering various general insurance products in property (including automobile), casualty, civil liability, personal insurance and reinsurance. Freedom Insurance distributes its products and services through different channels such as the internet and a call center. By utilizing its digital solutions, Freedom Insurance's customers can purchase Freedom Insurance products within as little as five minutes and have a personal account for managing policies. As of March 31, 2026, Freedom Insurance had 837,275 customers and 1,299,046 active contracts. As of March 31, 2026, Freedom Insurance had total assets of approximately $226.7 million and total liabilities of approximately $133.6 million. During the fiscal year ended March 31, 2026, Freedom Insurance recognized net profit of approximately $10.8 million. According to the NBK, as of March 31, 2026, Freedom Insurance had an approximately 6.55% share of the total Kazakhstan general insurance market based on total assets and had an approximately 14.53% share of the Kazakhstan car owners liability insurance market based on insurance premiums received.

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In our Insurance segment we also conduct proprietary securities trading activities.

As of March 31, 2026, we had 63 offices and 1,107 employees, including 1,103 full-time employees and 4 part-time employees, providing consumer life and general insurance services in Kazakhstan.

Brokerage Segment

As of March 31, 2026, in our Brokerage business segment we had 32 offices that provided brokerage and financial services, investment consulting and education, including offices in Kazakhstan, Europe, Armenia, United States, Uzbekistan, UAE and Kyrgyzstan. On December 29, 2025, our UAE subsidiary Freedom Broker Global Markets Ltd. received a brokerage license in the UAE issued by the Abu Dhabi Global Market Financial Services Regulatory Authority. In addition, we are in the process of obtaining a license to provide brokerage services in Türkiye based on the principal approval granted by the financial regulatory and supervisory authority of Türkiye on January 9, 2025.

Freedom KZ and Freedom Finance Global PLC ("Freedom Global") are professional participants on the Kazakhstan Stock Exchange ("KASE") and the Astana International Exchange ("AIX"). Foreign Enterprise Freedom Finance LLC ("Freedom UZ") is a professional participant on the Republican Stock Exchange of Tashkent ("UZSE"), the Uzbek Republican Currency Exchange ("UZCE") and International Trading System Limited ("ITS"). FCM is a professional participant on the New York Stock Exchange ("NYSE"). Freedom Finance Armenia LLC ("Freedom AR") is a professional participant on the Armenia Stock Exchange ("AMX"). Freedom Broker LLC is a professional participant on the Kyrgyz Stock Exchange ("KSE").

Freedom Finance Europe Limited ("Freedom EU") oversees our European region operations, including Austria, Bulgaria, Cyprus, France, Germany, Greece, Italy, Lithuania, The Netherlands, Poland, Portugal and Spain. Through Freedom EU, we provide transaction processing and intermediary services to our regional customers and to institutional customers that may seek access to the securities markets in the United States and Europe. All trading of United States and European exchange traded and over-the-counter ("OTC") securities by all Freedom group securities brokerage firms, excluding FCM, are also routed to and executed through Freedom EU.

We entered the U.S. market in December 2020 with the acquisition of FCM, a New York corporation that is a registered agency-only execution broker-dealer on the floor of the NYSE. FCM is a member of Nasdaq, NYSE & FINRA, as well as SIPC insured. FCM provides a full range of broker-dealer services, including, research sales and trading services for institutional accounts, investment banking services such as M&A, underwriting and capital markets advisory services and a research department that provides independent and objective investment research through research reports, recommendations and investment ideas to assist customers in making informed decisions.

As of March 31, 2026, we had 1,981 employees in our Brokerage segment, including 1,966 full-time employees and 15 part-time employees.

Set forth below is an overview of the services provided by our Brokerage business.

•Securities brokerage services. We provide a comprehensive range of securities brokerage services to individuals, businesses and financial institutions. Depending on the region, our brokerage services may include securities trading and margin lending. Customers can establish accounts and conduct securities trading with transaction-based pricing both through online tools and at retail locations. We market our brokerage services through a number of channels, including telemarketing, training seminars and investment conferences, print and online advertising using social media, mobile app and search engine optimization activities. We offer full-service retail brokerage services covering a broad array of investment alternatives including exchange-traded and over-the-counter corporate equity and debt securities, money market instruments, derivatives, government bonds, and mutual funds. A substantial portion of our revenue is derived from commissions from customers through accounts with transaction-based pricing. Brokerage commissions are charged on investment products in accordance with a schedule that aligns with local practices in the markets where we operate. We provide our brokerage customers with access to the U.S. stock markets, and a significant amount of our brokerage business relates to trading in U.S.-exchange listed and OTC securities by our brokerage customers.

A majority of our non-US customer brokerage transactions are executed through over-the-counter (OTC) arrangements with our non-U.S. market maker customer. All such transactions are carried out under margin-trading principles. These transactions are typically internalized with the market maker customer acting in the principal capacity and are settled on a cash basis through a prime broker and clearing firms. Under this margin-account settlement process, the securities are credited to the purchaser and, where necessary, borrowed by a market maker customer within the prime broker's and clearing firm’s custody, thereby eliminating any external

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delivery or locate requirement at execution. Relevant short positions are sufficiently collateralized by securities and cash in the market maker customer's margin account. We use the services of third-parties, including some U.S.-registered securities broker dealer and clearing firms to execute our trades. Our execution practices are designed to provide competitive outcomes for customers, including access to a broad range of liquidity sources, efficient price formation, and adherence to internationally recognized standards for best execution. We apply risk management controls that include counterparty oversight, exposure monitoring, and sufficient collateralization.

These execution models differ from those employed by U.S. broker-dealers that operate within U.S. domestic clearing and custody frameworks. Market structures, execution logistics, and post-trade arrangements may vary across jurisdictions, where we operate and may not be directly comparable to U.S.-based models.

For individual and institutional brokerage customers, we may enter into arrangements for securities financing transactions in respect of financial instruments held by us on behalf of the customer or may use such financial instruments for our own account or the account of another customer. We maintain omnibus brokerage accounts for certain institutional brokerage customers, in which transactions of the underlying customers of such institutional customers are combined in a single omnibus account with our third party broker. We may use the assets within the omnibus accounts to finance, lend, provide credit or provide debt financing or otherwise use and direct the order or manner of assets for financing of other customers of ours. See "Margin lending" below.

•Margin lending. We grant margin loans to our brokerage customers, collateralized by securities and cash in the customer's account, for application to a portion of the purchase price of securities, and we receive income from interest charged on such margin loans.

•Investment banking. Our investment banking business, which includes underwriting and market making activities, is carried out by professionals in Kazakhstan, Uzbekistan and the United States who provide strategic advisory services and capital markets products. Our investment banking team focuses on multiple sectors including consumer and business services, energy, financial institutions, real estate, technology, media and communications. In particular, in Kazakhstan many commercial banks primarily focus their financing activities on large or state-owned enterprises, and commercial lending sources impose loan structures and debt covenants that preclude many companies from obtaining such lending. This has created growing interest in and demand for our investment banking services in Kazakhstan. In the United States, our investment banking offering includes, among others, underwriting of debt and equity offerings on both a "best efforts" and a firm commitment basis. In the equity capital markets area, we offer capital raising solutions for corporate customers through initial public offerings and follow-on offerings, including listings of companies on stock exchanges. We focus on companies in growth industries and participate as market makers in our underwritten securities offerings after the initial placements of shares. In the debt capital markets area, we offer a range of debt capital markets solutions for emerging and small market cap companies. We focus on structuring and distributing private and public debt for various purposes including buyouts, acquisitions, growth capital financings, and recapitalizations. In addition, we participate in bond financings for both sovereign and corporate issuers in the emerging markets.

In our Brokerage segment we also conduct proprietary securities trading activities.

As of March 31, 2026 and 2025, respectively, we had approximately 858,000 and 683,000 total brokerage customer accounts respectively, of which more than 56% and 63% respectively had positive cash or asset account balances. As of March 31, 2026, we had approximately 149,000 active accounts, as compared to 151,000 active accounts as of March 31, 2025. We define "active accounts" as those from which at least one transaction occurred in the quarter prior to the date of calculation. The increase in the number of brokerage customer accounts between the fiscal years ended March 31, 2026 and 2025 was due to organic growth of our brokerage business.

Other Segment

As of March 31, 2026, in our Other segment we had 126 offices and 5,130 employees, including 4,930 full-time employees and 200 part-time employees, providing a range of services including payment processing, entertainment ticketing sales, online air and railway ticket purchase aggregation and an online retail trade and e-commerce services. In addition, we have established subsidiaries in Kazakhstan and UAE with a view to developing a telecommunications business and a media business, each of which is in the developmental stage. In our Other segment we also conduct proprietary securities trading activities, which are mainly conducted by FRHC. The Other segment accounted for $172.8 million, or 8%, of our total revenue, net for the fiscal year ended March 31, 2026. This revenue was mainly derived from online retail trade and e-commerce services, provision of payment processing services, retail online ticket sales and online aggregation of purchasing air and railway tickets.

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Digital Fintech Ecosystem

We operate as a single ecosystem that delivers financial services and selected lifestyle services through one login and interface. Each service is built to interoperate with the others - balances transfer instantly, loyalty rewards accrue across products and customer data is captured only once, so the combined offering is more useful to customers and more efficient for us.

