FRHC · Freedom Holding Corp.

Mr. Vogeleer was granted 677 shares of restricted common stock of Freedom Holding Corp. (the "Company") on April 1, 2026, under the Company's 2019 Equity Incentive Plan, pursuant to a Restricted Stock Award Agreement executed on June 11, 2026. The shares became fully vested on June 11, 2026, the date the Restricted Stock Award Agreement was executed and the transaction became effective.

Ms. Williams was granted 677 shares of restricted common stock of Freedom Holding Corp. (the "Company") on April 1, 2026, under the Company's 2019 Equity Incentive Plan, pursuant to a Restricted Stock Award Agreement executed on June 11, 2026. The shares became fully vested on June 11, 2026, the date the Restricted Stock Award Agreement was executed and the transaction became effective.

Mr. Gamble was granted 677 shares of restricted common stock of Freedom Holding Corp. (the "Company") on April 1, 2026, under the Company's 2019 Equity Incentive Plan, pursuant to a Restricted Stock Award Agreement executed on June 11, 2026. The shares became fully vested on June 11, 2026, the date the Restricted Stock Award Agreement was executed and the transaction became effective.

Mr. Cherdabayev was granted 677 shares of restricted common stock of the Company on April 1, 2026, under the Company's 2019 Equity Incentive Plan, pursuant to a Restricted Stock Award Agreement executed on June 11, 2026. The shares became fully vested on June 11, 2026, the date the Restricted Stock Award Agreement was executed and the transaction became effective.

Reflects the weighted average sale price on June 4, 2026. The shares were sold in multiple transactions at prices ranging from $158.62 to $158.82, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average sale price on June 4, 2026. The shares were sold in multiple transactions at prices ranging from $151.43 to $151.66, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average sale price on June 4, 2026. The shares were sold in multiple transactions at prices ranging from $152.00 to $152.59, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average sale price on June 4, 2026. The shares were sold in multiple transactions at prices ranging from $156.00 to $156.95, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average sale price on June 4, 2026. The shares were sold in multiple transactions at prices ranging from $159.00 to $159.50, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Mr. Yerdessov was awarded 83,749 restricted shares of common stock of Freedom Holding Corp. (the "Company") under the Company 2019 Equity Incentive Plan. The shares were deemed fully vested as of the date of the award.

Reflects the weighted average purchase price on February 25, 2026. The shares were purchased in multiple transactions at prices ranging from $119.87 to $120.50, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within such range.

Reflects the weighted average purchase price on February 24, 2026. The shares were purchased in multiple transactions at prices ranging from $120.30 to $121.00, inclusive. The reporting person undertakes to provide Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within such range.

Mr. Tukanov was awarded 9,000 restricted shares of common stock of Freedom Holding Corp. (the "Company") on February 11, 2026, under the Company 2019 Equity Incentive Plan. The shares shall vest as follows, subject to the reporting person's continued service with the Company and achievement of applicable market price conditions: 1,500 shares on February 11, 2026, and 1,500 shares annually thereafter on each January 25 from 2027 through 2031.

Reflects the weighted average sale price on December 29, 2025. The shares were sold in multiple transactions at prices ranging from $125.70 to $125.79, inclusive. The reporting person undertakes to provide the Company, any shareholder of the Company, or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average sale price on November 6, 2025. The shares were sold in multiple transactions at prices ranging from $136.24 to $136.37, inclusive. The reporting person undertakes to provide the Company, any shareholder of the Company, or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average sale price on November 4, 2025. The shares were sold in multiple transactions at prices ranging from $141.81 to $141.92, inclusive. The reporting person undertakes to provide the Company, any shareholder of the Company, or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Mr. Cherdabayev was awarded 757 restricted shares of common stock of Freedom Holding Corp. (the "Company") on September 16, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, vesting of the shares occurred on September 16, 2025.

Ms. Williams was awarded 757 restricted shares of common stock of Freedom Holding Corp. (the "Company") on September 15, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company, vesting of the shares occurred on September 15, 2025.

Mr. Vogeleer was awarded 757 restricted shares of common stock of Freedom Holding Corp. (the "Company") on September 15, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company, vesting of the shares occurred on September 15, 2025.

Mr. Gamble was awarded 757 restricted shares of common stock of Freedom Holding Corp. (the "Company") on September 15, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company, vesting of the shares occurred on September 15, 2025.

Reflects the weighted average purchase price on August 29, 2025. The shares were purchased in multiple transactions at prices ranging from $171.45 to $171.95, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within such range.

Mr. Kerr was awarded 3,309 restricted shares of common stock of Freedom Holding Corp. (the "Company") on July 24, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, vesting of the shares occurred on July 24, 2025.

Mr. Ler was awarded 5,169 restricted shares of common stock of Freedom Holding Corp. (the "Company") on July 09, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, vesting of the shares occurred on July 9, 2025.

Mr. Tashtitov was awarded 5,691 restricted shares of common stock of Freedom Holding Corp. (the "Company") on July 09, 2025, under the Company 2019 Equity Incentive Plan. Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, vesting of the shares occurred on July 9, 2025.

Reflects the weighted average purchase price on July 1, 2025. The shares were purchased in multiple transactions at prices ranging from $146.14 to $146.86, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within such range.

Reflects the weighted average purchase price on June 30, 2025. The shares were purchased in multiple transactions at prices ranging from $143.72 to $144.18, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within such range.

Reflects the weighted average price of purchases on June 20, 2025. The shares were purchased in multiple transactions at prices ranging from $140.36 to $140.96, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within such range.

Mr. Yerdessov was awarded 74,000 restricted shares of common stock of Freedom Holding Corp. (the "Company") under the Company 2019 Equity Incentive Plan. The award was authorized on April 8, 2025; the formalities of the issuance were completed April 11, 2025. The shares were deemed fully vested as of the date of authorization.

Reflects the weighted average price of sales on March 4, 2025. The shares were sold in multiple transactions at prices ranging from $146.00 to $147.00, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average price of sales on February 19, 2025. The shares were sold in multiple transactions at prices ranging from $155.01 to $156.00, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Mr. Lukyanov was awarded 106,000 restricted shares of common stock of Freedom Holding Corp. (the "Company") under the Company 2019 Equity Incentive Plan pursuant to that certain Restricted Stock Award Agreement entered into as of May 18, 2021, by and between the Company and Mr. Lukyanov (the "Agreement"). Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, 21,200 shares will vest annually beginning May 18, 2022 through May 18, 2026. Mr. Lukyanov's previously filed Form 3 inadvertently omitted the unvested restricted shares of common stock from Mr. Lukyanov's beneficially owned securities, which are now reflected in this Form 4.

Reflects the weighted average price of sales on February 19, 2025. The shares were sold in multiple transactions at prices ranging from $156.37 to $157.25, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average price of sales on February 18, 2025. The shares were sold in multiple transactions at prices ranging from $156.67 to $157.66, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average price of sales on February 18, 2025. The shares were sold in multiple transactions at prices ranging from $155.62 to $156.16, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Reflects the weighted average price of sales on February 18, 2025. The shares were sold in multiple transactions at prices ranging from $157.11 to $157.76, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.