Entry into Force of the New Version of the Regulations and its Annexes

Dear Clients,

Effective from May 4, 2026, the new version of the Regulations on the Provision of Brokerage (Agency) Services on the Securities Market (hereinafter referred to as the “Regulations”) of the Freedom Finance Global PLC (hereinafter referred to as the “Company”), as well as its annexes, will come into force.

In particular, the following amendments and additions have been made:

The following changes have been made:

1. Clause 4.2 of the Regulations has been supplemented with a provision establishing the Client’s obligation to independently monitor the relevance of the documents and information provided to the Company and to promptly submit updated data, as well as the Company’s lack of liability for the Client’s failure to provide updated information in a timely manner;
2. Clause 6.2 has been supplemented with subclause e), which provides for an additional method of submitting instructions via a dedicated web page, used for model portfolios;
3. Clause 6.8 has been amended to include an additional method of signing instructions using a one-time OTP code sent via push notifications in the Company’s application, as well as the possibility of using other authentication and confirmation methods not prohibited by law, if necessary;
4. The Regulations have been supplemented with clause 6.15, which sets out the Client’s ability to submit an instruction for the acquisition of model portfolios and the related conditions;
5. Clause 18.1 has been amended regarding the language in which information is provided to the Client. Taking into account the number of languages in which a Client may register in the Online Trading System (OTS), these changes stipulate that information to the Client may be provided only in Kazakh, Russian, or English, at the Client’s choice;
6. In clause 19.6, the period for which the Company stores the Client’s personal data has been changed from three to six years, in accordance with the requirements of the AIFC legislation;
7. The Regulations have been supplemented with clause 19.14, which provides that the processing of personal data is carried out in accordance with the requirements of the Company’s Personal Data Processing Policy;
8. Throughout the text of the Regulations and in clause 2.9 of Annex 4 to the Regulations, editorial changes have been made to correct spelling, stylistic, or grammatical errors, as well as to reflect the correct translation and legal drafting technique;
9. Annex 1A to the Regulations has been amended regarding the Client’s consent to the procedure for processing their personal data in accordance with the Regulations;
10. Annex 1B to the Regulations has been amended regarding the Client’s consent to the procedure for processing their personal data in accordance with the Regulations;
11. Annex 2B to the Regulations has been supplemented with a separate instruction form for clients, which is completed during onboarding to obtain qualified investor status when opening a brokerage account;
12. Annex 6 to the Regulations (“Certain Types of Transactions”) has been revised and clarified with regard to the following provisions:
    • The investment objectives of clients when using overnight REPO products (D-account) and term REPO have been clarified;
    • The liquidity criteria for securities accepted by the Company as collateral for transactions have been established and detailed;
    • The criteria for selecting counterparties with whom the Company enters into REPO transactions have been defined;
    • The factors taken into account by the Company when determining the size of the discount (haircut) applied to securities serving as collateral for REPO transactions have been specified;
    • The provisions on the separate accounting of the Client’s cash and securities placed in the D-account and used in REPO transactions have been strengthened;
    • The Client is to be informed through the Online Trading System (OTS) of all REPO transactions concluded in their interest;
    • It is expressly stated that the Company does not exercise discretionary management of the Client’s assets in the D-account;
    • The procedure for managing conflicts of interest has been regulated;
    • The Client’s consent has been recorded to the effect that the Company maintains separate accounting of their assets in the D-account in accordance with the requirements of the AIFC Conduct of Business Rules (COB 8.3.16);
    • The rights and obligations of the Client and the Company arising in connection with the conclusion, performance, and termination of REPO transactions have been set out in detail;
    • An exhaustive list of operations that may be carried out on the D-account has been described;
    • The applicable law for transactions concluded under Annex 6 to the Regulations has been determined;
    • Exclusive jurisdiction over disputes related to transactions concluded under Annex 6 has been established – the Court of the Astana International Financial Centre (AIFC Court);
    • The possibility of automatic prolongation (auto-prolongation) of the placement of funds through REPO transactions for a longer period has been introduced.
    
    The full text of the updated Regulations and annexes is available on the Company’s official website: https://fbroker.kz/
    
    If you have any questions, please contact your personal manager or call 7555 (for calls from mobile phones within the Republic of Kazakhstan).
    
    For international calls: +7 (7172) 67-77-55.
    
    Sincerely,
    Public Company Freedom Finance Global PLC