According to our growth model, we add new capabilities in two ways. First, we develop products in‑house, using common technology and process for compliance with applicable laws, regulatory requirements, industry standards and internal regulations. Second, we acquire focused businesses that either deepen an existing service or introduce a complementary one. Acquired platforms are migrated to the common architecture and made available through the same front end, which preserves a seamless user experience.

Big Data and Efficiency

Our operating entities share customer transaction flows, interactions and profile updates to big data. Predictive AI models built on this consolidated record set personalized products and services, adjust credit limits, rank cross-selling offers and screen payments for fraud or sanctions within milliseconds, allowing low‑risk traffic to settle automatically while only exceptional cases move to manual review. Integration with government services enriches the dataset with verified third‑party information, so loan and account forms are pre‑filled and collateral ownership confirmed without paper, reducing onboarding from days to minutes. The combined effect - smarter targeting, faster fulfillment and fewer manual touch‑points lowers acquisition cost and raises both customer lifetime value and retention.

Freedom SuperApp

The Freedom SuperApp is the Group's front end for all retail banking, payment, insurance and lifestyle services. A single sign‑on process and biometric authentication grant access to multi‑currency accounts, credit, card management and lifestyle commerce. All modules are built on a micro‑services architecture with APIs (Application Programming Interface) to nearly one hundred government and commercial data sources.

In March 2026, monthly active users (MAU) climbed to 2.59  million, up from 1.02 million in March 2025, an increase of 154% year over year, while daily active users (DAU) averaged 634,578 compared with 183,000 in March 2025. Management attributes this expansion to the roll‑out of high‑impact digital products - notably the seven‑currency SuperCard, "one‑tap" digital mortgage and Invest Card and to the tiered loyalty and referral programs, which credit cashback in Freedom Currency and reward heavier use of contactless, in‑app and marketplace transactions.

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The table below shows the growth of our SuperApp user base for the year ended March 31, 2026.

•Online banking and government services. Freedom SuperApp provides all core banking services, including deposits, accounts, payments, and transfers, to enable clients to manage their everyday financial needs in one digital platform. In addition, the SuperApp offers access to approximately 30 government services, such as payment of taxes and fines, obtaining official certificates, and accessing digital identity documents, enabling users to complete key public-service transactions fully online.

•Accounts and payments.  The SuperApp supports accounts and payments in KZT, seven‑currency ledger (KZT, USD, EUR, RUB, CNY, TRY, AED) and Freedom Currency, an exchange‑traded note (ETN) linked to the performance of FRHC common stock (NASDAQ: FRHC). Card and wallet transactions clear through Visa and Mastercard.

•Wealth integration. The My Assets dashboard consolidates deposit, securities, vehicle and real‑estate holdings into a real‑time net‑worth view and generates secured‑loan offers where collateral is available.

•Loyalty and reward program. A four‑tier structure (Standard, Silver, Gold, Platinum) defines monthly status on average balance, transaction count and ecosystem spend. Base cashback ranges from 1 % to 4 %, with additional incentives for near field communication (NFC) payments, in‑app purchases and partner verticals. Rewards are paid in Freedom Currency. Freedom Currency is a proprietary ETN-based loyalty and reward instrument of the Freedom ecosystem, linked to the performance of FRHC (NASDAQ: FRHC) shares and fluctuating in line with their market value. By linking everyday consumption with an investment-linked instrument, Freedom Currency encourages a shift in user mindset from purely consumer behavior toward long-term investment thinking. Freedom Currency can be used for payments, transfers, and financial operations both within the ecosystem and beyond it.

•Lifestyle marketplace.  Embedded verticals include ticketing (cinema, concerts via Freedom Ticketon), travel bookings (Freedom Travel), streaming services (Freedom Media), grocery delivery (Arbuz), on‑demand home services (Naimi), news feed (Super Journal), health services (My Health), auto accessories and tires (Freedom Drive), mobile phones and electronic devices (Freedom Mobile), travel e-SIM, a digital pharmacy, motor accident reporting and Europrotocol‑based insurance claim filing without police involvement (DTP.kz), a social‑commerce feed where users publish purchases to earn likes and points that drive enhanced cashback (Freedom Lenta), digital issuance and servicing of voluntary health, motor and financial-protection insurance policies, and a government e-services gateway enabling online document processing, tax and fine payments and submission of applications to state agencies. Customers elect to pay in cash, by installment credit or with accumulated loyalty rewards.

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•Credit products. All core lending lines operate on the same end‑to‑end digital rail inside the SuperApp. Applicants authenticate with biometric ID, whereupon the platform automatically pre‑loads supporting data:

◦Digital mortgage. Property details, income records and tax data are pulled automatically from state registries; an Automated Valuation Model supplies the valuation, and loan documents are e‑signed. Average time from application to disbursement is under 24 hours, versus several weeks under the legacy process.

◦Digital auto loan. VIN and pricing data stream in real time from more than 300 partner dealerships and the national vehicle register. Compulsory car insurance is bundled automatically, contracts are e‑signed, and funds reach the dealer the same day, allowing immediate vehicle delivery.

◦Digital business loan. Secured and unsecured loans for individual entrepreneurs of up to KZT 100 million with tenors of up to five years. The scoring model analyzes the customer’s transaction activity within the Bank, as well as tax payments, payroll fund payments, e-government data, and credit bureau updates related to the individual entrepreneur. Property valuation is also performed using an Automated Valuation Model (AVM). Eligible customers see a personalized offer on the home screen of the Freedom Business mobile application, confirm the offer using biometric authentication, and funds are credited to the entrepreneur’s account opened with the Bank within minutes. No separate application, branch visit, or tax declaration is required.

◦Digital cash loan. Unsecured cash loans of up to KZT 8 million for tenors of up to five years are originated entirely within the SuperApp. Income, tax, and credit history data are automatically retrieved by the system; the customer selects the loan amount, tenor, and repayment method (annuity or equal installments) through the in-app calculator, signs the agreement electronically, and the funds are credited to the customer’s card on the same day. The following disbursement logic applies: if the loan amount is up to KZT 600,000 and the borrower is under 40 years old, the loan proceeds are credited on the same day. If the loan amount exceeds KZT 600,000, the funds are placed on hold for 24 hours. In cases where the borrower is over 40 years old, the funds are also placed on hold for 24 hours regardless of the loan amount. Partial and full early repayment are available at any time without penalties or prepayment fees.

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•Card products. Freedom Bank offers a comprehensive suite of Visa and Mastercard card products, which can be issued, managed and fully integrated within our innovative mobile application SuperApp. These cards can be effortlessly printed directly at Bank’s Cardomat kiosks after completing biometric KYC verification. A card account may be opened in a seven-currency (KZT, USD, EUR, RUB, CNY, TRY, AED) and can be quickly tokenized for Apple Pay, Google Pay, or Samsung Pay within minutes.

◦SuperCard (flagship multi‑currency debit). Our SuperCard allows users to hold balances in any of the seven currencies while earning daily interest. The card features unique collectible designs licensed from popular franchises such as The Lord of the Rings, Game of Thrones, the DC series, Naruto, and Rick & Morty. This strategy targets the mass-affluent and Gen Z markets, driving organic social media promotion. In 2025, the Group expanded our collectible lineup through a co-branded edition featuring Spanish footballer Lamine Yamal, the famous musician Dimash Kudaibergen. In 2026 new creative card designs were launched with Messi, Anarbekov.

◦Invest Card (brokerage‑linked).  The Invest Card is linked to a customer’s brokerage account, with the ability to manage investment account. Card can be opened as digital and well as physical plastic. Cardholders can use their brokerage funds for everyday purchases, while any unspent balance remains invested, providing liquidity for trading. This innovative product, a first for Kazakhstan, significantly enhances customer engagement and boosts interchange income.

◦Power Card (parental‑control prepaid). Designed for children aged 5 to 18, the Power Card enables parents to set spending limits, block specific merchant categories. We also integrate with educational platforms to offer cashback rewards for good grades, promoting financial literacy and fostering customer loyalty among the next generation.

◦Premium Deposit Card (Visa Infinite / Mastercard World Elite). This premium card comes with deposit account, offering benefits such as global lounge access, concierge service, travel insurance, and enhanced loyalty rewards. This card operates as a multi-currency deposit account that accrues daily interest, with spending automatically debited from the deposit balance.

◦Araldy Saqta (ESG card). A multi-currency deposit card that allows to transfer 10% of cashback from transactions. Accumulated cashback is automatically transferred to a public association dedicated to the restoration of the Aral Sea ecosystem. The organization's mission is to assist local communities in adapting to climate change, restoring the ecosystems of the Aral region, and planting forests on the dried-up bottom of the Aral Sea.

◦Salary Project. Corporate employers may enroll their workforce in our salary project, under which employees receive compensation directly onto a Freedom Bank card. The cardholder activates the salary feature on an existing Freedom Bank card in-app through the Freedom SuperApp; once activated, the card is enabled to receive payroll credits and the cardholder qualifies for preferential pricing on selected credit products and other benefits available within the Freedom ecosystem. Participating employers may also commission a customized digital card design reflecting their corporate identity, supporting deployment across a range of industries, including the sports, education and healthcare sectors.

•Technology, big‑data analytics, security and compliance. A central data lake ingests click‑stream activity, transaction records, credit‑bureau updates and third‑party feeds (e.g., property registries, vehicle VIN databases). The dataset anchors all advanced analytics:

◦Proprietary scoring models combine multiple behavioral and financial variables to inform loan decisions and credit‑line recalibrations.

