The Compliance Hotline operates according to the following principles:

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

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

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

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

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

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

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

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

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

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

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

A full review is conducted within up to sixty (60) business days (depending on complexity and volume).

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

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

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

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

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