◦Real‑time antifraud and sanctions screening leverage graph analytics against Dow Jones, World‑Check and national registries.

◦Personalized product recommendations and loyalty boosters are generated by machine‑learning models that evaluate balance trends and purchase histories.

Big‑data platform reduces manual compliance processing times from up to two days to approximately eight minutes, while maintaining independent audit‑trail requirements.

Freedom Business - SME Functionality

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Our Freedom Business mobile application is a full-featured mobile bank designed for individual entrepreneurs. It provides customers with 24/7 mobile access to financial management tools, including access to current accounts, balance monitoring, account detail viewing, and statement downloads. The app enables customers to perform a full range of transactions, such as payments to counterparties, transfers to the state budget, internal account transfers, and payroll management, including direct transfers to employees. The application also includes advanced acquiring functionalities, such as online ordering of POS terminals and corporate cards, accepting payments via QR code, and monitoring sales analytics. In addition, Freedom Business integrates various value-added services, including the AirShop partner marketplace builder enabling customers to launch an online store within minutes, an AI assistant, access to credit products, and a cashback loyalty program.

Tradernet Platform

Tradernet is our flagship online trading platform designed for a wide range of investors, offering a comprehensive and user-friendly trading experience. The platform allows users to trade a diverse array of financial instruments, including stocks, options, and ETFs from major global exchanges such as KASE, AIX, NYSE, Nasdaq, ATHEX, the London Stock Exchange, the Chicago Mercantile Exchange, the Hong Kong Stock Exchange and Deutsche Börse, EUREX, ICE, SGX, HKFE, CFE, CBOE Europe and ITS.

•Accessibility and user interface. Accessible via both web and mobile platforms, Tradernet allows users to monitor and manage their investments in real-time from any location with internet connectivity. The platform's interface is designed to be intuitive and customizable, offering tools for technical analysis, portfolio management, and market monitoring. These features cater to both beginner traders, who benefit from the platform's simplicity, and advanced traders, who appreciate its sophisticated analytical tools.

•Data platform and operational efficiency. Tradernet features an advanced order routing system that facilitates trades to be executed at the best possible prices by directing orders to the most favorable markets. At the heart of Tradernet is a robust data platform that provides real-time market data and analytics. This platform supports various trading activities by offering comprehensive data on securities, enabling users to make informed decisions. The back-end infrastructure of Tradernet is designed to handle high volumes of transactions securely and efficiently, promoting the platform's reliability and performance even during peak trading times. Tradernet back office solutions automate many administrative processes, reducing the need for manual intervention and minimizing errors. The back-office system handles transaction processing, compliance checks, and real-time account monitoring, for smooth and efficient operations. The integration of Tradernet's back-office system with the trading platform allows for the efficient management of trading accounts and commissions, which helps to enable accurate reporting and payment processing. Compliance and risk management are integral parts of Tradernet's back-office solutions. The system includes advanced compliance features to enable trading activities to adhere to relevant regulations, which is crucial for maintaining the platform's integrity. Additionally, risk management tools help monitor customer positions, margins, and overall exposure, providing timely alerts and advice to manage risks effectively.

•Education and support. Tradernet places a strong emphasis on customer education and support, providing extensive resources such as tutorials, webinars and market analysis reports. This enables users to make informed trading decisions. The platform also offers customer support to assist users with any issues they may encounter.

Telecommunications, Cloud Services, and Media

In alignment with our digital fintech ecosystem strategy, we are seeking to expand by developing our telecommunications and cloud services in Kazakhstan and a regional media business in Central Asia.

We are seeking to establish a new independent telecommunications operator in Kazakhstan to provide a diverse range of telecommunications and telecommunications-related services to customers which may include, among others, high-quality internet connectivity, fixed wireless access (FWA), WiFi access, over-the-top (OTT) streaming, internet protocol television (IPTV), traffic transit for operators and cloud solutions, subject to obtaining applicable licenses, acquisitions of telecom assets or entering into partnerships where required. Our new telecommunications business is operated by Freedom Telecom, a wholly-owned subsidiary of FRHC incorporated under the laws of the AIFC.

Freedom Telecom represents a new line of business. Its strategy and budget are evolving dynamically in response to internal developments and external market factors, which may result in material adjustments to this strategy and our plan to develop this business. Our plan is that our telecom services will be offered as a separate product and as bundles with our other digital products and services and will expand the ecosystem’s reach to areas where traditional banking channels are

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less efficient. Management expects the FWA grid to evolve into the backbone for a future mobile operator, providing additional distribution capacity for our digital services and generating new data streams that feed our predictive AI models. The combined effect should widen our addressable market, deepen engagement across product lines and further reduce the unit cost of serving each customer.

Through entities incorporated under AIFC laws, we also operate Freedom Cloud which is structured as a standalone business line. Freedom Cloud is an essential component of our digital ecosystem that delivers advanced cloud infrastructure and related services both within the Group and to external clients, including major enterprises and government entities.

During fiscal 2024, we established Freedom Media as a subsidiary of Freedom Telecom. Freedom Media is intended to develop into a national media platform in Kazakhstan, offering streaming services to customers in Kazakhstan and the broader Central Asia region. The platform provides access to a library of more than 5,000 titles, including television series, films, documentaries from major international studios and in-house produced original content, as well as more than 100 television channels and a dedicated children’s section. Its sports offering includes regular broadcasts of football, UFC, tennis, basketball and hockey, and live streaming of major events, including the UEFA Champions League and other global competitions. Freedom Media also develops proprietary content, including original series and special projects, and is integrated within the Freedom SuperApp ecosystem.

AI Data Center in Kazakhstan

In November 2025, we signed a non-binding memorandum of understanding with the Kazakhstan Ministry of AI and Digital Development and NVIDIA Corporation with a view to develop a large-scale AI data center in Kazakhstan. This prospective growth project is expected to be implemented in phases. According to our preliminary internal estimate, which is subject to significant change based on the final scope and configuration, the initial investment in the project may be approximately $2 billion, of which we intend to seek external financing for a significant portion of this investment. The project remains subject to feasibility analysis and obtaining financing. For a discussion of risks relating to the development of the AI data center see "Our investments in AI data center infrastructure utilizing advanced GPUs, including those supplied by NVIDIA Corporation, may not be successful and could materially adversely affect our business, financial condition, and results of operations." in "Risks Related to our Business and Operations" in "Risk Factors" in Part I Item 1A of this annual report.

INFORMATION TECHNOLOGY

Our business model places heavy reliance on information technology to offer customers a seamless digital experience, meet their diverse needs, in adherence to regulatory requirements and information security standards. To support sustainable development and growth of a digital fintech ecosystem, we focus on the continuous development of our information technology systems empowering customers with accelerated time-to-market for digital products while enhancing predictability. We seek to harmonize technology governance approaches across all of our businesses and centralize key IT and information security processes.

We have developed a technology strategy aimed at building a robust technological infrastructure, fostering innovation, and enhancing user experiences. This strategy is designed to leverage technology as a key driver of success within our group. We seek to continuously adapt to the rapidly evolving digital landscape and to align our technological capabilities with the changing needs of our customers and stakeholders. By fostering innovation, enhancing collaboration, and prioritizing business continuity and growth, we aim to establish a strong technological foundation that supports our strategic objectives. See "Digital Fintech Ecosystem" above.

COMPETITION

We continue to face intense and evolving competition across all regions and service areas in which we operate. The financial services and brokerage industries, in particular, remain highly competitive and are marked by rapid technological advancements, changing regulatory frameworks, and increasing customer demand for integrated digital solutions and global market access.

We compete with international, regional, and local brokerage, banking, and financial services firms, many of which offer a broader array of services, possess greater capitalization, have more extensive global presence and advanced infrastructure, and benefit from well-established brand recognition. However, we believe our focus on innovation, customer-centric technology, and regional market expertise gives us distinct competitive advantages. In Kazakhstan, our home biggest market, our competitive positioning is supported by the development of our Freedom SuperApp, an all-in-one platform integrating banking, payments, insurance and lifestyle services. The Freedom SuperApp enhances customer engagement, supports cross-selling across our financial and non-financial offerings, and embeds our services more deeply into customers’ daily financial activities, creating for us a scalable and defensible competitive advantage.

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In Kazakhstan, our primary competitors in the brokerage space remain Halyk Finance, BCC Invest, Teniz Capital Investment Banking and United Group Alatau. While these firms benefit from strong domestic reputations and relationships, our integration with global capital markets through direct access to U.S. and European exchanges - coupled with digital brokerage infrastructure - positions us as a leader in cross-border investment facilitation in Central Asia.

In the banking sector, Freedom Bank KZ continues to expand its footprint. Its main competitors include Halyk Bank, Kaspi Bank, and Bank CenterCredit. While our competitors maintain dominant positions in retail and SME and pursue similar digital ecosystem development strategies, we differentiate ourselves through our investment-driven banking model, digital-first service delivery, and the unique synergy between our banking and brokerage operations, enabling seamless integration of financial services on a single platform.

In the insurance sector, Freedom Life and Freedom Insurance, operate in Kazakhstan's competitive life and general insurance markets. Key life insurance competitors include Halyk-Life, Nomad Life, and European Insurance Company (EIC). In the non-life insurance segment, our main competitors are Eurasia Insurance Company, Kommesk-Omir, and Victoria Insurance Company. While these firms benefit from scale and long-standing market positions, we differentiate our offering through digital-first distribution, investment-linked insurance products, and integration with our banking and brokerage platforms.

In Europe, we compete with digital-first brokers such as eToro and Interactive Brokers. These firms offer scale, brand recognition, and user engagement through social trading (eToro) and broad market access (Interactive Brokers). Nonetheless, our European customers benefit from curated research, access to U.S. pre-IPO markets, and personalized service tailored to emerging market investors seeking to diversify internationally areas where we maintain a niche edge. In the United States, our competition includes boutique investment banks and capital markets firms such as Needham & Company, Craig-Hallum Capital Group, and Oppenheimer & Co. These institutions have longstanding customer bases and capital markets experience. However, we aim to distinguish ourselves by leveraging our cross-border capital raising capabilities, our presence in fast-growing emerging markets, and our strength in supporting undercovered issuers.

During fiscal 2026, we continued our strategic expansion into the telecommunications and media sectors in Kazakhstan. As a result, we also face competition from leading telecommunications operators, such as Kazakhtelecom, Tele2/Altel, and Beeline Kazakhstan, as well as from domestic and international media content providers. This expansion remains aligned with our vision of becoming a digital ecosystem that connects finance, media, and communications.

HUMAN CAPITAL

Our human capital strategy is designed to support the Company’s continued growth as an integrated financial and digital ecosystem operating across multiple jurisdictions. Our business requires a workforce with capabilities spanning regulated financial services, technology and product development, customer operations, risk management, compliance, cybersecurity, and corporate infrastructure. As we expand our geographic presence and broaden our ecosystem offerings, we focus on attracting, developing, integrating, and retaining talent capable of operating in a dynamic, technology-enabled, and highly regulated environment.

As of March 31, 2026, we had 11,846 (11,627 full-time and 219 part-time) employees spanning 22 countries in the following regions: Central Asia - 10,830, Europe - 334, Middle East - 627, USA - 55). As of March 31, 2026, our workforce was 5,448 women and 6,398 men.

We view human capital as a key enabler of our long-term growth, innovation, customer trust, and operational resilience. Our human capital priorities are aligned with our strategic direction and include:

•attracting specialized talent in financial services, technology, data, risk, compliance, and infrastructure;

•developing leaders and critical specialists to support business growth and international expansion;

•enabling collaboration and internal mobility across functions, businesses, and jurisdictions; reinforcing a culture of performance, ethics, and accountability;

•and supporting employee engagement and retention in competitive labor markets.

Talent Acquisition, Development and Mobility

We seek to attract talented and capable employees through disciplined recruitment processes tailored to the requirements of specific roles, businesses, and jurisdictions. Our hiring decisions are based on professional qualifications, relevant experience, capability, and alignment with our standards and business needs. As our organization continues to grow and diversify, we place particular emphasis on attracting leaders and specialists who can operate effectively in regulated industries, support innovation, and contribute to the scaling of our ecosystem.

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We invest in employee development through onboarding, professional training, managerial development, mentoring, and cross-functional learning opportunities. We believe that capability-building supports both employee growth and stronger enterprise execution. Our development approach is intended to strengthen technical, managerial, regulatory, and leadership capabilities and to support collaboration across our businesses and markets.

As we continue to expand our digital ecosystem, we place growing emphasis on building talent in technology, data and product-related capabilities. This includes attracting, developing and retaining professionals in software engineering, platform architecture, data analytics, AI, information security, and digital product management, as well as leaders who can translate these capabilities into scalable business outcomes. We believe these skill sets are essential to enhancing customer experience, improving operational efficiency, supporting data-driven decision-making, strengthening control environments, and enabling innovation across our ecosystem. We seek to develop these capabilities through targeted hiring, internal development, and close collaboration among business, technology, risk and control functions so that our digital infrastructure and talent base can continue to evolve alongside our strategic objectives and regulatory requirements.

We also support employee mobility within the Company, including vertical and horizontal career movement, participation in cross-functional projects and working groups, and exposure to different business lines and operating environments. We believe that internal mobility and cross-functional experience contribute to leadership development, knowledge transfer, organizational cohesion, and the development of a stronger internal talent pipeline.

Culture, Performance and Leadership

We seek to foster a culture that supports disciplined execution, innovation, customer focus, and responsible growth. Because we operate in multiple jurisdictions and regulated industries, we place particular emphasis on ethical conduct, professionalism, compliance with applicable laws and internal policies, and protection of customer, employee, and business partner data. We believe these standards are critical to maintaining our reputation, supporting sustainable growth, and serving our stakeholders effectively.

We aim to provide employees with clear performance expectations, appropriate tools and support, opportunities for growth, and recognition for strong performance. We believe that a high-performance culture is strengthened by accountability, continuous development, and alignment between individual contributions and the Company’s strategic priorities.

Our leadership development efforts are intended to strengthen management capabilities, support succession readiness in key roles, and build a pipeline of leaders who can guide our businesses through growth, operational complexity, and international expansion.

Compensation and Benefits

Our compensation philosophy is designed to attract and retain talent, support performance, and reinforce accountability, while remaining competitive in the markets in which we operate. Compensation packages vary by role, business, and jurisdiction, but generally include base pay, performance-based incentives, paid time off, and other benefits.

Senior management compensation is designed to align remuneration with business performance, prudent risk-taking, and long-term shareholder value creation. Compensation generally consists of: (i) fixed base salary, (ii) annual performance-based cash incentive, and, where applicable, (iii) long-term incentive compensation, including equity-based awards, in each case subject to the Company’s internal governance and approval processes.

Variable compensation is determined by considering a combination of corporate, business-unit, and individual performance metrics. These metrics may include financial performance, strategic execution, operational delivery, cost discipline, leadership objectives, compliance, and control of environment effectiveness. For senior leaders in regulated, financial, or control functions, performance assessment also incorporates risk-adjusted and non-financial factors, including risk management, regulatory compliance, internal controls, audit findings, governance, and conduct.

Senior management compensation arrangements are overseen through the FRHC's governance framework, including review by the Compensation Committee, which provides oversight of executive compensation structures, incentive design, and alignment with performance and risk management principles.

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FRHC retains discretion, consistent with its policies and governance framework, to adjust variable compensation outcomes upward or downward based on overall performance, risk outcomes, conduct, compliance matters, and other relevant considerations.

Compensation decisions generally take into account factors such as individual performance, scope of responsibilities, market conditions, internal equity, tenure, and local practices. We believe our approach to compensation and benefits supports employee engagement, retention, and our ability to compete for talent in the labor markets in which we operate.

Human Rights

Our approach to respecting human rights and managing related risks is set forth in our Human Rights Policy adopted by our Board in 2024. It affirms our commitment to respect human rights in accordance with the United Nations Universal Declaration of Human Rights. The Policy includes our human rights commitments in relation to employees, customers, business partners, and local communities, and is compulsory for all directors, officers and employees of FRHC, our subsidiaries, and individuals acting on the Company's behalf.

We are committed to providing equal opportunities and non-discrimination in the recruitment and employment processes. We oppose modern slavery and human trafficking, child and forced labor, and do not tolerate any violence or harassment in the workplace. We provide decent working conditions, development opportunities and respect the data of employees, customers, and business partners.

ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG)

Today, ESG principles are essential in determining the direction of development of companies that are committed to a responsible approach to the impact of their activities on the environment, society, and economy. The Company is among them, and we have been working extensively in this direction.

Since 2023, FRHC discloses its sustainability data on its website. The data is prepared with a view to aligning with the Global Reporting Initiative (GRI) Standards and the Sustainability Accounting Standards Board (SASB) Standards.

Social

We place strong emphasis on having a favorable working environment and supporting our employees and serving the communities in the regions where we operate.

Employee Development and Corporate Activities

We recognize that success is inextricably linked to well-developed human capital, and we seek to attract the most qualified persons for our workforce. We invest in enhancing employees' professional knowledge, skills, and abilities by allocating funds for training and implementing free corporate educational activities available online.

We have established principles of ethical behavior that are contained in our Code of Ethics and Business Conduct, which defines the norms and standards to which all employees of our company must adhere. We pay attention to the personal and career development of our personnel.

Our subsidiaries offer a range of benefits packages, including corporate communication services, gym membership subsidies, and benefits related to certain of the Company's banking and insurance products. We also strive to foster a healthy work-life balance for our employees. To support this, we organize corporate events, holidays, team-building activities, and sports tournaments in chess, football and running.

Shapagat Corporate Fund

Our Freedom Shapagat Corporate Fund (the "Fund"), established in August 2023, is a non-profit organization and a subsidiary of FRHC. It was created through voluntary contributions from FRHC and its subsidiaries. The Fund serves as a centralized platform for managing and coordinating all sponsorship and charitable initiatives across the Company, ensuring a structured, transparent, and strategic approach to social investments.

Through collaboration with a wide range of partners, the Fund implements initiatives in social development, charity, culture, education, environmental protection, and sports, as well as other areas that contribute to broader societal impact and support the achievement of the United Nations Sustainable Development Goals.

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External Social Projects

We endeavor to support and contribute to sports, culture, and education in the communities in which we operate through various forms of financing, including charity and sponsorship activities via the Fund and other subsidiaries of FRHC. In fiscal year 2026, the support we provided for such activities included the following:

•We continued our support for the development of chess in Kazakhstan. During fiscal year 2026, the Fund has made financial contributions to the Kazakhstan Chess Federation to promote chess education in Kazakhstan and strengthen the country's international performance at major global tournaments. The Fund expanded its contribution to chess development throughout 2025 by hosting World School Team Chess Championship and the "Chess in Education" Scientific Conference.

•The Company continued supporting the development of sports in Kazakhstan. In 2025, the Company launched the construction of a football academy in the city of Karaganda. It will also provide football programs for residents of underserved areas who currently have limited or no access to organized training. The Fund also supported the participation of football club FC Zhenis in national competitions throughout the 2025 season and provided equipment for the children's teams of the football center of FC Shakhter.

•As part of our overarching commitment to promoting sports in Kazakhstan, we particularly pay attention to inclusive sports. Thus, the Fund sponsored the "“UNI FOOTBALL LEAGUE" project, which offers inclusive football sections for children with special needs. The initiative enables children with diverse physical and cognitive abilities to play football, boosts their physical activity and helps develop social skills.

•We continued supporting the "Teach for Qazaqstan" initiative with funds covering operational costs and holding educational events. As part of the initiative, teachers receive access to master classes, seminars and specialized training modules aimed at creating a supportive and stimulating learning environment.

•We expanded opportunities for youth through educational grants and scholarships. In 2024, we launched the Freedom Grants social project, which offers prospective students the opportunity to win an educational grant at regional universities in Kazakhstan. This initiative covers tuition fees throughout their studies to help motivated young people who may face financial barriers. We also provided sponsorship to the IQanat Educational Fund to organize an academic Olympiad that identifies motivated rural students and provides the selected schoolchildren with free three-year preparation for applying to scholarship-based programs. Furthermore, the Fund provided sponsorship to the Karagandy Buketov University to support 10 student scholarships.

•Following its ambition to support the development of local cultural institutions, the Company provided support to the renovation of Lermontov National Theatre in Almaty.

•We supported the development of the Reception House in Astana, a civic and cultural infrastructure project located in Presidential Park along the city's riverfront area. The project supports Astana's long-term urban development by strengthening public event infrastructure and creating a venue for official, cultural, and community-oriented activities. Located within a public park environment, the facility is expected to contribute to the quality of the surrounding public space and serve residents, visitors, and international guests.

The education center Freedom Academy provides online and in-person training courses and webinars in financial literacy to the public. The goal of this program is to generally expand knowledge about financial literacy and teach the basics of exchange trading so that participants can more knowledgeably trade and reduce the risk of financial mistakes in the future.

Environment

In fiscal year 2026, we continued conducting ESG diagnostics to identify key opportunities and recommendations for improving the efficiency of our environmental activities.

In July 2025, the Company adopted its Environmental Policy, which outlines the overarching principles the Company applies for a careful and responsible approach to managing environmental impacts arising from its operational activities.

In 2026, an annual climate risk assessment was conducted to determine the potential exposure of the Company’s investment, insurance, and operational activities to climate-related risks. For the first time, the Company's lending portfolio was also included in the assessment. This assessment forms part of the Company's efforts to establish a consistent and comprehensive approach to climate risk management.

External Environmental Projects

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In 2025, through the Fund, the Company continued providing financial support for the project focusing on planting black saxaul and other salt-tolerant plants on the dried-up bed of the Aral, aiming to restore the ecosystem of the region, which suffers from a long-term ecological crisis due to the sea's deterioration.

In 2025, the Company, in collaboration with the Kazakhstan's Ministry of Ecology and Natural Resources, began implementing a project dedicated to restoring the Turan tiger population in Kazakhstan. The project was initiated at COP29, when both parties signed a memorandum on environmental initiatives support. This ambitious project constitutes another milestone for the Company's action to recover biodiversity and land-based ecosystems.

As part of our efforts to build climate resilience and promote sustainable development, the Fund supported the Eco-Aul project in the village of Zhinishkekum, located in the Aral district of the Kazakhstan's Kyzylorda region. This initiative helps local communities adapt to environmental challenges by providing sustainable access to basic vital resources, including clean water, energy, and medical services. The project seeks to implement a pilot program on the grounds of a rural high school, serving as a model for environmental sustainability with the possibility of further scaling across the region.

INFORMATION SECURITY

Information security, with a particular focus on cybersecurity, is a high priority for us. We have and continue to develop and implement safeguards, policies and technology designed to protect the information provided to us by our customers and our own information from cyber-attacks and other misappropriation, corruption or loss. We also consult advisory organizations and follow regulatory requirements regarding information security. For a discussion of risks relating to information security see "Risks Related to Information Technology and Cybersecurity" in "Risk Factors" in Part I Item 1A, and "Regulation" in "Business" in Part I Item 1 of this annual report.

INTELLECTUAL PROPERTY

We rely principally on a combination of trademark, copyright, related rights and trade secret laws in the jurisdictions in which we operate as well as confidentiality procedures and contractual provisions to protect our proprietary technology and our brands. We enter into confidentiality agreements with our employees and consultants and confidentiality agreements with other third parties, and we rigorously control access to our proprietary technology.

We generally obtain trademark protection and often seek to register trademarks for the brand names and images under which we market our services. As of March 31, 2026, we owned approximately 14 registered trademarks in Armenia, 13 in Cyprus and its European subsidiaries, 12 in Kazakhstan, 10 in the United Kingdom, 7 in Türkiye, 2 in Azerbaijan and 1 in Kyrgyzstan. We use a third-party brand protection service to monitor our trademarks for unauthorized use on the Internet.

Our flagship technology product is our proprietary Tradernet software platform. We also believe our "Freedom" and other brands contribute to the appeal and success of our services. Despite our efforts to protect our intellectual property rights, unauthorized parties may attempt to copy or otherwise obtain and use our brands and technology. In addition, third parties may initiate litigation against us alleging infringement of their proprietary rights or declaring their non-infringement of our intellectual property rights. Effective intellectual property protection may not be available in all jurisdictions in which we offer our services. Further, we may be unable to obtain protection for our intellectual property in the future. See also "We may fail to adequately obtain, maintain, enforce and protect our intellectual property and similar proprietary rights, which may harm our business and competitive position." in "Risk Factors" in Part I Item 1A of this annual report.

REGULATION

We operate in highly regulated industries across multiple legal jurisdictions. The securities trading, banking, insurance, payment services and telecommunications business activities of our subsidiaries are subject to extensive regulation and oversight by the stock exchanges, central/national banks, governmental and self-regulatory authorities in the jurisdictions where we conduct business. We anticipate that the regulatory environment will continue to evolve, increasing standards and introducing new regulations that we will need to comply with in a timely manner.

We operate under various securities trading, banking, insurance, and other financial services licenses and must maintain our licenses in order to conduct our operations. As of March 31, 2026, we, through our subsidiaries, held (a) brokerage licenses (i) in Kazakhstan issued by the NBK and the Astana Financial Services Authority (the "AFSA"), (ii) in Cyprus issued by the Cyprus Securities and Exchange Commission ("CySEC"), (iii) in the United States issued by FINRA, (iv) in Armenia issued by the Central Bank of Armenia, (v) in Uzbekistan issued by the Center of Coordination and Development of Securities Market, (vi) in Kyrgyzstan issued by the Financial Market Regulatory and Supervision Service under the Ministry of Economy and Commerce of the Kyrgyz Republic, and (vii) in UAE issued by the Abu Dhabi Global

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Market Financial Services Regulatory Authority; (b) a banking license for foreign currency operations in Kazakhstan issued by the ARDFM; (c) banking licenses (i) in Kazakhstan for corporate and retail banking services issued by the ARDFM (including for currency exchange operations), and (ii) Tajikistan issued by the National Bank of Tajikistan; (d) a payment service provider in Kazakhstan registered in such capacity with the NBK, payment services providers in Uzbekistan and Kyrgyzstan holding licenses from the Central Bank of Uzbekistan and the National Bank of the Kyrgyz Republic, respectively; (e) a securities portfolio management license in Tajikistan issued by the Ministry of Finance of Tajikistan, and (f) virtual asset exchange operator license in Kyrgyzstan issued by the Financial Market Regulatory and Supervision Service under the Ministry of Economy and Commerce of the Kyrgyz Republic. Our U.S. broker-dealer subsidiary FCM is subject to regulatory oversight by relevant U.S. authorities, including the SEC and FINRA, with respect to its brokerage and investment advisory activities in the U.S.

Subject to completion of the acquisition of approximately 99.32% of the issued share capital of Turkish Bank A.S., we expect to obtain control of the bank, which holds a banking license in Türkiye. We are also taking steps to establish a bank in Georgia which is subject to obtaining the required regulatory approvals. In addition, we are in the process of obtaining a license to provide brokerage services in Türkiye following our receipt of a principal approval by the Türkiye's financial regulatory and supervisory authority in fiscal 2025.

Our Kazakhstan telecommunications and media subsidiaries hold licenses for providing local telephone services, internet access, TV and radio broadcasting, services for identifying technical information leakage channels and conducting technical operational investigative activities as well as designing and constructing telecommunication networks. As a result, our telecommunications and media businesses are subject to a range of regulations, including certification and other technical qualification requirements, as well as media content, data protection and AI laws, with which we must comply.

In the jurisdictions where we conduct business, we are subject to often overlapping schemes of regulation that govern many aspects of our relationships with our customers. These regulations cover a broad range of practices and procedures, including:

•minimum net capital and capital adequacy requirements;

•the use and safekeeping of customers' funds and securities;

•recordkeeping and reporting requirements;

•customer identification, clearance and monitoring to identify and prevent money laundering and funding of terrorism, U.S. Department of Treasury's Office of Foreign Assets Control ("OFAC") and other non-U.S. sanctions violations, to follow FATF recommendations;

•tax reporting obligations under QI, FATCA and CRS regulations;

•supervisory and organizational procedures intended to monitor and assure compliance with relevant laws and regulations and to prevent improper trading practices;

•employee-related matters, including qualification and certification of personnel and senior management;

•provision of investment and ancillary services, clearance, and settlement procedures;

•maximum loan and bank guarantees concentration issued to shareholders and group of borrowers;

•credit risk requirements;

•liquidity risk requirements;

•acquisitions;

•investment limitations;

•competition;

•IT, information security, data protection and AI;

•risk detection, management, and correction; and

•various shareholders' requirements required for obtaining regulatory status (banking holding, major shareholder, insurance holding, etc.).

The regulatory authorities in each jurisdiction where we are regulated establish minimum net capital and capital adequacy requirements, which as of March 31, 2026 range from approximately $2.1 million to approximately $231.1 million in local currency equivalents and fluctuate depending on various factors. As of March 31, 2026, the aggregate net capital requirements of our subsidiaries was approximately $518.2 million. As of March 31, 2026, aggregate excess regulatory capital for all of the operating subsidiaries was $2,688.2 million. Our regulated insurance subsidiaries are subject to regulations and standards in Kazakhstan, which require these subsidiaries to maintain specified levels of statutory capital, as defined by Kazakhstan law, and restrict the timing and amount of dividends and other distributions which may be paid to their parent company. For the fiscal years ended March 31, 2026 and March 31, 2025, our insurance subsidiaries did not pay dividends to their parent company, except for the payment of a $7.5 million dividend by Freedom Insurance to its parent company Freedom KZ in December 2025 based on its results for 2023 calendar year. In the event one or more of our subsidiaries fails to maintain minimum/adequate net capital, we may be subject to fines and penalties,

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suspension of operations, and disqualification of our management from working in the relevant industry. Our subsidiaries are also subject to rules and regulations regarding liquidity ratios. Compliance with minimum capital requirements could limit our expansion into activities and operations that require significant capital. Minimum capital requirements could also restrict the ability of our subsidiaries to transfer funds among themselves and FRHC. For more details please refer to Note 31 "Statutory Capital Requirements" in the notes to our consolidated financial statements in Part II Item 8 of this annual report.

We spend considerable resources in our general efforts to comply with the various regulations to which we are subject, and we expect this burden to continue in the future. We are from time to time subject to inquiries, investigations, audits, inspections and subpoenas, as well as regulatory proceedings brought by regulators.

Violations of securities, trading, banking, payment services, sanctions, anti-money laundering and financing of terrorism laws, rules and regulations could subject us and our employees to a broad range of disciplinary actions including the imposition of fines and sanctions, other remedial actions, such as cease and desist orders, removal from managerial positions, loss of licensing, and civil and criminal proceedings.

Anti-Money Laundering, Anti-Terrorism Funding and Economic Sanctions Laws

Anti-money laundering laws, financial record-keeping and reporting laws, and similar legislation and regulations in the jurisdictions where our subsidiaries operate, as well as certain stock exchanges and self-regulatory organizations, impose a variety of rules that require financial organizations, including registered broker-dealers, to meet "know your customer" requirements and monitor their customers' transactions for potentially suspicious activities.

OFAC, in connection with its administration and enforcement of economic and trade sanctions publishes lists of individuals and companies, known as "Specially Designated Nationals" or SDNs. Assets of SDNs are blocked, and U.S. companies are generally prohibited from dealing with them. OFAC also administers a number of comprehensive sanctions and embargoes that target certain countries, governments and geographic regions. Under our global sanctions compliance policies and procedures, we and our U.S. subsidiaries and, in certain circumstances, our non-U.S. subsidiaries may be prohibited from engaging in transactions involving any individual, entity, country, region or government that is subject to such sanctions. Additionally, our U.S. subsidiary, FCM, operates under its own U.S. sanctions compliance policies and procedures, which govern its own sanctions compliance activities with its institutional customers and with other group companies.

We are committed to compliance with all applicable economic sanctions. With respect to Russia-related sanctions, we have assessed that such sanctions applicable to our business have not materially impacted the majority of our existing retail customers. We continue to monitor all sanctions developments closely. In the case of a customer or counterparty becoming known to one of our subsidiaries to be subject to sanctions, the relevant subsidiaries take active steps so that we do not violate, or cause a violation of, applicable sanctions. In addition, where sanctions do not apply due to a lack of jurisdictional nexus, our subsidiaries also seek to avoid conduct that could create exposure to secondary sanctions, while considering potential conflicts with local regulatory requirements. As of March 31, 2026, our subsidiaries Freedom KZ, Freedom Bank KZ, Freedom Global and Freedom EU collectively had customer liabilities relating to sanctioned individuals and entities or persons whose sanctioned status was being confirmed at the time of approximately $187.8 million that represented approximately 3% of our total customer liabilities as of such date.

We use multiple third‑party databases and screening tools to perform sanctions, PEP, and adverse‑information checks as part of their onboarding and ongoing monitoring processes. In addition, we maintain omnibus brokerage accounts for certain other institutional brokerage customers. The order flow from these accounts represents transactions of underlying customers of the relevant institutions, which are executed by the relevant institutions through their omnibus accounts with us. Such institutional customers give undertakings to us by which they have agreed to comply with AML/CTF controls that are applicable to brokers. We also audit their frameworks and systems by regular risk-based sampling and have access to their underlying customer records for purposes of compliance monitoring. Nevertheless, we do not have direct access to such institutional customers' underlying customers or screening systems.

See "Our measures to prevent money laundering, terrorist financing, and sanctions violations may not be completely effective." and "Non-compliance with U.S., EU, UK or other sanctions programs could adversely impact our company." in "Risk Factors" in Part I Item 1A of this annual report.

Protection of Customer Assets

Our business is subject to extensive oversight by regulators around the world relating to, among other things, the fair treatment of customers, safeguarding of customer assets and our management of customer funds. Freedom EU is subject to the European Union Markets in Financial Instruments Directive ("MiFID") and/or related regulations and must, when holding funds belonging to customers, maintain segregated accounting of its own and customers' assets, make

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adequate arrangements to safeguard the rights of customers and maintain their records and accounts in a way that ensures their accuracy. Freedom KZ and Freedom AR are similarly obliged to maintain segregated accounting of its own and customers' assets. Freedom Global is subject to the AIFC business rules and is required to have systems and controls in place to ensure the proper safeguarding of customer assets which includes conducting proper due diligence of the third parties in which customer assets will be held and confirming that the laws and regulations that govern such third parties are appropriate.

Cybersecurity, Data Protection and AI

As part of our business, we routinely receive sensitive and confidential information from our customers. We collect personal information from our prospective and current employees, as permitted by employment laws and regulations. We use AI in some of our product, services and to advance our internal processes. We are subject laws regulating these activities in the various jurisdictions where we conduct business or have customers. This includes the requirements under the laws of Kazakhstan, the EU, the UK and the U.S., as well as the rules and regulations of their various state agencies and self-regulatory organizations.

These laws include the law on data privacy, information security and AI legal frameworks in the European Union and the United Kingdom, Kazakhstan, as well as the laws of a number of states of the United States. These laws, rules and regulations require us to maintain high standards for personal data collection, processing, and retention and impose strict standards for information security and AI risk management and reporting incidents and data breaches. They also provide for potentially significant penalties for non-compliance. For a discussion of related risks, see "Risk Factors" in Part I Item 1A and "Cybersecurity" in Part I Item 1C in this annual report.

Kazakhstan Regulation

Kazakhstan Securities Market Regulation

The Kazakhstan brokerage sector is highly regulated. The securities market in Kazakhstan is regulated in accordance with Kazakhstan law and the by-laws of the ARDFM. The Law of the Republic of Kazakhstan No. 461-II "On the Securities Market", dated July 2, 2003 (the "Securities Market Law") is the main law regulating the brokerage and dealer activities in the securities market and portfolio management activities in mainland Kazakhstan. It establishes a framework for brokers and dealers, portfolio management activities, registration and licensing requirements, and regulation of such activities by the ARDFM. Separately, the AIFC (as defined below) operates under an independent legal and regulatory regime based on principles of English common law, with financial services regulated by the Astana Financial Services Authority (AFSA). Brokerage and dealer firms licensed by AFSA and operating within the AIFC are therefore subject to a distinct set of rules and supervisory practices, separate from the national Kazakhstan legal framework. Kazakhstan mainland framework applies to the AIFC brokers to the extent relations and activities are not regulated by AFSA regulations. Given limited period of AIFC operation and limited practice of AIFC legal framework enforcement in some instances it is uncertain which regulation should apply (if any) to the activities of AIFC brokers/ dealers.

Under the Securities Market Law, broker-dealer and portfolio management activities in the securities market are carried out on the basis of a license to carry out such activities issued by the ARDFM. A license for broker and dealer activities may include the right to maintain customer accounts as a nominal holder or may not include the right to keep customer accounts. A license for portfolio management can be with or without the right to attract voluntary pension contributions.

Freedom KZ currently holds the following licenses:

• broker-dealer and portfolio management license No. 3.2.238/15 dated October 2, 2018 (initially issued on March 21, 2007); and

•banking license No. 4.3.12 dated February 4, 2020 (initially issued on April 4, 2019) for performance of exchange operations with foreign currency, except for exchange operations with cash currency.

Under the Securities Market Law (and the relevant ARDFM regulations), the following prudential standards are applicable to brokers and dealers and portfolio management companies, among others: (i) an equity capital adequacy ratio, the daily value of which must be at least 1; and (ii) a liquidity ratio, the daily value of which must be at least 1 (as a maximum value). Compliance with these prudential standards is determined in accordance with ARDFM methodologies based on, among other things: (i) highly liquid and liquid assets; (ii) balance sheet liabilities; and (iii) minimum amount of equity capital, taking into account the capital adequacy ratio.

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Based on the AIFC Framework Law dated December 7, 2015, as well as amendments to the Constitution of the Republic of Kazakhstan made in March 2017, a special legal regime for the financial sector, including the securities market, was established in the Astana International Financial Center (the "AIFC"). The current law of the AIFC consists of: (i) the AIFC Framework Law; (ii) AIFC acts that do not contradict the AIFC Framework Law and which may be based on the principles, norms and precedents of the law of England and Wales and/or the standards of the world's leading financial centers; and (iii) current Kazakhstan law, which is applied to the extent not regulated by the AIFC Framework Law and acts of the AIFC. The AIFC Acts establish the requirements for carrying out activities in the securities market in the AIFC and, in particular, the requirements for licensing regulated activities, which are carried out on the basis of a relevant license issued by the AFSA. Our Freedom Global subsidiary is a member of the AIFC and has License No. AFSA-A-LA-2020-0019 issued by the AFSA on May 20, 2020 to carry out the following major regulated activities:

•dealing in investments as principal;

•dealing in investments as agent;

•managing investments;

•arranging deals in investments;

•advising on investments;

•managing a collective investment scheme;

•providing custody in relation to digital assets and arranging custody in relation to digital assets; and

•arranging deals in investments in relation to digital assets.

Under the AIFC Framework Law and applicable acts, the following prudential standards are applicable to AIFC brokers and dealers and portfolio management companies, among others: the capital adequacy ratio, which indicator must be at least 1, and the liquid assets requirement, which indicator must be not less than 0.25. Compliance with the prudential standards is measured based on the following indicators: (i) capital resources, (ii) liquid assets, (iii) minimum capital requirement, and (iv) annual operating expenditures. In their activities, AIFC participants operating in the securities market are guided, among other things, by the provisions of the AIFC General Rules, the AIFC Conduct of Business Rules and other acts of the AIFC.

Kazakhstan Banking Regulation

Banks in Kazakhstan are subject to numerous laws and regulations governing banking activities as well as a number of laws and regulations that regulate, among other matters, payment services, anti-money laundering, data protection, AI and information security. Kazakhstan has a two-tier banking system, with the NBK comprising the first tier and all other commercial banks comprising the second tier (with the exception of the Development Bank of Kazakhstan, which as a state development bank has a special status and belongs to neither tier and Eurasian Development Bank which is an intergovernmental bank). Generally, all financial institutions in Kazakhstan are required to be licensed and regulated by the ARDFM. From 2004 to April 2011, licensing and regulation functions were carried out by the Agency of the Republic of Kazakhstan for Regulation and Supervision of the Financial Market and Financial Organizations (including its respective successors). The respective functions had been carried out by the NBK from April 2011 until the end of 2019. Starting January 1, 2020, these functions have been carried out by the ARDFM. As a central bank, the NBK has retained its role in developing monetary credit policy, currency regulation and control and payment systems.

The Law of the Republic of Kazakhstan No. 258-VIII ZRK "On Banks and Banking Activity in the Republic of Kazakhstan", dated January 16, 2026 (as amended) (the "Banking Law"), is the main law regulating the banking sector in Kazakhstan. It establishes a framework for banking activities, licensing, regulation and supervision of banks by the ARDFM. Under the Banking Law, banking operations may only be conducted pursuant to an appropriate license issued by the ARDFM. The Banking Law introduced a two-tier banking licensing regime comprising universal banking licenses and basic banking licenses. Freedom Bank KZ continues to operate under a universal banking license. Under the Banking Law and the relevant ARDFM regulations, banks in Kazakhstan holding a universal banking license are subject to prudential standards, including, but not limited to, minimum authorized and equity capital, equity capital adequacy, maximum exposure per borrower, liquidity, liquidity coverage and net stable funding, capitalization to liabilities to Kazakhstan non-residents, placement of bank funds in internal assets, leverage, and open currency position limits. Freedom Bank KZ holds License No. 1.1.108 dated June 25, 2024 for performing banking and other operations.

Kazakhstan Insurance Regulation

Insurance companies in Kazakhstan are subject to numerous laws and regulations governing general and life insurance activities as well as a number of laws and regulations that regulate particular types of insurance activities (e.g., mandatory liability insurance of vehicle owners), anti-money laundering, data protection, AI and information security. Generally, all financial institutions (including companies performing insurance activities) in Kazakhstan are required to be licensed and are then regulated by the ARDFM.

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The Law of the Republic of Kazakhstan No. 126-II "On Insurance Activities", dated December 18, 2000 (as amended) (the "Insurance Law"), is the main law regulating the insurance sector in Kazakhstan. It establishes a framework for insurance activities, registration and licensing of insurance companies and regulation of insurance activities by the ARDFM. The Insurance Law provides for a list of insurance operations that cannot be conducted without an appropriate license from the ARDFM (its predecessor) and sets forth a list of activities permitted for insurance companies. The Insurance Law (and relevant NBK regulations) establishes prudential standards applicable to insurance companies. These standards cover, among other areas, requirements pertaining to minimum authorized capital, solvency margin adequacy, the sufficiency of highly liquid assets, asset diversification, retention amounts under insurance, reinsurance, coinsurance/joint reinsurance contracts, and the maintenance of reserves for stabilization and unforeseen risks. Freedom Insurance holds license No. 2.1.28 dated March 12, 2025 for performing general insurance (reinsurance) activities. Freedom Life holds license No.2.2.14 dated July 22, 2024 for performing life insurance (reinsurance) activities.

Kazakhstan Payment Services Regulation

Payment services in Kazakhstan are mainly regulated by the Kazakhstan Law "On Payments and Payment Systems" dated July 26, 2016 (the "Law on Payments"). A "payment organization" is defined by the Law on Payments as Kazakhstan limited liability partnership which is registered as a payment organization with the NBK and which activities are associated with rendering payment services. We provide payment services in Kazakhstan through Freedom Pay LLP and its subsidiaries under the brand "Freedom Pay". Freedom Pay LLP is registered with the NBK to provide the following payment services, among others: issuance and distribution of electronic money, acceptance and processing of payments made using electronic money.

Cypriot Investment Firms and Regulatory Legislation

Freedom EU is a Cyprus Investment Firm ("CIF"), duly incorporated in the Republic of Cyprus under registration number HE 324220 and authorized and regulated by the Cyprus Securities and Exchange Commission ("CySEC") under license number 275/15.

Freedom EU operates in accordance with the applicable European Union and Cypriot legal and regulatory framework governing investment firms, including compliance with the applicable anti-money laundering and counter-terrorist financing framework and related reporting obligations to the Cyprus Unit for Combating Money Laundering (MOKAS).

Freedom EU complies with, inter alia, the following legislative and regulatory framework:

•Directive 2014/65/EU on markets in financial instruments ("MiFID II"), as amended;

•The Investment Services and Activities and Regulated Markets Law of 2017 (Law 87(I)/2017), as amended;

•Regulation (EU) 2019/2033 on the prudential requirements of investment firms ("IFR") and Directive (EU) 2019/2034 on the prudential supervision of investment firms (“IFD");

•The Prevention and Suppression of Money Laundering and Terrorist Financing Law (Law 188(I)/2007), as amended, and the CySEC Directive for the Prevention and Suppression of Money Laundering and Terrorist Financing;

•Regulation (EU) No 596/2014 on market abuse ("MAR"), as amended;

•Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products ("PRIIPs"), as amended; and

•Applicable Regulatory Technical Standards (RTS), Implementing Technical Standards (ITS), and guidelines issued by the European Securities and Markets Authority (ESMA).

Freedom EU continuously monitors and ensures compliance with regulatory developments, circulars, and guidance issued by CySEC, ESMA, the European Commission, and other competent authorities.

Pursuant to its authorization, Freedom EU is permitted to provide investment services and activities in Cyprus and, under the MiFID II passporting regime, on a cross-border basis within the European Economic Area in accordance with applicable local requirements.

Freedom EU is authorized by CySEC to provide the following investment services:

•Reception and transmission of orders in relation to one or more financial instruments;

•Execution of orders on behalf of clients;

•Dealing on own account;

•Provision of investment advice; and

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•Portfolio management.

In addition, Freedom EU is authorized to provide the following ancillary services:

•Safekeeping and administration of financial instruments, including custodianship and related services;

•Granting credits or loans to investors to allow them to carry out transactions in financial instruments, where Freedom EU is involved in the transaction;

•Foreign exchange services where these are connected to the provision of investment services; and

•Investment research and financial analysis or other forms of general recommendation relating to transactions in financial instruments.

Freedom EU may also provide its services to third countries, subject to compliance with the applicable regulatory framework of such jurisdictions.

Under the prudential framework established by Regulation (EU) 2019/2033 (“IFR”) and Directive (EU) 2019/2034 (“IFD”), Freedom EU is classified as a Class 2 investment firm and is subject to the applicable capital adequacy, liquidity, governance, and risk management requirements. Freedom EU maintains appropriate internal policies, procedures, and controls to ensure ongoing compliance with its regulatory obligations and to safeguard client interests.

Armenian Securities Market Regulation

Armenia's brokerage sector is subject to strict regulatory regime. The primary legal act regulating broker, dealer, and portfolio management activities in Armenia is the Law of the Republic of Armenia "On the Securities Market" No. HO-195-N of October 11, 2007 (the "AR Securities Market Law"). This law establishes the framework for broker and dealer activities, portfolio management services, licensing requirements, and the regulatory oversight carried out by the Central Bank of Armenia (the "CBA").

Based on the AR Securities Market Law and the relevant regulations adopted by the CBA, a comprehensive legal regime for the securities market has been established in Armenia. The current law governing the Armenian securities market consists of (i) the AR Securities Market Law, (ii) regulatory acts adopted by the CBA, which implement and supplement the provisions of the AR Securities Market Law, and (iii) other applicable laws of the Republic of Armenia, which are applied to the extent not otherwise specifically regulated by the AR Securities Market Law and the CBA acts.

In Armenia, brokers and dealers must obtain a license from the CBA to carry out their activities. The license authorizes a brokerage firm to provide brokerage services, dealer services, portfolio management, or a combination thereof. Depending on the license terms, a brokerage firm may also be permitted to hold customer assets in custody or may be limited to intermediary activities without asset custody rights.

Under the AR Securities Market Law, broker-dealer and portfolio management activities must be performed in accordance with the license terms and the CBA regulations on, among other, capital requirements, organizational standards, conduct of business, and customer protection measures. Additional regulations, such as the CBA's "Regulation on Investment Services and Activities," provide detailed rules governing the operations of licensed entities. Freedom AR is subject to the CBA's prudential standards including the requirements to capital and N1 ratio, being the marginal ratio of total capital to risk-weighted assets as determined under the CBA regulation.

All securities market participants in Armenia are subject to the unified regulatory framework administered by the CBA. However, such framework is still developing and, therefore, brokerage firms in Armenia may still face interpretation challenges and practical uncertainties in the cases involving cross-border services or activities not explicitly regulated by Armenian law.

Freedom AR is a licensed investment service provider holding License No. 0021 issued by the CBA on November 9, 2021, authorizing it to carry out the following major regulated activities:

•receiving and forwarding customer instructions for securities transactions,

•providing investment-related advice to customers regarding securities,

•executing securities transactions on behalf of the firm or the customer and at the customer's account,

•executing securities transactions on the firm's own account and in the firm's own name;

•managing the pool of securities,

•carrying out guaranteed or non-guaranteed placement of securities; and

•securities underwriting and trust management.

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According to the AR Securities Market Law, investment companies may also provide supplementary services that do not require a license. Freedom AR provides such supplementary services as custody of securities, execution of foreign currency purchase and sale transactions on its own behalf or on behalf of the customer, preparation and dissemination of research, financial analysis related to securities transactions, and other general investment recommendations.

U.S. Regulation

U.S. Securities Market Regulation

Our U.S. subsidiary FCM is registered as a securities broker dealer with the SEC, is a member of various self-regulatory organizations ("SROs") and securities exchanges, including being a "Blue Line" broker dealer on the floor of the NYSE. FCM has been a member of FINRA since 1994, most recently receiving approval from FINRA in January 2022 to expand its operations to include conducting certain types of investment banking business. Such business is conducted under the name Freedom Capital Markets. FINRA serves as the primary SRO with oversight over FCM, although the NYSE continues to have oversight over FCM's NYSE-related market activities. FINRA regulates many aspects of FCM's business, including registration, education and conduct of its broker-dealer employees, examinations, rulemaking, enforcement of these rules and the federal securities laws, trade reporting and the administration of potential disputes between FCM and its customers. FCM has agreed to abide by the rules of FINRA (as well as those of the NYSE and other SROs), and FINRA has the power to expel, fine and otherwise discipline FCM and its officers, directors and employees. Among the rules that apply to FCM are the uniform net capital rule of the SEC (Rule 15c3-1) and the net capital rule of FINRA. Both rules set a minimum level of net capital a broker dealer must maintain and also require that a portion of the broker dealer's assets be relatively liquid. FINRA may prohibit a member firm from expanding its business or paying cash dividends if resulting net capital falls below FINRA requirements. In addition, FCM is subject to certain notification requirements related to withdrawals of excess net capital. As a result of these rules, our ability to make withdrawals of capital from FCM may be limited. In addition, FCM is licensed as a broker dealer in 36 U.S. states and the District of Columbia, requiring it to comply with applicable laws, rules and regulations of each of those states. A state regulator may revoke a license to conduct securities business in its state and fine or otherwise discipline broker dealers and their officers, directors and employees.

Foreign Corrupt Practices Act

In the United States, the 1970 Foreign Corrupt Practices Act, or FCPA, broadly prohibits foreign bribery and mandates recordkeeping and accounting practices. The foreign countries where our subsidiaries operate have similar anti-bribery and anti-corruption laws imposed on our subsidiaries. The anti-bribery provisions make it illegal for us, either directly or through any subsidiary that we may acquire, to bribe any foreign official for the purpose of obtaining business. The term "public official" is defined broadly to include persons affiliated with government-sponsored or owned commercial enterprises as well as appointed or elected public officials. The recordkeeping provisions require that we and our subsidiaries make and maintain books that, in reasonable detail, reflect our transactions and dispositions of assets and devise and maintain a system of internal accounting controls that enables us to provide reasonable assurance that transactions are properly recorded in accordance with management's authorizations, that transactions are recorded as necessary to permit the preparation of financial statements, that access to our funds and other assets is permitted only in accordance with management's authorizations, and that the recorded accounts for assets are compared periodically with the existing assets to assure conformity. Failure to comply with the FCPA can result in substantial fines and other sanctions. In 2025, the U.S. Department of Justice announced changes to its FCPA enforcement priorities and processes. These changes did not alter our legal obligations under the FCPA.

Foreign Account Tax Compliance Act

The 2010 Foreign Account Tax Compliance Act ("FATCA") was enacted in the U.S. to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions, such as certain of our non-U.S. subsidiaries, to report to the U.S. Internal Revenue Service ("IRS") information about financial accounts held by U.S. taxpayers or by foreign entities in which U.S. taxpayers hold a substantial ownership interest.

The U.S. has entered into intergovernmental agreements with a number of countries establishing mutually agreed-upon rules for the implementation of the data-sharing requirements of FATCA. Cyprus, Kazakhstan, Uzbekistan, Türkiye, and the United Arab Emirates have entered into Model 1 intergovernmental agreements while Armenia has entered into Model 2 agreement. These agreements with the U.S. contain provisions regulating the process for financial institutions in these countries to collect information on U.S. taxpayer accounts and provide that information to the IRS. In general, the requirements of the agreements concern the analysis of new and existing customer accounts to identify U.S. taxpayers. The agreements generally require financial institutions in these countries to identify their customers and analyze their products to identify the accounts of customers affected by FATCA and collect all necessary information to classify those accounts in compliance with the requirements of FATCA. After classifying the accounts, financial institutions generally must regularly present information, including name, taxpayer identification number, and account balance, to the local tax authorities for

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transfer to the IRS. The agreements also generally address when financial institutions in these countries are required to withhold taxes to be remitted to the IRS. Pursuant to certain intergovernmental agreements, our subsidiaries in the relevant countries which are financial institutions are required to obtain customer documentation associated with the indicia of the relevant customer's U.S. tax residency status, as well as related account information, and to report it accordingly. A failure by our subsidiaries to comply with FATCA could result in adverse financial and reputational consequences to us as well as the imposition of sanctions or penalties, including responsibility for the taxes on any funds distributed without the proper withholdings having been made.

AVAILABLE INFORMATION

Our investor relations website is located at https://ir.freedomholdingcorp.com. We use our investor relations website as a channel for disclosing material non-public information and for complying with SEC Regulation FD and our other disclosure obligations. In addition to our investor relations website, our subsidiaries maintain corporate websites and we may use social media to communicate with the public. It is possible that information we post on social media could be deemed to be material to investors. Accordingly, investors should monitor the website, in addition to following our press releases and SEC filings. We are subject to the reporting requirements of the Exchange Act. Reports filed with or furnished to the SEC pursuant to the Exchange Act, including annual and quarterly reports, are available free of charge, through our website. We make them available on our website as soon as reasonably possible after we file them with the SEC. The reports we file with or furnish to the SEC are also available on the SEC's website (www.sec.gov). Our corporate governance policies, code of ethics and Board committee charters are also posted on our investor relations website. The content of our website, the websites of our subsidiaries, and the information we communicate through social media is not intended to be incorporated by reference or otherwise included into this annual report or in any other report or documents that we file with the SEC.